FINAL

1999 AMENDMENT TO THE

1997 OZONE SIP REVISION FOR THE

SOUTH COAST AIR BASIN

NOTE

THIS ADOBE ACROBAT VERSION FAITHFULLY

REPRODUCES THE CONTENT OF THIS DOCUMENT.

HOWEVER, DUE TO DIFFERENT PRINTER SETTINGS,

THE FORMAT OF THIS VERSION IS SLIGHTLY DIFFERENT

FROM THE PRINTED VERSION
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

FINAL

1999 AMENDMENTS TO THE

1997 OZONE STATE IMPLEMENTATION PLAN

FOR THE SOUTH COAST AIR BASIN

December 1999

Planning, Rule Development and Area Sources

Deputy Executive Officer

Jack P. Broadbent

Assistant Deputy Executive Officer

Elaine Chang, DrPH

Planning and Rules Manager

Henry Hogo

REVIEWERS:

District Counsel

Barbara Baird

Frances Keeler

PRODUCTION STAFF:

Julie Franco

Felicia Leung

Rachel Valenzuela
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

GOVERNING BOARD

Chair: WILLIAM A. BURKE, Ed.D.

Speaker of the Assembly Appointee

Vice Chair: NORMA J. GLOVER

Councilmember, City of Newport Beach

Cities Representative, Orange County

MEMBERS:

MICHAEL D. ANTONOVICH

Supervisor, Fifth District

Los Angeles County Representative

HAL BERNSON

Councilmember, City of Los Angeles

Cities Representative, Los Angeles County, Western Region

CYNTHIA COAD

Supervisor, 4th District

Orange County Representative

BEATRICE LAPISTO-KIRTLEY

Mayor, City of Bradbury

Cities Representative, Los Angeles County, Eastern Region

MEE HAE LEE

Senate Rules Committee Appointee

RONALD O. LOVERIDGE

Mayor, City of Riverside

Cities Representative, Riverside County

JON D. MIKELS

Supervisor, Second District

San Bernardino County Representative

LEONARD PAULITZ

Councilmember, City of Montclair

Cities Representative, San Bernardino County

S. ROY WILSON, Ed.D.

Supervisor, Fourth District

Riverside County Representative

VACANT

Governor's Appointee

EXECUTIVE OFFICER

BARRY R. WALLERSTEIN, D.Env.
Table of Contents

i

Table of Contents

EXECUTIVE SUMMARY

........................................................................................................................ ES-1

1. INTRODUCTION

Background and Purpose ....................................................................................1-1

Amendment to the 1997 AQMP .........................................................................1-2

Progress in Implementing the 1997 AQMP..............................................1-3

Preliminary Court-Ordered Schedule of 1994 Ozone SIP Control Measures.......1-6

Format of This Document...................................................................................1-8

2. REVISED AQMP CONTROL STRATEGY AND

PROJECTED EMISSION REDUCTIONS

Introduction........................................................................................................2-1

Amendment to the 1997 AQMP VOC and NOx Control Strategy.......................2-1

New Stationary Source Control Measures................................................2-7

1997 AQMP Stationary Source Control Measures

with Revised Adoption/Implementation Schedules ..................................2-9

1997 AQMP Control Measures with Adoption/

Implementation Dates to be Determined ................................................2-10

Revisions to the 1997 AQMP Long-Term Control Measures.................2-12

Projected Emission Reductions.........................................................................2-12

SIP Emission Commitment ....................................................................2-16

Comparison of Emission Reductions in This

Amendment to Prior Ozone SIP Revisions.............................................2-21

APPENDIX A SUPPORTING DOCUMENTATION ON THE REMOVAL OF

31 1994 OZONE SIP CONTROL MEASURES FROM THE

1997 AQMP

APPENDIX B NEW AND REVISED STATIONARY SOURCE CONTROL

MEASURES
List of Tables

ii

List of Tables

TABLE 1-1 VOC and NOx Emission Reductions in 2010 Associated with

District Control Measures Adopted From October 1996

Through September 1999....................................................................... 1-4

TABLE 1-2 Preliminary Court-Ordered Schedule of 1994 Ozone SIP

Control Measures (VOC or NOx).......................................................... 1-7

TABLE 2-1 Revised AQMP Short- and Intermediate-Term Control Measures,

Implementing Agency, Adoption Date and Implementation Period ........ 2-2

TABLE 2-2 Revised Long Term Control Measures, Implementing Agency,

Adoption Date and Implementation Period ............................................ 2-4

TABLE 2-3 Comparison of the Adoption and Implementation Dates of the

Control Measures Provided in the 1997 AQMP to the Adoption

and Implementation Dates Under the Proposed Amendment.................. 2-5

TABLE 2-4 Emission Reductions in 2010 Associated with the

Proposed Revised Control Strategy.......................................................2-14

TABLE 2-5 SCAQMD VOC and NOx Emission Reduction Rules

Adopted Since the Submittal of the 1994 Ozone SIP

to U.S. EPA (November 1994). ............................................................2-17

TABLE 2-6 2010 Planning Inventory Emission Reductions Commitment

by Year Achieved through Rule Adoption and Implementation

(Tons/Day)...........................................................................................2-19

TABLE 2-7 Amendment to the South Coast Air Basin Stationary

VOC Emissions (Tons/Day) Budget by Milestone Year .......................2-21

TABLE 2-8 Comparison Between the 1997 AQMP and the

1999 Amendment VOC Emission Reductions for

Short-, Intermediate-, and Long-Term Stationary Source Measures

for 2010 Based on Summer Planning Inventory (Tons per Day) ...........2-22

TABLE 2-9 Emission Reductions from Adopted Rules with

Future Complance Dates.......................................................................2-23
List of Tables

iii

TABLE 2-10 Summary of Rate-of-Progress Calculations for VOC -

South Coast Air Basin ..........................................................................2-24

TABLE 2-11 Summary of Rate-of-Progress Calculations for NOx -

South Coast Air Basin ..........................................................................2-25
List of Figures

iv

List of Figures

FIGURE 2-1 Comparison Of Remaining VOC Stationary Source Emissions

After Implementation of the 1999 Amendment,

1997 AQMP, and the 1994 Ozone SIP................................................ 2-26
EXECUTIVE SUMMARY
Executive Summary

ES - 1

The South Coast Air Quality Management District (District) adopted the 1997 Air

Quality Management Plan (AQMP) in November 1996. The 1997 AQMP provides

updated technical information relative to baseline emission inventories and control

measures to achieve the federal ozone and particulate matter (PM10) air quality

standards. In addition, the 1997 AQMP provides a revised attainment demonstration for

ozone, PM10, and carbon monoxide, and a maintenance plan for nitrogen dioxide. As

part of the adoption of the 1997 AQMP, the District requested that the 1997 AQMP

replace the previously submitted ozone, PM10, and carbon monoxide state

implementation plans (SIPs). On January 23, 1997, the California Air Resources Board

(ARB) approved those portions of the 1997 AQMP pertaining to the federal Clean Air

Act requirements for SIP submittals. The 1997 AQMP was subsequently submitted to

the U.S. Environmental Protection Agency (EPA) for approval.

On January 12, 1999, the U.S. EPA proposed partial approval/disapproval of the ozone

portion of the 1997 AQMP as a revision to the 1994 California Ozone SIP (64 FR 1770).

The proposed disapproval primarily pertained to the control measure strategy provided in

the 1997 AQMP (referred to as the 1997 Ozone SIP Revision). The cited reasons were

as follows: 1) the District is behind in adoption of control measure commitments; 2) the

overall control strategy is an impermissible relaxation of the SIP; 3) the Plan includes

unlawful assignments of control measure responsibility to EPA; and 4) the 1997 Ozone

Plan violates the intent of the Clean Air Act Section 182(e)(5) by increasing the

proportion of measures in the plan that were considered long-term measures. To-date,

U.S. EPA has not taken final action on the 1997 Ozone SIP Revision.

Since the adoption of the 1997 AQMP, three environmental/community organizations

filed a lawsuit pertaining to non-implementation of the 1994 California Ozone SIP for

the South Coast Air Basin. They cited that the District has not acted on 32 1994 Ozone

SIP control measures which were deleted or placed in a “Further Evaluation” status in

the 1997 AQMP. On August 27, 1999, the U.S. District Court issued a preliminary order

that the District must continue to implement the approved 1994 Ozone SIP until such

time that the U.S. EPA approves a revised ozone SIP for the South Coast Air Basin, and

establishing a preliminary schedule for adoption and implementation of these measures.

This Amendment to the 1997 AQMP revises the implementation of the stationary source

control element of the 1997 AQMP control strategy that the District is responsible for

implementing. This Amendment provides greater emission reductions in the near-term

than the original 1997 AQMP control strategy. This Amendment is limited to the ozone

portion of the 1997 AQMP. As such, 1997 AQMP control measures specific to PM10

would remain the same and are not included in this Amendment. This Amendment does

not revise any of the control measures that the state or federal agencies will be

implementing. In addition, the ozone attainment demonstration, future emission baseline
1999 Amendment to the 1997 Ozone SIP Revision

ES - 2

inventories, carrying capacity, and 2010 emission budgets remain the same as those

provided in the 1997 AQMP. The Amendment does provide additional emission

reductions for some of the interim milestone years.

Specifically, the 1999 Amendment:

• Revises the 1997 AQMP control strategy to reflect adoption of 14 stationary and

mobile source control measures that the District is responsible for implementing. In

addition, one existing rule was amended to address concerns raised by the California

Air Resources Board.

• Adds four short-term stationary source control measures to reduce VOC emissions.

These short-term control measures represent implementation of portions of the longterm stationary source control measures such that the reliance on the long-term

controls is reduced.

• Adds four new short-term stationary source control measures to reduce VOC

emissions in the near-term. Many of these measures were developed as part of the

District’s technical assessments for the next comprehensive AQMP revision and

through compliance/emission audits of various stationary sources. The emission

reductions associated with these measures would further reduce the reliance on the

long-term measures identified in the 1997 AQMP.

• Changes the adoption/implementation schedule for 13 short-term stationary source

control measures provided in the 1997 AQMP. Three of the 13 control measures are

to be implemented earlier.

• Revises the VOC emission budgets for some of the interim milestone years.

• Provides explicit SIP emissions commitment in attaining the federal ozone air quality

standard.

The District continues to believe that the technical foundation for the 1997 AQMP

control strategy is fundamentally sound. However, given that almost three years have

past since the 1997 AQMP was adopted and the state of knowledge on the current

available control technologies has evolved, the District staff has identified control

approaches to implement portions of the 1997 AQMP long-term control measures. In

addition, District staff has identified several new control approaches that could be

implemented in the near-term.

The District also believes that as rules and regulations are developed for each of the

control measures provided in this Amendment, emission limits associated with the rule

or regulation that are certain to occur should be submitted to U.S. EPA to meet the South

Coast Air Basin’s SIP obligations. In addition, emission reductions associated with other
Executive Summary

ES - 3

actions either mandatory or voluntary, which are enforceable, should be credited towards

meeting SIP emission reduction obligations. If during the rule adoption phase, emission

limits expected to be achieved for a control measure are not fully realized, substitution

reductions will be identified, until such time that the overall emission goals are met.

The District believes that with this Amendment, there is greater assurance than with the

1997 AQMP or the 1994 Ozone SIP that emission reduction benefits will be realized

earlier. The District also believes that the ozone SIP should reflect all activities that

affect the amount of emission reductions that are actually occurring regardless if these

reductions occur through formal rule and regulations developed by the District or

through other actions that are either mandatory or voluntary.
CHAPTER 1

INTRODUCTION

Background and Purpose

Amendment to the 1997 AQMP

Progress in Implementing the 1997 AQMP

Preliminary Court-Ordered of 1994 Ozone SIP Control Measures

Format of This Document
Chapter 1 Introduction

1 - 1

BACKGROUND AND PURPOSE

The South Coast Air Quality Management District (District) adopted the 1997 Air

Quality Management Plan (AQMP) in November 1996. The 1997 AQMP provides

updated technical information relative to baseline emission inventories and control

measures to achieve the federal ozone and particulate matter (PM10) air quality

standards. In addition, the 1997 AQMP provides a revised attainment demonstration for

ozone, PM10, and carbon monoxide, and a maintenance plan for nitrogen dioxide. As

part of the adoption of the 1997 AQMP, the District requested that the 1997 AQMP

replace the previously submitted ozone, PM10, and carbon monoxide state

implementation plans (SIPs). On January 23, 1997, the California Air Resources Board

(ARB) approved those portions of the 1997 AQMP pertaining to the federal Clean Air

Act requirements for SIP submittals. The 1997 AQMP was subsequently submitted to

the U.S. Environmental Protection Agency (EPA) for approval.

Since the adoption of the 1997 AQMP, three environmental/community organizations

filed a lawsuit pertaining to non-implementation of the 1994 California Ozone SIP for

the South Coast Air Basin. They cited that the District has not acted on 32 1994 Ozone

SIP control measures which were deleted or placed in a “Further Evaluation” status in

the 1997 AQMP. These measures were determined to be infeasible or unnecessary to

implement by the District upon further evaluation. The environmental/community

organizations contended that the District must continue to implement these measures

even though these measures were not contained in the 1997 AQMP. On August 27,

1999, the U.S. District Court issued a preliminary order that the District must continue to

implement the approved 1994 Ozone SIP until such time that the U.S. EPA approves a

revised ozone SIP for the South Coast Air Basin and establishing a preliminary schedule

for adoption and implementation of these measures.

In addition, the U.S. EPA has proposed partial approval/disapproval of the ozone portion

of the 1997 AQMP as a revision to the 1994 California Ozone SIP (64 FR 1770). The

proposed disapproval principally pertained to the control measure strategy provided in

the 1997 AQMP (referred to as the 1997 Ozone SIP Revision). The cited reasons were

as follows: 1) the District is behind in adoption of control measure commitments; 2) the

overall control strategy is an impermissible relaxation of the SIP; 3) the Plan includes

unlawful assignments of control measure responsibility to EPA; and 4) the 1997 Ozone

Plan violates the intent of the Clean Air Act Section 182(e)(5) by increasing the

proportion of measures in the plan that were considered long-term measures. The

District strongly disagrees with U.S. EPA’s position on these matters and has provided

comments to U.S. EPA regarding the proposed disapproval (See Appendix A for

discussion of correspondence submitted on February 11, 1999). To-date, U.S. EPA has

not taken final action on the 1997 Ozone SIP Revision.
1999 Amendment to the 1997 Ozone SIP Revision

1 - 2

Since November 1996 (the adoption date of the 1997 AQMP), the District has adopted

14 stationary and mobile source volatile organic compounds (VOC) and oxides of

nitrogen (NOx) control measures provided in the 1997 AQMP. In addition, the District

has amended one of its existing stationary source rules to address the ARB’s action on

the 1997 AQMP.

In preparation for the next comprehensive AQMP revision, District staff evaluated new

control concepts as well as the feasibility of implementing the remaining 1997 AQMP

stationary source control measures including the stationary source long-term measures.

As part of the evaluation, District staff: 1) identified four new short-term control

measures that could be adopted in the near-term; 2) identified portions of the 1997

AQMP long-term stationary source control measures that could be specified in greater

detail and moved forward as new short-term control measures; and 3) determined that the

remaining short-term control measures provided in the 1997 AQMP should be revised to

contain new adoption/implementation dates with accelerated implementation dates for

three measures. As such, an amendment to the 1997 AQMP to include the new shortterm control measures and revise the overall control strategy to attain the federal ozone

air quality standard is warranted at this time. This Amendment intends to address U.S.

EPA’s proposed disapproval of the 1997 Ozone SIP Revision to the greatest degree

feasible within the District’s ability and helps ensure that the 1997 AQMP complies with

or exceeds federal requirements.

AMENDMENT TO THE 1997 AQMP

The Amendment to the 1997 AQMP revises the stationary source control element of the

1997 AQMP that the District is responsible for implementing. This Amendment

provides greater emission reductions in the near-term than the original 1997 AQMP

control strategy. Since this Amendment is limited to the ozone portion of the 1997

AQMP, 1997 AQMP control measures specific to PM10 would remain the same and are

not included in this amendment. This Amendment does not revise any of the control

measures that the state or federal agencies have or will be implementing. In addition, the

ozone attainment demonstration, future emission baseline inventories, carrying capacity,

and 2010 emission budgets remain the same as those provided in the 1997 AQMP. The

Amendment does provide additional VOC emission reductions for some of the interim

milestone years.

Specifically, this Amendment makes the following changes to the 1997 AQMP control

strategy:

• Revises the 1997 AQMP control strategy to reflect adoption of 14 stationary and

mobile source control measures that the District is responsible for implementing and
Chapter 1 Introduction

1 - 3

includes one existing rule that was recently amended to address concerns raised by

ARB.

• Adds four short-term stationary source control measures to reduce VOC emissions.

These short-term control measures represent implementation of portions of the longterm stationary source control measures such that the reliance on the long-term

controls is reduced.

• Adds four new short-term stationary source control measures to reduce VOC

emissions in the near-term. Many of these measures were developed as part of the

District’s technical assessments for the next comprehensive AQMP revision and

through compliance/emission audits of various stationary sources. The emission

reductions associated with these measures would further reduce the reliance on the

long-term measures identified in the 1997 AQMP.

• Changes the adoption/implementation schedule for 13 short-term stationary source

control measures provided in the 1997 AQMP. Three of the 13 control measures are

to be implemented earlier.

• Revises the VOC emission budgets for some of the interim milestone years.

Progress in Implementing the 1997 AQMP

Progress in implementing the 1997 AQMP can be measured by the number of control

measures that have been adopted as rules and the resulting tons of pollutants targeted for

reduction. Since October 1996 (the 1997 AQMP provided a list of 1994 Ozone SIP

control measures adopted through September 1996), 14 control measures have been

adopted by the District through September 30, 1999 to reduce VOC and NOx emissions.

In addition, the District amended one existing rule to address an ARB request. Table 1-1

lists the existing rule and the District stationary and mobile source control measures from

the 1997 AQMP that were adopted through September 30, 1999. The targeted emission

reductions associated with each of the 1997 AQMP control measures and the emission

reductions achieved through rule adoption and implementation for each measure are also

provided in Table 1-1.

During the period from 1996 to September 30, 1999, the District adopted rules that

achieved 108.1 and 4.2 tons/day (tpd) of VOC and NOx emission reductions,

respectively. These emission reductions represent 28.3 tpd and 1.8 tpd more VOC and

NOx emission reductions, respectively, than the commitment made in the 1997 AQMP

for that time period.
1999 Amendment to the 1997 Ozone SIP Revision

1 - 4

TABLE 1-1

VOC and NOx Emission Reductions in 2010 Associated with District Control Measures

Adopted From October 1996 Through September 1999

Control

Measure/

Rule

Title 1997 AQMP

Commitment

Achieved

Through Rule

Implementation

CTS-02H

(Rule 1107)

Emission Reductions from Metal Parts and

Products (VOC)

5.4 8.8

CTS-02M

(Rule 1145)

Emission Reductions from Plastic, Rubber, Glass

Coatings (VOC)

1.7 1.2

CTS-02N

(Rule 1122)

Emission Reductions from Solvent Degreasers

(VOC)

35.2 48.1

CTS-03

(--)∗

Consumer Product Education Labeling Program

(VOC)

0.0 0.0

CTS-04

(--)*

Public Awareness/Education Programs - Area

Sources (VOC)

0.0 0.0

CTS-07

(Rule 1113) **

Further Emission Reductions from Architectural

Coatings (VOC)

39.3 49.8

CMB-02B

(Rule 1146.2)

Emission Reductions from Small Boilers and

Process Heaters (NOx)

2.4 4.2***

CMB-03

(Rule 2506)

Area Source Credit Programs (NOx) 0.0 0.0

CMB-07

(Rule 1118)†

Emission Reductions from Petroleum Refinery

Flares (All)

0.0 0.0

CMB-04

(Rule 2506)

Area Source Credit for Energy

Conservation/Efficiency (NOx)

0.0 0.0

 

∗ CTS-03, CTS-04, and MSC-02 are implemented through the District’s Public Outreach Programs. Actions to

implement these measures were approved by the District Governing Board in September 1998, March 1999, and

June 1999, respectively. There were no emission reductions assigned to these measures in the 1997 AQMP.

** CTS-07 was adopted in two phases. The first phase was adopted in November 1996 and the second phase in May

1999.

*** Rule 1146.2 is expected to achieve 7.9 tons/day of NOx reductions. However, only 4.2 of the 7.9 tons/day

reductions were included in the 1997 AQMP baseline emissions inventory.

†

Phase I of CMB-07 was adopted March 1998. Additional rulemaking may occur pending the findings of the

measurement program.
Chapter 1 Introduction

1 - 5

TABLE 1-1

Concluded.

Control

Measure/

Rule

Title 1997 AQMP

Commitment

Achieved

Through Rule

Implementation

MSC-02

(--)*††

In-Use Compliance Program for Air Pollution

Control Equipment (All)

0.0 0.0

PRC-03

(Rule 1138)

Emission Reductions from Restaurant Operations

(VOC, PM10)

1.2 0.2

FLX-02

(Rule 2501)

Air Quality Investment Program (All) 0.0 0.0

MON-10

(Rule 1613)

Emission Reduction Credit for Truck Stop

Electrification (All)

0.0 0.0

Rule 1104 Wood Flat Stock Coating Operations (VOC) N/A (negligible)

Total

VOC =79.8

NOx = 2.4

VOC = 108.1

NOx = 4.2

 

†† Based on District technical assessments, many of the pieces of equipment subject to MSC-02 were found to meet

certification standards for their useful life. As such, further emission reductions would be insignificant. However,

public outreach programs were developed to promote the use of the cleaner technologies.
1999 Amendment to the 1997 Ozone SIP Revision

1 - 6

PRELIMINARY COURT-ORDERED SCHEDULE OF 1994 OZONE SIP

CONTROL MEASURES

On August 27, 1999, the U.S. Central District Court of California provided an

“intended” decision ordering that 31 of the 32 control measures from the 1994 Ozone

SIP must still be implemented even though the District considers them to be infeasible,

not cost-effective to implement, and/or not necessary to achieve the federal 1-hour ozone

air quality standard. These measures include ridesharing for special event centers (e.g.,

the Staples Arena or the Anaheim Pond), shopping centers, and pollution controls for

facilities that no longer exist such as the General Motors Van Nuys plant. The Court

noted that it is constrained by the federal Clean Air Act and must order implementation

of all measures contained in an approved SIP.

Table 1-2 provides a list of the 31 measures that the U.S. Court will likely order the

District to implement. Table 1-2 also provides the Court’s proposed adoption and

implementation dates for each measure. In its proposed partial disapproval of the 1997

Ozone SIP Revision, the U.S. EPA indicated that there was not sufficient evidence

documenting the removal of the 31 1994 Ozone SIP control measures. To address this

issue, this Amendment provides in Appendix A of this document, reference to additional

information that further demonstrates the removal of these measures from the 1997

AQMP. Much of this information was previously provided by the District in its court

filings during the litigation on this matter.
Chapter 1 Introduction

1 - 7

TABLE 1-2

Preliminary Court-Ordered Schedule of 1994 Ozone SIP Control Measures (VOC or NOx)

CM# Title Proposed

Adoption Date

Proposed

Implementation Period

CTS-A Emission Reductions from Electronic Components September 2000 September 2001

CTS-C Further Emission Reductions from Solvent Cleaning Operations November 2000 November 2001

CTS-D Further Emission Reductions from Marine and Pleasure Craft

Coating Operation

May 2001 May 2003

CTS-E Further Emission Reductions from Adhesives November 2000 November 2002

CTS-F Further Emission Reductions from Motor Vehicle and Mobile

Equipment Non-Assembly Line Coating Operations

April 2001 April 2003

CTS-G Further Emission Reductions from Paper, Fabric and Film

Coating Operations

September 2000 September 2002

CTS-H Further Emission Reductions from Metal Parts and Products September 2001 September 2005

CTS-I(1)

CTS-I(2)

Further Emission Reductions from Screen Printing Operations October 1999 October 2000 (1)

October 2002 (2)

CTS-J Further Emission Reductions from Wood Products November 2000 November 2005

CTS-K* Further Emission Reductions from Aerospace Assembly and

Component Manufacturing Operations (Rule 1124)

CTS-L Emission Reductions from Automotive Assembly November 2000 November 2001

CTS-07 Further Emission Reductions from Architectural Coatings October 2000 October 2002 to October 2007

ADV-CTS-02 Emission Reductions from Solvents and Coatings November 2000 November 2001 to November 2010

FUG-01 Emission Reductions from Organic Liquid Transfer and Loading June 2000 December 2001

FUG-02 Emission Reductions from Active Draining of Liquid Products August 2000 August 2001

FUG-04 Further Emission Reductions of Fugitive Sources Phase I - October 1999

Phase II - October 2001

Phase I - October 2001

Phase II - October 2003

RFL-02 Further Emission Reductions from Gasoline Dispensing Facilities October 1999 October 2001 to October 2004

RFL-03 Emission Reductions from Pleasure Boat Fueling Operations October 2000 October 2001

MSC-02 In-Use Compliance Program for Air Pollution Control Equipment October 2000 October 2001

PRC-02 Further Emissions from Bakeries October 2000 October 2002 to October 2005

PRC-03 Emission Reductions from Restaurant Operations Phase I - October 1999

Phase II - October 2002

Phase I - October 2000 to October 2002

Phase II - October 2002 to October 2004

WST-01 Emission Reductions from Livestock Waste October 2000 October 2001 to October 2003

WST-03 Emission Reductions from Waste Burning October 2000 October 2002

WST-04 Disposal of Materials Containing VOCs March 2000 March 2002

CMB-02F Control of Emissions from Combustion Equipment December 2000 June 2000 to June 2008

CMB-05 Clean Stationary Fuels December 2000 December 2001 to December 2010

ISR-01 Special Event Centers September 2001 September 2001 to September 2004

ISR-02 Shopping Centers June 2001 June 2001 to June 2005

ISR-03 Registration and Commercial Vehicles Phase I - July 2000

Phase II - July 2002

Phase I - July 2000

Phase II - July 2003 to July 2005

ISR-04 Airport Ground Access Phase I - October 2001 Phase I - October 2002

ISR-05 Trip Reduction for Schools February 2002 February 2003 to February 2007

* Control measure CTS-K was included as part of the litigation. However, this measure was not included in the preliminary Court decision.
1999 Amendment to the 1997 Ozone SIP Revision

1 - 8

FORMAT OF THIS DOCUMENT

Chapter 2, “Revised AQMP Control Strategy and Projected Emission Reductions,”

presents the revisions to the 1997 AQMP control strategy and the adoption and

implementation schedule for the revised control strategy. The emission reductions

associated with the revised AQMP control measures and the revised VOC emission

reductions for the federal Rate-of-Progress milestone years are also provided in this

chapter.

Appendix A, “Supporting Documentation on the Removal of 31 1994 Ozone SIP Control

Measures from the 1997 AQMP” provides additional information on the infeasibility and

impracticability of the 31 control measures that the court has ordered the District to

implement.

Appendix B, “New and Revised Control Measures” provides detailed descriptions of the

new and revised control measures.
CHAPTER 2

REVISED AQMP CONTROL STRATEGY AND

PROJECTED EMISSION REDUCTIONS

Introduction

Amendment to the 1997 AQMP VOC and NOx Control Strategy

New Stationary Source Control Measures

1997 AQMP Stationary Control Measures

with Revised Adoption/Implementation Schedules

1997 AQMP Control Measures with Adoption/

Implementation Dates to be Determined

Projected Emission Reductions

SIP Emission Commitment

Comparison of Emission Reductions in This Amendment to Prior

Ozone SIP Revisions
Chapter 2 Revised AQMP Control Strategy

2 - 1

INTRODUCTION

As discussed in Chapter 1, this Amendment provides revisions to the 1997 AQMP

control strategy. Specifically, four short-term stationary source control measures that

implement portions of the 1997 AQMP long-term control measures and four new

stationary source control measures that are developed based on District technical

assessments and compliance auditing, are added to the control strategy. In addition, 13

of the 1997 AQMP control measure have revised adoption/implementation dates. As a

result, greater emission reductions are expected in the near-term and the emission

reduction commitments for the long-term control measures in the 1997 AQMP are

reduced to reflect the additional emission reductions from the short-term control

measures. This chapter provides a description of each of the new control measure,

explanations for the revised adoption/implementation dates of the 13 control measures,

and revisions to the remaining long-term control measures.

AMENDMENT TO THE 1997 AQMP VOC AND NOX CONTROL

STRATEGY

As discussed in Chapter 1, the 1997 AQMP control strategy has changed due to the

adoption of 14 VOC and NOx control measures and the availability of new information.

This Amendment adds eight short-term stationary source control measures to the AQMP

control strategy and revises the adoption/implementation dates of 13 of the remaining

1997 AQMP short-term stationary source control measures that the District is

responsible for implementing. Table 2-1 provides a list of the short-term control

measures provided in this Amendment includingadoption/implementation dates. Table

2-2 shows the long-term stationary source control measures from the 1997 AQMP that

would continue to be evaluated and brought forward for adoption as technologies are

available. Table 2-3 shows a comparison of the adoption and implementation dates for

the remaining short- and intermediate-term control measures from the 1997 AQMP

compared to the adoption and implementation dates provided in this Amendment. The

following sections provide a brief discussion of each of the new control measures. More

detailed descriptions of each of the new control measures and revisions to some of the

remaining 1997 AQMP control measures are provided in Appendix B.

Table 2-1 does not include two 1997 AQMP short-term stationary source control

measures (CMB-09 - Emission Reductions from Petroleum Refinery FCCUs and PRC01 - Emission Reductions from Woodworking Operations) needed for PM10 attainment.

However, the two measures are still part of the 1997 PM10 SIP submittal and are not

being replaced.
1999 Amendment to the 1997 Ozone SIP Revision

2 - 2

TABLE 2-1

Revised AQMP Short- and Intermediate-Term Control Measures,

Implementing Agency, Adoption Date and Implementation Period

Control

Measure

Number

Control Measure

Name

Implementing

Agency

Adoption

Date

Implementation

Period

SHORT- AND INTERMEDIATE-TERM MEASURES

Surface Coating and Solvent Use

CTS-02C(P2)* Further Emission Reductions from

Solvent Cleaning Operations (Rule

1171) (VOC)

SCAQMD 1999 2002

CTS-02E Emission Reductions from

Adhesives (Rule 1168) (VOC)

SCAQMD/

ARB

2000 2007-2008

CTS-02O Emission Reductions from Solvent

Usage (Rule 442) (VOC)

SCAQMD 2000 2002

CTS-07(P3) Further Emission Reductions from

Architectural Coatings and Cleanup

Solvents (Rule 1113) (VOC)

SCAQMD 2003 2006-2008

CTS-08* Further Emission Reductions from

Industrial Coating and Solvent

Operations (VOC)

SCAQMD Phase I: 2002

Phase II: 2003

Phase I: 2004-2008

Phase II: 2005-2008

CTS-09 Further Emission Reductions from

Large Solvent and Coating Sources

(VOC)

SCAQMD Phase I: 2000

Phase II: 2002

Phase I: 2003-2004

Phase II: 2005-2006

Petroleum Operations and Fugitive Emissions

FUG-03 Further Emission Reductions from

Floating Roof Tanks (Rule 463)

(VOC)

SCAQMD TBD TBD

FUG-04 Further Emission Reduction from

Fugitive Sources (Rule 1173)

(VOC)

SCAQMD (a) (a)

FUG-05 Further Emission Reductions from

Large Fugitive VOC Sources

(VOC)

SCAQMD Phase I: 2001

Phase II: 2002

Phase III: 2003

Phase I: 2003-2006

Phase II: 2004-2007

Phase III: 2005-2008

* CTS-02C(P2) and portions of CTS-08 were adopted in October 1999 as part of amendments to Rule

1171 and 1130, respectively, subsequent to the release of the draft 1999 Amendment. The control

measures are kept in this section of this Amendment for purposes of SIP reduction commitment

tracking.

(a) Due to potential double-counting, rule development for this measure will be combined with FUG-05.
Chapter 2 Revised AQMP Control Strategy

2 - 3

TABLE 2-1

(continued)

Control

Measure

Number

Control Measure

Name

Implementing

Agency

Adoption

Date

Implementation

Period

Petroleum Operations and Fugitive Emissions (cont.)

FUG-06 Control of Methanol Emissions from

Refinery Hydrogen Plant Vents

SCAQMD 2000 2001-2003

RFL-02(P2) Further Emission Reductions from

Gasoline Dispensing Facilities (Rule

461) (VOC)

SCAQMD/

ARB

2000 2001-2002

Combustion Sources

CMB-06 Emission Standards for New

Commercial and Residential Water

Heaters (R1121) (NOx)

SCAQMD 1999 2002-2005(b)

Miscellaneous Sources

PRC-03(P2) Further Emission Reductions from

Restaurant Operations (VOC, PM10)

SCAQMD 2000 2001 (new)

2003 (retrofit)

PRC-06 Further Emission Reductions from

Industrial Processes (VOC)

SCAQMD 2001 2004-2007

MSC-01 Promotion of Lighter Color Roofing

and Road Materials and Tree

Planting Programs (All Pollutants)

SCAQMD,

Local

Government

TBD TBD

MSC-03 Promotion of Catalyst-Surface

Coating Technology Programs (All

Pollutants)

SCAQMD TBD TBD

WST-01 Emission Reductions from Livestock

Waste (VOC, Ammonia)

SCAQMD 2002 2004

WST-02 Emission Reductions from

Composting (VOC, PM10,

Ammonia)

SCAQMD 2001 2004-2006

WST-03 Emission Reductions from Waste

Burning (Implemented through

Memorandum of Understandings)

SCAQMD,

Local Fire

Agencies

-- 2002

(b) A public hearing for the adoption of this measure is scheduled for December 1999. Depending on the

outcome of this hearing, the implementation period may change. However, equivalent reductions by

2010 are expected.
1999 Amendment to the 1997 Ozone SIP Revision

2 - 4

TABLE 2-1

(concluded)

Control

Measure

Number

Control Measure

Name

Implementing

Agency

Adoption

Date

Implementation

Period

Miscellaneous Sources (cont.)

WST-04 Disposal of Materials Containing

Volatile Organic Compounds (VOC)

SCAQMD 2000 2002

FSS-04 Emission Charges of $5,000 per Ton

of VOC for Stationary Sources

Emitting Over 10 Tons per Year

(VOC)

SCAQMD TBD TBD

Compliance Flexibility Programs

FLX-01 Intercredit Trading Program (All) SCAQMD TBD TBD

TABLE 2-2

Revised Long Term Control Measures, Implementing Agency,

 Adoption Date and Implementation Period

Control

Measure

Number

Control Measure

Name

Implementing

Agency

Adoption

Date

Implementation

Period

LONG -TERM MEASURES

Stationary Sources

ADV-CLNG* Solvent Cleaning and Degreasing

Operations (VOC)

SCAQMD 2003-2004 2005

ADV-CTS Miscellaneous Industrial Coating and

Solvent Operations (VOC)

SCAQMD 2003-2005 2006-2010

ADV-FUG Fugitive Emissions (VOC) SCAQMD 2003-2005 2006-2010

ADV-PRC Industrial Process Operations (VOC) SCAQMD 2003-2005 2006-2010

* This measure was adopted in October 1999 as part of amendments to Rule 1171. However, the

expected reductions are subject to technology assessments in 2003 and 2004 prior to implementation in

2005.
Chapter 2 Revised AQMP Control Strategy

2 - 5

TABLE 2-3

Comparison of the Adoption and Implementation Dates of the Control Measures

Provided in the 1997 AQMP to the Adoption and Implementation Dates

Under the Proposed Amendment

Adoption Date Implementation Period

Measure

Number

Control Measure

Name

1997

AQMP

1999

Amendment

1997

 AQMP

1999

Amendment

SHORT- AND INTERMEDIATE-TERM MEASURES

Surface Coating and Solvent Use

CTS-02E Emission Reductions from

Adhesives (Rule 1168)

(VOC)

2000 2000 2007-2010 2007-2008

CTS-02O Emission Reductions from

Solvent Usage (Rule 442)

(VOC)

2000 2000 2000-2005 2002

Petroleum Operations and Fugitive Emissions

FUG-03 Further Emission

Reductions from Floating

Roof Tanks (Rule 463)

(VOC)

1999 TBD 2000 TBD

FUG-04 Further Emission Reduction

from Fugitive Sources (Rule

1173) (VOC)

1997 (a) 1997 (a)

Combustion Sources

CMB-06 Emission Standards for New

Commercial and Residential

Water Heaters (R1121)

(NOx)

1999 1999 2003-2013 2002-2005(b)

Miscellaneous Sources

PRC-03(P2) Further Emission

Reductions from Restaurant

Operations (VOC, PM10)

1997 2000 2000-2004 2001 (new)

2003 (retrofit)

(a) Due to potential double-counting, rule development for this measure will be combined with FUG-05.

(b) A public hearing for the adoption of this measure is scheduled for December 1999. Depending on the

outcome of this hearing, the implementation period may change. However, equivalent reductions by

2010 are expected.
1999 Amendment to the 1997 Ozone SIP Revision

2 - 6

TABLE 2-3

(concluded)

Adoption Date Implementation Period

Measure

Number

Control Measure

Name

1997

AQMP

1999

Amendment

1997

 AQMP

1999

Amendment

Miscellaneous Sources (cont.)

MSC-01 Promotion of Lighter Color

Roofing and Road Materials

and Tree Planting Programs

(All Pollutants)

1999 TBD 2000 TBD

MSC-03 Promotion of CatalystSurface Coating Technology

Programs (All Pollutants)

1998 TBD 2000-2004 TBD

WST-01 Emission Reductions from

Livestock Waste (VOC,

Ammonia)

1998 2002 2004-2006 2004

WST-02 Emission Reductions from

Composting (VOC, PM10,

Ammonia)

1998 2001 2004-2006 2004-2006

WST-03 Emission Reductions from

Waste Burning

(Implemented through

Memorandum of

Understandings)

1997 -- 1997-2010 2002

WST-04 Disposal of Materials

Containing Volatile Organic

Compounds (VOC)

1997 2000 1998-2001 2002

FSS-04 Emission Charges of $5,000

per Ton of VOC for

Stationary Sources Emitting

Over 10 Tons per Year

(VOC)

TBD TBD TBD TBD

Compliance Flexibility Programs

FLX-01 Intercredit Trading Program

(All)

1997 TBD 1997-1998 TBD

Tables 1-1, 2-1 and 2-2 replace completely the portion of the 1997 AQMP control

strategy provided in Tables 7-3 and 7-6 of the 1997 AQMP for those stationary

source control measures that the District is responsible for implementing.

Furthermore, Tables 2-1, 2-2 and 2-5 replace completely the remaining 1994
Chapter 2 Revised AQMP Control Strategy

2 - 7

California Ozone SIP stationary source control measures that the District is

responsible for implementing.

New Stationary Source Control Measures

Eight additional short-term stationary source control measures are proposed in this

Amendment (four of the control measures implements new control concepts that were

not provided in the original 1997 AQMP and four control measures implements portions

of the 1997 AQMP long-term control measures). The following sections describe each

of the seven measures.

CM#99CTS-02C(P2) - Further Emission Reductions from Solvent Cleaning

Operations: This measure will implement a portion of CM#97ADV*-CLNG provided in

the 1997 AQMP by reducing the VOC limit to below 50 g/l for many of the cleaning

operations. Previously, due to the constraint of laboratory test detection limits, the

standard has been set at 50 g/l. Recent refinements in test methods have identified

compliant products at a lower level. The measure will also seek emission reduction

opportunities from categories currently exempt under AQMD Rule 1171. This measure

was adopted by the District in October 1999 as an amendment to Rule 1171. However,

the control measure is kept in this section for purposes of SIP reduction commitment

tracking.

CM#99CTS-07(P3) - Further Emission Reductions from Architectural Coatings and

Cleanup Solvents: This measure along with two recent rule amendments in 1996 and

1999 to Rule 1113 - Architectural Coatings, will fully implement CM#97ADV-ARCH.

On-going technical evaluation on coating performance and research to further develop

low-VOC and/or low-reactive coating materials can provide further reduction

opportunities. This measure will also seek emission reductions in cleanup solvent use

that is currently exempt under Rule 1171 - Solvent Cleaning Operations.

CM#99CTS-08 - Further Emission Reductions from Industrial Coating and Solvent

Operations: This measure will implement a portion of CM#97ADV-CTS provided in

the 1997 AQMP through a comprehensive review of existing Regulation XI and

Regulation IV to identify further reduction potential. The review would include, but not

be limited to, a comparison of VOC limits adopted by other air districts in California,

survey of recent BACT determinations, etc. Portions of this measure were adopted by

the District in October 1999 as an amendment to Rule 1130. However, the control

measure is kept in this section for purposes of SIP reduction commitment tracking.

 

*

 The three-letter designation represents the source category: ADV=Advanced Technology Measures;

CMB=Combustion Sources; CTS=Coatings & Solvents; MSC=Misc. Sources; PRC=Process-Related Emissions. Some

measures may have a suffix designation of “(Px)” to represent additional phases of adoption and implementation and

“x” represents the phase.
1999 Amendment to the 1997 Ozone SIP Revision

2 - 8

CM#99CTS-09 - Further Emission Reductions from Large Solvent and Coating

Sources: This measure is designed to seek additional VOC emission reduction

opportunity from large coating and solvent operations (e.g., facilities emitting more than

25 tons per year). Control options to be considered include add-on controls, use of

super-clean coating materials, or process changes. Compliance flexibility at the facility

level would also be examined. Emission reductions achievable for this measure will take

into account technical feasibility and cost-effectiveness at individual facilities (especially

for high flow/low VOC situations such as some aerospace applications). This measure

will implement a portion of CM#97ADV-CTS reductions provided in the 1997 AQMP.

CM#99PRC-06 - Further Emission Reductions from Industrial Processes: This

measure is designed to implement a portion of CM#97ADV-PRC provided in the 1997

AQMP. The source categories include, but are not limited to, polyester resin operations,

manufacturing or fabrication of rubber or plastic products, or food flavoring operations.

The potential control options to be evaluated include material and/or process

modification, and good housekeeping measures.

CM#99FUG-05 - Further Emission Reductions from Large Fugitive VOC Sources:

This measure intends to further reduce emissions from large fugitive emission sources,

such as refineries, oil and gas production facilities, terminals, chemical plants, and

manufacturing facilities. Reductions could be achieved through the implementation of

facility-specific and District approved compliance plans. As such, compliance flexibility

opportunities could be maximized. This measure will implement a portion of

CM#97ADV-FUG reductions provided in the 1997 AQMP.

CM#99FUG-06 - Emission Reductions from Hydrogen Plant Process Vents: During

recent emission audits, AQMD staff found that the methane reformer catalyst at some

refinery hydrogen plants may generate a potentially significant amount of VOC

emissions, primarily methanol. Although the recently developed Refinery National

Emission Standards for Hazardous Air Pollutants (NESHAP) Maximum Achievable

Control Technology (MACT) exempts hydrogen plant process vents, there may be costeffective controls to reduce such emissions for criteria pollutant purposes. The

implementation of this control measure would first involve the development of an

accurate inventory. Since the 1997 AQMP baseline emissions inventory may not have

included these emissions, any emission reductions achieved from this measure would not

be credited towards the attainment demonstration.

CM#99RFL-02(P2) - Further Emission Reductions from Gasoline Dispensing

Facilities: During recent compliance audits for Rule 461, it was found that many gas

stations were not complying with Rule 461. As such, AQMD staff is developing

amendments to Rule 461 to tighten rule requirements and improve compliance. As part

of the rule amendment staff has also identified further emission reductions potential from
Chapter 2 Revised AQMP Control Strategy

2 - 9

gas stations. This measure will implement a portion of CM#97ADV-FUG reductions

provided in the 1997 AQMP.

1997 AQMP Stationary Source Control Measures with Revised

Adoption/Implementation Schedules

As part of this amendment, 13 of the 1997 AQMP control measures would have revised

adoption/implementation dates.1 Of the 13 control measures, nine have revised

adoption/implementation dates and four control measures have adoption/implementation

dates to be determined as part of the next comprehensive AQMP revision. One of the 13

control measures (WST-03 - Emission Reductions from Waste Burning) would be

implemented through the development of Memorandum of Understanding (MOUs) with

local fire agencies. Three measures are proposed to have accelerated implementation

dates based on District staff review of the technical feasibility in implementing these

measures. The revised adoption/implementation dates reflect current findings by the

District staff relative to the feasibility and the resources necessary to adopt and

implement these measures. Specific explanations for the revised dates of each of the 13

control measures are provided below.

CM#99CTS-02E This measure is similar to CM#97CTS-02E provided in the 1997

AQMP, except that the implementation period would be shortened (i.e., 2007 to 2008 in

lieu of 2007 to 2010 in the 1997 AQMP).

CM#99CTS-02O Further Emission Reductions from Solvent Usage: This measure is

similar to CM#97CTS-02O provided in the 1997 AQMP, except that there would be an

expedited adoption schedule of no later than 2000 with implementation by 2002. The

source categories to be considered are those operations using VOC-containing materials

but currently not subject to any Regulation XI rule. The proposed approach would be an

evaluation of the existing Rule 442 to determine if the number of sources subject to this

rule can be minimized and the existing Regulation XI rules can be more effectively

applied to these sources.

CM#99FUG-04 This measure is similar to CM#97FUG-04 provided in the 1997

AQMP. Due to potential double-counting, emission reductions associated with this

measure are included as part of CM#99FUG-05. As such, rule development for

CM#99FUG-04 and CM#99FUG-05 will be combined.

CM#99CMB-06 This measure is similar to CM#97CMB-06 provided in the 1997

AQMP for new sales of water heaters. The measure will seek to reduce NOx emissions

from water heaters based on recently developed burner technology. The implementation

 

1 One of the 1997 AQMP control measure (FSS-04) placed into further study does not have dates certain for

adoption and implementation and will be carried forward under the proposed Amendment with no changes.
1999 Amendment to the 1997 Ozone SIP Revision

2 - 10

date has been revised to reflect the nature of implementing this control measure that will

only affect new sales.

CM#99PRC-03(P2) The first phase of this control measure was adopted as part of

amendments to Rule 1138. The revised adoption/implementation dates reflect phase II

of the control measure, which will establish emission limits for under-fired charbroilers.

CM#99WST-01 This control measure considers the emissions inventory associated

with livestock waste and the development and assessment of feasible control approaches.

The technical work has been initiated. The next step involves the development of

feasible control approaches. The adoption schedule is clarified to reflect the ammonia

and VOC control portions (the PM10 portion was adopted in 1998). The implementation

schedule is shortened to achieve full implementation of this measure two years earlier.

CM#99WST-02 This control measure is divided into two phases. The first phase is the

development of an emission inventory for composting activities. In the second phase,

District staff will conduct technical assessments of the feasibility of controlling

composting activities in conjunction with studies for control measure WST-01. The

adoption date for this control measure has been revised to 2001, as technical studies of

control effectiveness are completed.

CM#99WST-04 The rule development proceedings for this control measure is currently

underway. District staff technical analysis includes data collection of the emissions

inventory associated with disposal of organic waste at disposal facilities and

identification of feasible control methods. The adoption/implementation schedule is

revised to reflect the current rulemaking schedule.

1997 AQMP Control Measures With Adoption/Implementation Dates to be

Determined

The following four control measures will be kept in the overall AQMP ozone control

strategy. However, the adoption/implementation dates would be determined at a future

date. The basis for the revised adoption/implementation dates is provided below. In

addition, since no emission reductions were assigned to these measures, they are not

relied upon for rate-of-progress or attainment demonstration.

CM#99FUG-03 Based on the most recent technical assessment for this control measure,

it is determined that the emissions from this activity (source) are insignificant, resulting

in negligible emission reduction potential. As such, it is recommended that this measure

be re-evaluated as part of the next comprehensive AQMP revision to identify other

viable control strategies.
Chapter 2 Revised AQMP Control Strategy

2 - 11

CM#99WST-03 U.S. EPA recently released a federal wildland fire policy that would

require air districts and states to develop a fire management program or revised their

current fire management program to be consistent with the federal policy. U.S. EPA

does not expect states to make formal SIP submittals of any regulatory actions. Instead,

the U.S. EPA prefers that Memorandum of Understandings (MOUs) be established

between the air districts, state, federal land managers, and fire departments to implement

the fire management program.

Instead of formal rule amendments to the District Rule 444, the District will be working

with the stakeholders to develop the fire management MOU. The MOU will be brought

to the District Governing Board for consideration.

In addition, the ARB is considering amendments to Title 17 of the California Code to be

consistent with the federal fire policy. ARB envisions that the amendments would be

completed sometime in 1999. If necessary, Rule 444 may need to be amended after the

state revisions. Therefore, this measure will be implemented through MOUs and/or

amendments to Rule 444.

CM#99MSC-01 This measures was envisioned in the 1997 AQMP to provide emission

reduction credits for voluntary actions to reduce ozone by lowering the ambient

temperature through the use of lighter colored roofing and paving materials. This

measure is implemented in part through the U.S. EPA’s Cool Communities Program.

The U.S. EPA and the District has been moving forward with the promotion of the use of

lighter color roofing and paving materials. Several demonstration projects are currently

being conducted nationally (one with the City of Los Angeles). In addition, tree planting

programs are being promoted throughout the region. The District has sponsored several

studies to further quantify the benefits of these actions. As such, this Amendment

proposes to revise the adoption/implementation dates for MSC-01 to dates to be

determined. It is recommended that this measure be re-evaluated as part of the next

comprehensive AQMP revision to identify additional viable implementation approaches.

CM#99MSC-03 It was envisioned in the 1997 AQMP that ozone destroying catalyst

coatings could be applied on a larger regional-scale. Several field studies have been

conducted to demonstrate the efficacy of the use of the ozone destroying catalyst and

preliminary results do indicate reductions in ozone concentrations when the catalyst is

used. There are ongoing technical research studies and demonstration projects

determining the relationship between the amount of ozone destroyed and equating the

ozone destroyed to an equivalent amount of VOC and/or NOx emissions reduced under

various meteorological and geographic conditions. In addition, staff is reviewing the

recent ARB LEV II Program that contains an element to allow for VOC credits for the

catalyst surface coating in mobile source applications. If the mobile source credit

approach is found to be applicable to stationary sources, staff will develop an incentives
1999 Amendment to the 1997 Ozone SIP Revision

2 - 12

program for stationary sources. Therefore, this Amendment would revise the 1997

AQMP adoption/implementation date for this measure to dates to be determined.

CM#99FLX-01 The adoption/implementation dates have been revised to allow

additional time to incorporate changes to the U.S. EPA Economic Incentive Program.

The District remains committed to the development and implementation of this program

and views it as an important part of the local attainment effort.

Revisions to the 1997 AQMP Long-Term Control Measures

As discussed above, eight short-term stationary control measures will implement portions

of the long-term stationary source control measures. As such, the reliance on long-term

control measure emission reductions is reduced with this Amendment. One of the eight

short-term measure [CTS-07(P3)] would fully implement the CM#97ADV-ARCH.

Therefore, control measure ADV-ARCH is no longer included in the AQMP control

strategy. Similarly, several control measures proposed in this Amendment would fully

achieve emission reductions called for in CM#97ADV-MSC. As shown in Table 2-2,

four long-term control measures would still be included in the AQMP control strategy.

PROJECTED EMISSION REDUCTIONS

This section provides the projected emission reductions and timelines associated with

this Amendment. The emission reductions for 2010 (the attainment year for the 1-hour

ozone air quality standard) are projected to be the same overall reductions as provided in

the 1997 AQMP. However, with the addition of the four stationary source control

measures that implement portions of the long-term control measures and four new shortterm control measures, the contribution of the short- and intermediate-term control

measures have increased and the reliance on the long-term control measures have

decreased. Additionally, with implementation of all of the new control measures and the

changes in the implementation dates of some of the 1997 AQMP control measures (as

discussed earlier in this Chapter), the projected emission reductions in the interim ozone

milestone years are expected to be greater for the stationary portion of the strategy

compared to the reductions provided in the 1997 AQMP.

Table 2-4 provides the emission reductions associated for the entire stationary source

control strategy that the District is responsible for implementing. The emission

reductions are based on the 2010 baseline summer planning inventory provided in the

1997 AQMP. Due to the need to develop more comprehensive emission inventories for

several source categories and/or to quantify their reduction potentials, the potential

emission reductions associated with some of the measures cannot be identified at this

time. The specific emission reductions for these measures will be amended into the SIP

at a later date when the emission data are identified.
Chapter 2 Revised AQMP Control Strategy

2 - 13

TABLE 2-4

Emission Reductions in 2010 Associated with the Proposed Revised Control Strategy

Control

Measure

Number

Control Measure

Name

Emission

Reduction

(tons/day)

(a) Short- and Intermediate-Term Control Measures

Surface Coating and Solvent Use

CTS-02C(P2)*Further Emission Reductions from Solvent Cleaning Operations

(Rule 1171) (VOC)

11.0 - 27.0

CTS-02E Emission Reductions from Adhesives (Rule 1168) (VOC) 1.3

CTS-02O Emission Reductions from Solvent Usage (Rule 442) (VOC) 1.0 - 2.0

CTS-07(P3) Further Emission Reductions from Architectural Coatings and

Cleanup Solvents (VOC)

9.8

CTS-08* Further Emission Reductions from Industrial Coating and Solvent

Operations (VOC)

Phase I: 2 - 3

Phase II: 3 - 4

CTS-09 Further Emission Reductions from Large Solvent and Coating

Sources (VOC)

Phase I: 4 - 6

Phase II: 3 - 5

Petroleum Operations and Fugitive Emissions

FUG-03 Further Emission Reductions from Floating Roof Tanks (Rule 463)

(VOC)

TBD

FUG-04 Further Emission Reduction** from Fugitive Sources (Rule 1173)

(VOC)

(--)

FUG-05 Further Emission Reductions from Large Fugitive VOC Sources

(VOC)

Phase I: 1 - 2

Phase II: 1 - 2

Phase III: 1 - 2

FUG-06 Emission Reductions from Hydrogen Plant Process Vents (VOC) 0.8***

RFL-02(P2) Further Emission Reductions from Gasoline Dispensing Facilities

(Rule 461) (VOC)

2-5

Combustion Sources

CMB-06 Emission Standards for New Commercial and Residential Water

Heaters (NOx)

7.6

 

∗ CTS-02C(P2) and portions of CTS-08 were adopted in October 1999 as part of amendments to Rule 1171 and

1130, respectively, subsequent to the release of the draft 1999 Amendment. The control measures are kept in this

section of this Amendment for purposes of SIP reduction commitment tracking.

** Due to potential double-counting, emission reductions from this measure are included as part of FUG-05.

*** Emission reductions are not included in the overall reductions because these emissions may not have been included

in the 1997 AQMP baseline inventory.
1999 Amendment to the 1997 Ozone SIP Revision

2 - 14

TABLE 2-4

(concluded)

Control

Measure

Number

Control Measure

Name

Emission

Reductions

(tons/day)

Miscellaneous Sources

PRC-03(P2) Further Emission Reductions from Restaurant Operations

(VOC, PM10)

VOC = 0.9

PRC-06 Further Emission Reductions from Industrial Processes (VOC) 3.0 - 4.0

MSC-01 Promotion of Lighter Color Roofing and Road Materials and Tree

Planting Programs (All Pollutants)

0.0

MSC-03 Promotion of Catalyst-Surface Coating Technology Programs

(All Pollutants)

0.0

WST-01 Emission Reductions from Livestock Waste (VOC, Ammonia) VOC = 3.3

WST-02 Emission Reductions from Composting

(VOC, PM10, Ammonia)

TBD

WST-03 Emission Reductions from Waste Burning (Rule 444) TBD

WST-04 Disposal of Materials Containing Volatile Organic Compounds

(VOC)

0.8

FSS-04 Emission Charges of $5,000 per Ton of VOC for Stationary Sources

Emitting Over 10 Tons per Year (VOC)

TBD

Compliance Flexibility Programs

FLX-01 Intercredit Trading Program (All) 0.0

VOC Subtotal 48.1 - 78.1

(b) Long-Term Control Measures

ADV-CLNG Solvent Cleaning and Degreasing Operations (VOC) 16.0

ADV-CTS Miscellaneous Industrial Coating and Solvent Operations (VOC) 6.0

ADV-FUG Fugitive Emissions (VOC) 5.0

ADV-PRC Industrial Process Operations (VOC) 1.0

VOC Subtotal 28

VOC Total*** 76.1

*** The total VOC emission reductions reflect the sum of the lower-end of the short- and intermediate-term

control measure reductions and the long-term measure reductions. Reductions achieved above the

lower-end value would reduce the reliance on the long-term measures.
Chapter 2 Revised AQMP Control Strategy

2 - 15

SIP Emission Commitment

The SIP commitment of the 1999 Amendment is structured into three components:

reductions from adopted rules, short-term measures, and long-term measures. Taken

together, these components provide the necessary reductions that this Amendment relies

upon to demonstrate expeditious progress and attainment with the federal 1-hour ozone

standard. The following sections first describe the methodology for SIP emission

reduction calculations and the creditable SIP reductions, then delineate each component

of SIP commitment as to when and what procedures will be followed to ensure

fulfillment of the commitment.

SIP Emission Reduction Tracking

For purpose of tracking the progress in emission reductions, the baseline emissions for

the year 2010 planning inventory (summer inventory for ozone) in the 1997 AQMP will

be used, regardless of any subsequent new inventory information that reflects more

recent knowledge. This is to assure that the same "currency" is used in measuring

progress as was used in designing the AQMP. This will provide a fair and equitable

measurement of progress. Therefore, whether progress is measured by emission

reductions or by remaining emissions for a source category provides no material

difference. However, current emission inventory information at the time of rule

development will continue to be used for calculating reductions, cost-effectiveness and

socioeconomic impacts of the proposed rule. Therefore, for future rulemaking activity

both the current and AQMP inventories will be reported.

Any non-mandatory emission reductions achieved beyond the existing District

regulations are creditable only if they are also SIP-enforceable. Therefore, in certain

instances the District may have to adopt regulations to reflect the existing industry

practices in order to claim SIP reduction credit with the understanding that there may not

be additional reductions beyond what has already occurred. Exceptions can be made

where reductions are real, quantifiable, surplus to the 1997 AQMP baseline inventories,

and enforceable through other state and/or federal regulations.

Reductions from Adopted Rules

Many of the control measures contained in the 1994 or 1997 AQMP have been adopted.

These adopted rules and their projected emission reductions become assumptions in

developing AQMP future year inventories. Although they are not part of the control

strategy in the 1999 Amendment, continued implementation of those rules is essential in

achieving the clean air goal and maintaining the attainment demonstration. Table 2-5

lists the rules adopted since the adoption of the 1994 SIP and their expected emission

reductions.
1999 Amendment to the 1997 Ozone SIP Revision

2 - 16

TABLE 2-5

SCAQMD VOC and NOx Emission Reduction Rules Adopted Since the Submittal

of the 1994 Ozone SIP to U.S. EPA (November 1994)

Control

Measure/

Rule

Title Adoption

Date

Implementation

Schedule

Achieved

Through Rule

Implementation

in 2010

Rules without Technology-Forcing Limits

and/or Technology Assessments

CTS-C

(Rule 1171)

Emission Reductions from Solvent

Cleaning Operations

1996 1999 26.8

CTS-02H

(Rule 1107)

Emission Reductions from Metal

Parts and Products (VOC)

1998 1999 8.8

CTS-02M

(Rule 1145)

Emission Reductions from Plastic,

Rubber, Glass Coatings (VOC)

1997 1998 1.2

CTS-02N

(Rule 1122)

Emission Reductions from Solvent

Degreasers (VOC)

1997 1999 48.1

CTS-07*

(Rule 1113)

Further Emission Reductions from

Architectural Coatings (VOC)

Phase I: 1996

Phase II: 1999

Phase I:

1998-2008

Phase II:

2002-2006

14.8

16.5

CMB-02B

(Rule

1146.2)

Emission Reductions from Small

Boilers and Process Heaters (NOx)

1998 2000-2006 4.2**

FUG-01

(Rule 462)

Emission Reductions from Organic

Liquid Transfer (VOC)

1995 1999 0.8***

FUG-02

(Rule 1176)

Emission Reductions from Sumps

and Wastewater Separators (VOC)

1996 1997 5.0***

PRC-03

(Rule 1138)

Restaurant Operations (VOC) 1997 1999 0.2

RFL-02

(Rule 461)

Further Emission Reductions from

Gasoline Dispensing Facilities

(VOC)

1995 1998 3.7***

Rule 1104 Wood Flat Stock Coating Operations

(VOC)

1998 2000 (negligible)

* CTS-07 was adopted in two phases. The first phase was adopted in November 1996 and the second phase in May 1999.

18.5 tons per day of the Phase II reductions are subject to technology assessment prior to final implementation.

** Rule 1146.2 is expected to achieve 7.9 tons/day of NOx reductions. However, only 4.2 of the 7.9 tons/day reductions were

included in the 1997 AQMP baseline emissions inventory.

*** The projected reductions were incorporated in the 1997 AQMP baseline emission inventories.
Chapter 2 Revised AQMP Control Strategy

2 - 17

TABLE 2-5

(Concluded)

Control

Measure/

Rule

Title Adoption

Date

Implementation

Schedule

Achieved

Through Rule

Implementation

in 2010

Rules with Technology Forcing Limits and/or

Technology Assessments

Rule 1136† Wood Products Coatings (VOC) 1996 2005 7.9

Rule 1124† Aerospace Assembly and Component

Manufacturing Operations (VOC)

1996 2002 0.2

Rule 1130.1† Screening Printing Operations (VOC) 1996 2003 0.1

Rule 1168† Adhesive Applications (VOC) 1998 2003 1.3

CTS-07*

(Rule 1113)

Further Emission Reductions from

Architectural Coatings (VOC)

Phase II: 1999 Phase II:

2002-2006

18.5

Total

VOC = 153.9

NOx = 4.2

* CTS-07 was adopted in two phases. The first phase was adopted in November 1996 and the second phase in May 1999.

18.5 tons per day of the Phase II reductions are subject to technology assessment prior to final implementation.

† The projected reductions were incorporated in the 1994 Ozone SIP and 1997 AQMP baseline emission inventories. The

recent amendments delayed the implementation of technology-forcing limits.

Reductions from Short-Term Measures

For purposes of implementing an approved SIP, the District is committed to adopt and

implement control measures that will achieve, in aggregate, emission reductions

specified in Table 2-6. Emission reductions achieved in excess of the amount committed

in a given year can be applied to the emission reduction commitment of subsequent

years. The District is committed to adopt Table 2-1 measures unless these measures or a

portion thereof are found infeasible and other substitute measures that can achieve

equivalent reductions in the same adoption/implementation timeframes are adopted.

Findings of infeasibility will be made at a regularly scheduled meeting of the District

Board with proper public notification. For purposes of SIP commitment, infeasibility

means the proposed control technology is not reasonably likely to be available by the

implementation date in question, or achievement of the emission reductions by that date

is not cost effective. The District acknowledges that this commitment is enforceable

under Section 304(f) of the federal Clean Air Act.
1999 Amendment to the 1997 Ozone SIP Revision

2 - 18

TABLE 2-6

2010 Planning Inventory Emission Reductions Commitment by Year Achieved

through Rule Adoption and Implementation (Tons/Day)

Based on Adoption Date Based on Implementation Date*

VOC NOx VOC NOx

1999 11.0 7.6 -- --

2000 10.0 -- -- --

2001 4.0 -- -- --

2002 9.3 -- 14.8 --

2003 13.8 -- 0.9 7.6

2004 -- -- 7.3 --

2005 -- -- -- --

2006 -- -- 4.0 --

2007 -- -- 4.0 --

2008 -- -- 17.1 --

Total 48.1 7.6 48.1 7.6

* Represents the final, full implementation date; typically a rule contains multi-implementation dates.

(A) Adoption and Implementation of Table 2-1 Measures: In response to the concerns

raised by the regulated community that costly controls may be required to meet the

SIP obligations, the District establishes a threshold of $13,500 per ton of VOC

reduction for tiered levels of analysis. Specifically, proposed rules with an average

cost effectiveness above the threshold will trigger a more vigorous average costeffectiveness, incremental cost-effectiveness, and socioeconomic impact analysis. A

public review and decision process will be instituted to seek lower cost alternatives.

In addition, the District staff, with input from stakeholders, will attempt to develop

viable control alternatives within the industry source categories that a rule is

intended to regulate. If it is determined that control alternatives within the industry

source category are not feasible, staff will perform an evaluation of the control

measure as described in paragraph (B) below. Viable alternatives shall be reviewed

by the District Governing Board at a public meeting no less than 90 days prior to

rule adoption and direction given back to staff for further analyses. During this

review process, incremental cost-effectiveness scenarios and methodology will be

specified, and industry-specific affordability issues will be identified as well as

possible alternative control measures. The District Governing Board may adopt the

original proposal or an alternative that is consistent with state and federal law. In

addition, staff shall include in all set hearing items a notification that proposed rules

do or do not exceed the threshold.
Chapter 2 Revised AQMP Control Strategy

2 - 19

(B) Adoption and Implementation of Alternative/Substitute Measures: Under the 1999

Amendment, the District will be allowed to substitute Table 2-1 measures with other

measures, provided the overall equivalent emission reductions by adoption and

implementation dates in Table 2-6 are maintained and the applicable Table 2-1

measure is infeasible. In order to provide meaningful public participation, when

new control concepts are introduced for rule development, the District is committed

to provide advanced public notification beyond its regulatory requirements.

Specifically, the District will report quantitatively the AQMP implementation

progress semi-annually at its regularly scheduled Board meetings. Included in the

reports will be any new control measures being proposed or measures, or portions

thereof, that have been found to be infeasible and the basis of such finding. In

addition, in the beginning of the year, any significant emission reduction related

rules to be considered would be listed in the Board's Rule Forecast Report. Public

notice is provided 75 days prior to public hearing on the proposed rule. The

existing rule development outreach efforts such as public workshops, stakeholder

working group meetings or public consultation meetings will continue to solicit

public input.

Reductions from Long-Term Measures

The 1999 Amendment contains a total of 28 tons per day of long-term VOC emission

reductions needed to achieve attainment beyond that expected from the short-term

measures. Table 2-4 provides a range of emission reductions for many short-term

control measures. The upper-end reflects additional reduction potential, which will be

subject to further feasibility evaluation during the rule development process and are not

suitable for formal SIP commitment at this time. However, the District will use its best

effort to maximize the emission reductions wherever feasible. The uncertainty

associated with the 30 tons per day of VOC reductions (the difference between the

known and maximum possible potential for the short-term measures) include potential

double-counting of emission reductions between control measures, applicability of

control technology across source categories, and cost-effectiveness. In addition, longer

implementation periods may also be required to allow for further development or

refinement of control technologies.

Should there be excess emission reductions adopted and implemented from a control

measure beyond the lower range commitment, they will first be applied to ensure the

Table 2-6 commitment is met before being credited toward long-term measure

reductions. For example, CTS-02C(P2) was adopted in 1999 with 16 tons of reductions

to be implemented by 2005 unless the 2004 technology assessment indicates otherwise.

These 16 tons per day reductions are available for Table 2-6 applications. If not needed,

they will be used to satisfy the 28 tons per day of long-term measure reductions.
1999 Amendment to the 1997 Ozone SIP Revision

2 - 20

In order to ensure expeditious progress, the District will be conducting annual workshops

to solicit public assistance in identifying viable control measures. These new measures

can provide a better assurance that the Table 2-6 commitment can be met and the

reliance on long-term control measures can be minimized, if not eliminated at the earliest

practicable date.

Comparison of Emission Reductions in This Amendment to Prior Ozone SIP

Revisions

As discussed earlier, this Amendment will reduce the reliance on long-term control

measures compared to the 1997 AQMP. The additional emission reductions in the shortterm would change the stationary source VOC emission budgets in the interim years

provided in the 1997 AQMP. The VOC emission budgets are provided for federal VOC

rate-of-progress demonstrations. For this Amendment, the stationary portions of the

VOC emission budgets for each of the milestone years to the year 2010 are provided in

Table 2-7. The stationary VOC emission budgets by milestone year shown in Table 2-7

would replace the stationary VOC emission budgets provided in Table 4-9, Appendix V

of the 1997 AQMP.

TABLE 2-7

Amendment to the South Coast Air Basin Stationary

VOC Emissions (tons/day) Budget by Milestone Year

Stationary VOC Emissions*

Year 1997 AQMP Proposed Amendment

1999 447.3 435.2

2002 427.9 402.4

2005 385.0 334.4

2008 335.4 305.1

2010 267.8 267.6

* The emission budgets shown here contain the statewide consumer products and

pesticide measures.

A comparison of the short-term stationary source emission reductions compared to the

long-term stationary source emission reductions under this Amendment and the 1997

AQMP is provided in Table 2-8. Table 2-8 shows the stationary source VOC emission

reductions for those short-, intermediate-, and long-term control measures that the

District is responsible for implementing and does not include the statewide consumer

products and pesticide control measures. In addition, 1997 AQMP control measures

adopted since October 1996 are shown for the 1999 Amendment. As seen in Table 2-8,

the emission reductions associated with the long-term control measures have been
Chapter 2 Revised AQMP Control Strategy

2 - 21

reduced from 89 tons/day to 28 tons/day. As a result, the commitment to long-term

emission reductions is about 15 percent of the total stationary source VOC emission

reductions as compared to about 48 percent in the 1997 AQMP.

TABLE 2-8

Comparison Between the 1997 AQMP and the 1999 Amendment

VOC Emission Reductions for Short-, Intermediate-, and Long-Term Stationary

Source Measures for 2010 Based on Summer Planning Inventory (tons per day)

1997

AQMP*

1999

AMENDMENT*

Emission Reductions

Adopted 1997 AQMP Measures -- 108

Short-, Intermediate-Term

Stationary Measures 95 48

Long-Term Stationary Measures

Stationary 89 28

Total Reductions (All Measures) 184 184

* Does not include state consumer products or pesticide control measures.

For the post-1996 federal VOC rate-of-progress milestone demonstration, the 1997

Ozone SIP Revision demonstrated that the VOC rate-of-progress would be met with

adopted rules and regulations as of September 1996 that are incorporated into the futureyear baseline emissions inventories and that the VOC control strategy provided in the

1997 Ozone SIP Revision would not be needed to demonstrate rate-of-progress.

Included in the future-year baseline emission inventories are several stationary source

VOC rules with compliance dates beyond 2000 (as shown in Table 2-9). Some of the

future compliance dates may potentially be amended if controls for technology forcing

limits are not available. Since the post-1996 rate-of-progress demonstration allows for

NOx substitution, additional NOx reductions that will occur from adopted NOx rules

would be available to make up the difference. To be conservative, reductions from the

future rule limits shown in Table 2-9 are not relied upon to demonstrate rate-of-progress

compliance. Tables 2-10 and 2-11 show the revised rate-of-progress calculation without

the inclusion of the three rules that have future compliance dates. In addition, the 14

adopted control measures provided in Table 1-1 in the aggregate will make up any delays

in future compliance dates of the rules shown in Table 2-9.
1999 Amendment to the 1997 Ozone SIP Revision

2 - 22

TABLE 2-9

Emission Reductions from Adopted VOC and NOx Rules with Future Compliance Dates

Rate-of-Progress Milestone Years

VOC Rules with Future Compliance Dates 2002 2005 2008 2010

· Rule 1136 1.4 3.7 6.2 7.9

· Rule 1124 0.1 0.2 0.2 0.2

· Rule 1130.1 0.1 0.1 0.1 0.1

· Rule 1168 1.1 1.2 1.2 1.3

Total VOC Emission Reductions 2.7 5.2 7.7 9.5

NOx Rule with Future Compliance Dates

· Rule 1110.2 0.8 2.1 3.6 4.7

Total NOx Emission Reductions 0.8 2.1 3.6 4.7
Chapter 2 Revised AQMP Control Strategy

2 - 23

TABLE 2-10

Summary of Rate-of-Progress Calculations for VOC - South Coast Air Basin

Milestone Year (tons/day)a

Row Calculation Step 1999 2002 2005 2008 2010

1 1990 ROP Base Yearb1733.3 1733.3 1733.3 1733.3 1733.3

2 FMVP/RVP Reductions 205.9 218.1 223.2 223.9 224.4

3 FMVCP/RVP Correctionsc12.2 5.1 0.7 0.5

4 Adjusted 1990 Base Yeard1527.4 1515.2 1510.1 1509.4 1508.9

5 Required Reduction (%)e24.00 9.00 5.40 0.50 0.50

6 Emission Reductionsf366.6 136.4 81.5 7.5 7.5

7 RACT Corrections 0.0 0.0 0.0 0.0 0.0

8 I/M Corrections 0.0 0.0 0.0 0.0 0.0

9 Target Levelg1160.8 1012.3 925.6 917.4 909.3

10 Projected Baselineh981.9 945.6 917.5 912.9 909.3

11 Additional Reductionsi0.0 0.0 0.0 0.0 0.0

12 Controlled Emissionsj938.6 826.1 707.6 587.4 413.6

a

 Units are tons per day unless noted otherwise.

b

 Contains only anthropogenic emissions.

 c FMVCP/RVP Correction(x) = FMVCP/RVP Reduction(x) - FMVCP/RVP Reduction(y),

 where x is the current target year and y is the previous target year.

 d (Row 1) - (Row 2)

e

 24% VOC reduction by 1999 and 3% per year (total VOC and NOx reductions) thereafter.

 f [(Row 4) x (Row 5)]/100

 g For 1999,

 (Row 1) - (Row 2) - (Row 6) - (Row 7) - (Row 8)

 For 2002, 2005, ..., 2010

 Target level for previous milestone year - (Row 3) - (Row 6) - (Row 7) - (Row 8)

 h Projected baseline emissions taking into account existing rules (excluding rules listed in Table 2-9)

and projected growth. It includes emission reduction credits.

i

 (Row 10) - (Row 9)

j

 VOC emission level with the implementation of the control strategy given in Chapter 3.
1999 Amendment to the 1997 Ozone SIP Revision

2 - 24

TABLE 2-11

Summary of Rate-of-Progress Calculations for NOx - South Coast Air Basin

Milestone Year (tons/day)a

Row Calculation Step 1999 2002 2005 2008 2010

1 1990 ROP Base Yearb1472.2 1472.2 1472.2 1472.2 1472.2

2 FMVP/RVP Reductions 0.0 0.0 0.0 0.0 0.0

3 FMVCP/RVP Correctionsc0.0 0.0 0.0 0.0 0.0

4 Adjusted 1990 Base Yeard1472.2 1472.2 1472.2 1472.2 1472.2

5 Required Reduction (%)e0.00 0.00 3.60 8.50 5.50

6 Emission Reductionsf0.0 0.0 53.0 125.1 81.0

7 RACT Corrections 0.0 0.0 0.0 0.0 0.0

8 I/M Corrections 0.0 0.0 0.0 0.0 0.0

9 Target Levelg1472.2 1472.2 1419.2 1294.1 1213.1

10 Projected Baselineh956.1 858.8 796.6 763.5 751.1

11 Additional Reductionsi0.0 0.0 0.0 0.0 0.0

12 Controlled Emissionsj935.1 814.5 694.5 609.0 530.4

a

 Units are tons per day unless noted otherwise.

b

 Contains only anthropogenic emissions.

 c FMVCP/RVP Correction(x) = FMVCP/RVP Reduction(x) - FMVCP/RVP Reduction(y),

 where x is the current target year and y is the previous target year.

 d (Row 1) - (Row 2)

e

 24% VOC reduction by 1999 and 3% per year (total VOC and NOx reductions) thereafter.

 f [(Row 4) x (Row 5)]/100

 g For 1999,

 (Row 1) - (Row 2) - (Row 6) - (Row 7) - (Row 8)

 For 2002, 2005, ..., 2010

 Target level for previous milestone year - (Row 3) - (Row 6) - (Row 7) - (Row 8)

 h Projected baseline emissions taking into account existing rules (excluding rules listed in Table 2-9)

and projected growth. It includes emission reduction credits.

i

 (Row 10) - (Row 9)

j

 VOC emission level with the implementation of the control strategy given in Chapter 3.
Chapter 2 Revised AQMP Control Strategy

2 - 25

Relative to the federal Clean Air Act requirement to achieve emission reductions as

“expeditiously as practicable,” Figure 2-1 shows the remaining VOC emissions with full

implementation of the Proposed 1999 Amendment compared to the 1997 AQMP and the

1994 Ozone SIP. As shown in Figure 2-1, the remaining VOC emissions are lower for

this Amendment compared to the 1997 AQMP for all future years up to 2010. This

Amendment will provide for lower remaining VOC emissions compared to the 1994

Ozone SIP for all years up to 2008. After 2008, the 1994 Ozone SIP requires greater

emission reductions over the two-year period from 2008 to 2010 due to different

carrying capacity calculations. However, the District continues to believe that the 1997

AQMP attainment modeling is superior technically to the 1994 Ozone SIP modeling and

complies with federal guidance on conducting ozone attainment demonstrations.

FIGURE 2-1

Comparison of Remaining VOC stationary source emissions after implementation of the

1999 Amendment, 1997 AQMP, and the 1994 Ozone SIP

150

250

350

450

550

650

1990 1993 1999 2002 2005 2008 2010

Years

VOC (TPD)

1994 S IP 1997 AQMP 1999 AMENDMENT
APPENDIX A

SUPPORTING DOCUMENTATION ON THE REMOVAL

OF 31 1994 OZONE SIP CONTROL MEASURES FROM

THE 1997 AQMP
Appendix A: Supporting Documentation on the Removal of 31 1994 Ozone SIP

Control Measures from the 1997 AQMP

A - 1

INTRODUCTION

The U.S. Environmental Protection Agency (EPA), in its notice of partial approval,

partial disapproval of the 1997 Ozone SIP Revision for the South Coast Air Basin

(64FR1770), stated that the U.S. EPA supports the amendment or replacement of a

control measure when it is determined to be infeasible or ineffective. However, in a

subsequent court proceeding U.S. EPA indicated that the District had not made a

showing that the 31 control measures contained in the 1994 California Ozone SIP for the

South Coast Air Basin were no longer feasible to implement. The 1997 AQMP provided

information on the reasons the control measures were to be removed from the 1994 SIP.

The purpose of this Appendix is to provide the US EPA and the public with additional

information to demonstrate the infeasibility of those measures.

The specific measures that the District is replacing with the measures in the 1997 AQMP

and this Amendment to the 1997 AQMP are:

• CTS – 07 (Architectural Coatings) (Rule 1113)

• FUG - 01 (Organic Liquid Transfer And Loading) (Rule 462)

• FUG – 02 (Active Draining Of Liquid Products) (Rule 1176)

• FUG – 04 (Fugitive Sources) (Rule 1173)

• RFL – 02 (Gasoline Dispensing Facilities) (Rule 461)

• RFL – 03 (Pleasure Boat Fueling Operations)

• CMB - 02F (Combustion Equipment at Non-Reclaim Sources/ Internal

 Combustion Engines) (Rule 1110.2)

• CMB - 05 (Clean Stationary Fuels)

• MSC – 02 (In-Use Compliance Program for Air Pollution Control Equipment)

• PRC – 02 (Bakeries) (Rule 1153)

• PRC – 03 (Restaurant Operations) (Rule 1138)

• WST - 01 (Livestock Waste)

• WST – 03 (Waste Burning) (Rule 444)

• WST – 04 (Disposal of Materials Containing VOCs)

• CTS – A (Electronic Components Manufacturing)

• CTS – C (Solvent Cleaning Operations) (Rule 1171)

• CTS – D (Marine and Pleasure Craft Coating Operations) (Rules 1106/1106.1)

• CTS – E (Adhesives) (Rule 1168)

• CTS – F (Motor Vehicle and Mobile Equipment Non-Assembly Line Coating

 Operations) (Rule 1151)
Appendix A: Supporting Documentation on the Removal of 31 1994 Ozone SIP

Control Measures from the 1997 AQMP

A - 2

• CTS – G (Paper, Fabric and Film Coating Operations) (Rule 1128)

• CTS – H (Metal Parts and Products) (Rule 1107)

• CTS – I (Screen Printing Operations and Graphic Arts) (Rules 1130/1130.1)

• CTS – J (Wood Products Coatings) (Rule 1136)

• CTS – K (Aerospace Assembly And Manufacturing) (Rule 1124)

• CTS – L (Automobile Assembly Operations) (Rule 1115)

• ISR – 1 (Special Event Centers)

• ISR – 2 (Regional Shopping Centers)

• ISR – 3 (Registration and Commercial Vehicles)

• ISR – 4 (Airport Ground Access)

• ISR – 5 (Trip Reduction for Schools)

• ADV-CTS – 02

Since, the U.S. EPA did not provide any guidance on what information would be

sufficient to make a showing of infeasibility, the District is providing all the information

it believes is relevant to the issue. The substitution is being made in toto. It is not the

intent of the District that the U.S. EPA make additions to the 1994 SIP by selecting some

or all of measures from the 1999 Amendment. It is the intent of the District that the

above referenced 1994 control measures be deleted entirely, and the stationary source

control measures provided in the 1997 AQMP as modified by the 1999 Amendment, that

the District is responsible for implementing be substituted as a whole.

The demonstration consists primarily of two types of documents. First are declarations

filed in the matter of Coalition for Clean Air v. South Coast Air Quality Management

District, No. 97-6916 HLH (C. D. Cal. Filed 9/18/97), in which the final decision has

not yet been entered. These declarations describe the actions that the District has taken

to determine the feasibility of the 1994 Ozone SIP control measures, and contain various

attachments that include studies and reports on different source categories affected by

the control measures. The second type of documents are rule adoption packages that

have been prepared by the District for rules that implement, partially implement, or

substitute for control measures in the 1994 Ozone SIP and the 1997 AQMP. Many of

these rule adoption packages have been submitted to the U.S. EPA for review and

inclusion in the SIP. Table A-1 contains a summary of the types of documentation

submitted for each control measure.
Appendix A: Supporting Documentation on the Removal of 31 1994 Ozone SIP

Control Measures from the 1997 AQMP

A - 3

TABLE A-1

District Staff Declarations and/or Rule Package Submittals on the

31 1994 Ozone SIP Control Measures

Control

Measure Declaration

Rule

Package

CTS-07 Naveen Berry September 28, 1998,

Jack Broadbent June 22, 1999

November 8, 1996,

May 14, 1999

FUG-01 Brian Choe September 28, 1998 and June 22, 1999 June 9, 1995

FUG-02 Mohsen Nazemi September 28, 1998, June 22, 1999 September 13, 1996

FUG-04 Mohsen Nazemi September 28, 1998, June 22, 1999,

Elaine Chang June 22, 1999

RFL-02 Larry Bowen September 28, 1998 and June 22, 1999 September 8, 1995

RFL-03 Larry Bowen September 28, 1998 and June 22, 1999

CMB-02F Larry Bowen September 28, 1998 and June 22, 1999 November 14, 1997

CMB-05 Michael Mills September 28, 1998 and June 22, 1999

MSC-02 Anupom Ganguli September 28, 1998 and June 22, 1999

PRC-02 David Schwien September 28, 1998, Jack Broadbent June 22, 1999,

Elaine Chang June 22, 1999

PRC-03 Rudy Eden September 28, 1998 and June 22, 1999,

Jack Broadbent June 22, 1999, Elaine Chang June 22, 1999

November 14, 1997

WST-01 Julia Lester September 28, 1998 and June 22, 1999,

Elaine Chang June 22, 1999

WST-03 Michael Mills September 28, 1998 and June 22, 1999

WST-04 Elaine Chang June 22, 1999

CTS-A Anupom Ganguli September 28, 1998 and June 22, 1999,

Elaine Chang June 22, 1999

CTS-C Anupom Ganguli September 28, 1998 and June 22, 1999 September 13, 1996

CTS-D Anupom Ganguli September 28, 1998 and June 22, 1999,

Elaine Chang June 22, 1999

CTS-E Anupom Ganguli September 28, 1998 and June 22, 1999,

Elaine Chang June 22, 1999

February 13, 1998

CTS-F Fred E Lettice, III September 28, 1998 and June 22, 1999 June 13, 1997,

December 11, 1998

CTS-G Anupom Ganguli September 28, 1998 and June 22, 1999,

Elaine Chang June 22, 1999

CTS-H Anupom Ganguli September 28, 1998 and June 22, 1999,

Elaine Chang June 22, 1999

August 14, 1998

CTS-I Fred E Lettice, III September 28, 1998 and June 22, 1999,

Francis Goh September 28, 1998, Elaine Chang June 22, 1999

CTS-J Jack Broadbent September 28, 1998 and June 22, 1999,

Elaine Chang June 22, 1999

June 14, 1996
Appendix A: Supporting Documentation on the Removal of 31 1994 Ozone SIP

Control Measures from the 1997 AQMP

A - 4

TABLE A-1

(Concluded)

Control

Measure Declaration

Rule

Package

CTS-K Anupom Ganguli September 28, 1998 and June 22, 1999,

Elaine Chang June 22, 1999

December 13, 1996

CTS-L Elaine Chang 3/15/99 and June 22, 1999,

Jack Broadbent June 22, 1999

ISR-1

through

ISR-5

Laki Tisopulos September 28, 1998 and June 22, 1999

ADV-CTS02Jack Broadbent September 28, 1998 and June 22, 1999

Several of the rules that were adopted to implement or partially implement control

measures from the 1994 SIP have already been forwarded to the U.S. EPA for review

and approval into the SIP. Table A-2 contains a list of those control measures and the

dates on which they were submitted to U.S. EPA. Where known, an indication of the

status of that rule, approved, disapproved or pending, is indicated.

TABLE A-2

Status of 1994 Ozone SIP Control Measures that were Adopted as Rules or Regulations

Control

Measure

Rule

Adopted

Date

Submitted Status

RFL-02 461 November 30, 1995 SIP Approved

CMB-02F 1110.2 January 14, 1998 Limited Approval -

March18, 1999

FUG-02 1176 November 26, 1996 No Action

CTS-F 1151 August 22, 1997

February 16, 1999

SIP Approved

SIP Approved

FUG-01 462 August 28, 1997 SIP Approved

CTS-C 1171 November 1, 1996 No Action

CTS-E 1168 July 17, 1998 Direct Final Approval

CTS-H 1107 February 16, 1999 Direct Final Approval

CTS-K 1124 SIP Approved

PRC-03 1138 December 23, 1998 No Action

CTS-O7 1113 November 8, 1996

(May 14, 1999 Rule)*

Proposed Approval

(with ARB)*

CTS-J 1136 1996 SIP Approved

* This documentation is included pending SIP submittal by ARB. Other rules that have

already been formally submitted are not included.
Appendix A: Supporting Documentation on the Removal of 31 1994 Ozone SIP

Control Measures from the 1997 AQMP

A - 5

Finally, the District is including any other type of document it believes is relevant to the

demonstration of the impracticability or infeasibility of the 31 1994 Ozone SIP control

measures, including a February 1999 comment letter submitted to U.S. EPA regarding

the proposed approval/disapproval of the 1997 Ozone SIP Revision. The following is a

list of those documents.

• February 1999 Comment letter from Barry Wallerstein regarding the proposed

approval/disapproval of the 1997 Ozone SIP Revision.

• September 23, 1998 letter from Barry Wallerstein to Felicia Marcus regarding U.S.

EPA action on the 1997 AQMP.

• March 2, 1998 letter from Barry Wallerstein to Felicia Marcus regarding U.S. EPA

action on the 1997 AQMP.

• January 6, 1998 letter from Barry Wallerstein to Felicia Marcus regarding U.S.

EPA action on the 1997 AQMP.

• 1993 Study of Refinery Fugitive Emissions from Equipment Leaks prepared for

Western States Petroleum Association by Radian Corp. (August 1993)

• Final Report on California AIM Paint Survey for SCAQMD (Contract No.

961362)

• Results of the Measurement of PM10 Precursor Compounds (PM10PCs) from

Dairy Industry Livestock Waste (June 1996) Dr. C.E. Schmidt

• Development and Demonstration of an Emission Control Technology for

Commercial Underfired Charbroilers – Final Report. Prepared by William Fitz

January 30, 1998.

• VOC Reduction Technologies for Aerospace Component Coatings – Draft Final

Report. Prepared for SCAQMD by Aerovironment Environmental Services, Inc.

July 1996.

• Draft Staff Report for: Technology Review for Adhesives, Coatings, Inks, and

Solvents January 5, 1996

• Declaration of Elaine Chang June 22, 1999 (for general plan information)

• Declaration of Jack Broadbent June 22, 1999 (for general plan information)

• Declaration of Chris Marlia September 28, 1998 (for general plan information)

• Declaration of Sue Lieu September 28, 1998 (for general plan information)

• Technical Assessment for Control Measure MSC-02: “In-Use Compliance

Program for Air Pollution Control Equipment (All Pollutants)” May 11, 1999

• Rule and Control Measure Forecast Report - November 14, 1997
Appendix A: Supporting Documentation on the Removal of 31 1994 Ozone SIP

Control Measures from the 1997 AQMP

A - 6

NOTE

THE DISTRICT IS PROVIDING A COMPLETE SET OF SUPPORTING

DOCUMENTATION TO THE U.S. EPA FOR THEIR REVIEW. BECAUSE OF

THE VOLUME OF DOCUMENTATION, THIS INFORMATION WILL NOT BE

INCLUDED IN COPIES TO THE PUBLIC. COPIES OF THE FULL APPENDIX

ARE AVAILABLE FOR REVIEW IN THE DISTRICT LIBRARY. (LIBRARY

HOURS: TUES – THURS: 10:00 a.m. – 5:00 p.m.; FRI - 8:00 a.m. - 3:00 p.m.;

CLOSED: SAT - MON)
APPENDIX B

NEW AND REVISED STATIONARY SOURCE

CONTROL MEASURES
CONTRIBUTORS

Barry R. Wallerstein, D.Env.

Executive Officer

Jack P. Broadbent

Deputy Executive Officer

Planning, Rule Development and Area Sources

Elaine Chang, DrPH

Assistant Deputy Executive Officer

Planning, Rule Development and Area Sources

Henry Hogo

Planning and Rules Manager

Planning, Rule Development and Area Sources

Authors/Contributors Reviewers

Laki Tisopulos – Planning and Rules Manager

Alene Taber – Planning and Rules Manager

Jill Whynot – Planning and Rules Manager

Joe Cassmassi – Senior Meteorologist

Jay Chen – Program Supervisor

Dave Coel – Program Supervisor

Moustafa Elserif – Program Supervisor

Kathy Hsiao – Program Supervisor

Julia Lester – Program Supervisor

Susan Nakamura – Program Supervisor

Zorik Pirveysian – Program Supervisor

Gary Quinn – Air Quality and Compliance

 Supervisor

Chris Abe – Air Quality Specialist

Naveen Berry – Air Quality Specialist

Mike Krause – Air Quality Specialist

Larry Irwin – Air Quality Specialist

Pamela Perryman – Air Quality Specialist

Ricardo Rivera – Air Quality Specialist

Darren Stroud – Air Quality Specialist

Susan Yan – Air Quality Specialist

Vaskem Yardemian – Transportation Specialist

Barbara Baird – District Counsel

Frances Keeler – Sr. Deputy District Counsel

Production

Rachel Valenzuela – Senior Office Assistant
Table of Contents

i

Table of Contents

Introduction ......................................................................................................................B-1

Format of Control Measures..............................................................................................B-1

Control Measure Number.......................................................................................B-1

Title.......................................................................................................................B-2

Summary Table......................................................................................................B-2

Description of Source Category .............................................................................B-2

Proposed Method of Control..................................................................................B-3

Emissions Reduction..............................................................................................B-3

Rule Compliance....................................................................................................B-4

Test Methods.........................................................................................................B-4

Cost Effectiveness..................................................................................................B-4

Implementing Agency ............................................................................................B-5

References.............................................................................................................B-5

Listing of Stationary Source Control Measures..................................................................B-5

GROUP 1 CONTROL MEASURES WITH EXPEDITED

ADOPTION/IMPLEMENTATION SCHEDULES

CTS-02C(P2) Further Emission Reductions from Solvent Cleaning

Operations - Rule 1171 [VOC]...................................................................B-7

CTS-07(P3) Further Emission Reductions from Architectural Coatings

and Cleanup Solvents - Rule 1113 [VOC]................................................. B-10

CTS-08 Further Emission Reductions from Industrial Coating and

Solvent Operations [VOC] ....................................................................... B-13

PRC-06 Further Emission Reductions from Industrial Processes [VOC]................. B-16

GROUP 2 NEW STATIONARY SOURCE CONTROL MEASURES

CTS-09 Further Emission Reductions from Large Solvent and

Coating Sources [VOC] ........................................................................... B-19

FUG-05 Further Emission Reductions from Large Fugitive

VOC Sources [VOC] ............................................................................... B-23

FUG-06 Further Emission Reductions from Hydrogen Plant Process Vents

[VOC]...................................................................................................... B-26

RFL-02(P2) Further Emission Reductions from Gasoline Dispensing Facilities

[VOC]...................................................................................................... B-29

GROUP 3 REMAINING 1997 AQMP STATIONARY SOURCE CONTROL

MEASURES

CTS-02E Further Emission Reductions from Adhesives - Rule 1168 [VOC] ............ B-33

CTS-02O Further Emission Reductions from Usage of Solvent -

Rule 442 [VOC]....................................................................................... B-36

FUG-03 Further Emission Reductions from Floating Roof Tanks [VOC]................ B-39

FUG-04 Further Control of Emissions from Fugitive Sources [VOC] ..................... B-43
Table of Contents

ii

CMB-06 Emission Standards for New Commercial and

Residential Water Heaters [NOx] .............................................................. B-47

MSC-01 Promotion of Lighter Color Roofing and Road Materials Programs [All

Pollutants]................................................................................................ B-54

MSC-03 Promotion of Catalyst-Surface Coating Technology Programs

[O3, CO] .................................................................................................. B-61

PRC-03(P2) Emission Reductions from Restaurant Operations [VOC, PM10] ............... B-65

WST-01 Emission Reductions from Livestock Waste [VOC, NH3]......................... B-71

WST-02 Emission Reductions from Composting [VOC, NH3, PM10]...................... B-79

WST-03 Emission Reductions from Waste Burning [VOC]..................................... B-84

WST-04 Emission Reductions from Disposal of Materials

Containing Volatile Organic Compounds [VOC] ...................................... B-87

FSS-04 Emission Charges of $5,000 Per Ton of VOC for Stationary Sources

Emitting Over 10 Tons Per Year [VOC]................................................... B-90

FLX-01 Intercredit Trading Program [All Pollutants]............................................. B-93

GROUP 4 LONG-TERM STATIONARY SOURCE CONTROL

MEASURES

ADV-CLNG Long-Term Control Measure for Solvent Cleaning and Degreasing

Operations [VOC].................................................................................... B-99

ADV-CTS Long-Term Control Measure for Miscellaneous Industrial Coating

 and Solvent Operations [VOC].............................................................. B-102

ADV-FUG Long-Term Control Measure for Fugitive Emissions [VOC]................... B-106

ADV-PRC Long-Term Control Measure for Industrial Process Operations [VOC]... B-109
Appendix B: New and Revised Stationary Source Control Measures

B - 1

INTRODUCTION

This Appendix describes the stationary control measures to be included in the Proposed

1999 Amendment. The major revisions to the 1997 AQMP stationary source control

strategy include the introduction of four new short-term measures and expediting the

adoption and implementation portions of the 1997 AQMP long-term measures. These

actions are expected to significantly reduce the reliance on the long term [or Section 182

(e)(5)] measures as compared to the 1997 AQMP. There are another 14 existing shortterm measures from the 1997 AQMP that the District is responsible for implementing,

which will continue to be included in the 1999 Amendment. Thirteen of the 14 control

measures have a revised adoption and implementation schedule as well as minor

clarifications, in some instances, to reflect the current status of the control measures.

One control measure from the 1997 AQMP, CM#97FSS-04, is a further study strategies

measure. As such, no specific adoption or implementation dates are provided until after

further technical evaluations for feasibility are completed.

FORMAT OF CONTROL MEASURES

Included in each control measure description is a title, summary table, description of

source category, proposed method of control, estimated emission reductions, rule

compliance, test methods, cost effectiveness, and references. The type of information

that can be found under each of these subheadings is described below.

Control Measure Number

Each control measure is identified by a control measure number such as “CM #99CTS07” located at the upper right hand corner of every page. “CM #” is the abbreviation for

the “control measure number” and is immediately followed by the year of the AQMP

revision. The next designation represents the source category, for example “CTS”

represents coatings and solvents, “CMB” represents combustion, etc.

The three-letter designation, “CTS” represents the abbreviation for a source category.

For example “CTS” is an abbreviation for “Coatings and Solvents.” The following

provides a description of the abbreviations for each category of measure.

• CTS Coatings and Solvents

• FUG Fugitive Emissions

• CMB Combustion Sources

• MSC Miscellaneous Sources

• PRC Process Related Emissions
Appendix B: New and Revised Stationary Source Control Measures

B - 2

• WST Waste Related Measures

• FSS Further Study Strategies

• FLX Compliance Flexibility Programs

• ADV Advanced Technology Measures

If the measure is based on a 1997 AQMP control measure, the former control measure

number is the same, except the year designator will be 99, indicating the 1999

Amendment to the 1997 AQMP, e.g. CM #99MSC-01 is based on CM #97MSC-01. In

some instances control measures have a suffix designation of (Px)" to represent

additional phases of adoption and implementation and "x" represents the phase.

Title

The title contains the control measure name and the major pollutant(s) controlled by the

measure. Titles that state “Control of Emissions from...” indicate that the measure is

regulating a new source category, not presently regulated by an existing source- specific

District rule. Titles that state “Further Emission Reductions of” imply that the measure

would result in an amendment to an existing District rule.

Summary Table

Each measure contains a table that summarizes the measure that is designed to identify

the key components of the control measure. The table contains a brief explanation of the

source category, control method, emission reductions, control costs, and implementing

agency. It should be noted that the 1999 Amendment establishes a set of reduction

commitments as stated in Table 2-6 of this document. The emission reductions listed in

the summary table for each control measure illustrate how the total reduction

commitments were derived.

Description of Source Category

This section provides a general description of the emission source categories subject to

the proposed control measure. It is not unusual that during rule development when

source-specific survey or inventory is conducted, some source subcategories identified

by the control measure are found not to be the primary sources of concern. Expansion or

replacement of emission source categories, or an update to the inventory to reflect the

current characteristics of source categories may occur to achieve the required emission

levels.

Proposed Method of Control

The purpose of this section is to identify potential control options an emission source can

use to achieve emission reductions. If an expected performance for a control option is
Appendix B: New and Revised Stationary Source Control Measures

B - 3

provided, it is intended for informational purposes only and should not be interpreted as

the targeted overall control efficiency for the proposed control measure. The overall

control efficiency for a control measure should take into account achievable controls in

the field by various subcategories within the control measure. This type of analysis is

typically conducted during rulemaking, not in the planning stage. It has been the

District's long standing policy not to exclude any control technology and have

intentionally identified as many control options as possible to spur further technology

development. Therefore, potential control options described in this section do not ensure

their viability when subject to further technology assessment conducted during the

rulemaking process.

Emissions Reduction

The emission reductions are estimates based on the baseline inventories prepared for the

1997 AQMP and are provided in the Control Measure Summary Table. Because the

1999 AQMP Amendment addresses specifically the ozone SIP, the planning inventory

(i.e., summer inventory for VOC and NOx) is reported. The emissions section of the

summary table includes the 1993, 2006, and 2010 inventory. The 2006 and 2010

emission projections reflect implementation of District adopted rules. Based on the

expected reductions associated with implementing the control measure, emission data are

calculated for 2006 and 2010 assuming the implementation of the control measure in the

absence of other competing control measures. For those control measures contained in

the original 1997 AQMP, the emission reductions are the same as in the 1997 AQMP.

The emission reductions listed in the summary table represent the current best estimates,

which are subject to change during rule development. As demonstrated in previous

rulemaking, the District is always seeking maximum emission reductions when proven

technically feasible and cost-effective. For emission accounting purposes, a weighted

average control efficiency is calculated based on the targeted controls. The concept of

weighted average acknowledges the fact that a control measure or rule consists of several

subcategories, the emission reduction potential for each subcategory is a function of

proposed emission limitation and the associated emission inventory. Therefore, the use

of control efficiency to estimate emission reductions does not represent a commitment by

the District to require emission reductions uniformly across source categories. In

addition, due to the current structure of emission inventory reporting system, a control

measure may partially affect an inventory source category (e.g., certain size of

equipment or certain level material usage). In this case, an impact factor is incorporated

into the calculation of a control efficiency to account for the fraction of inventory

affected. During the rule development, the most current inventory will be used.

However, for tracking rate-of-progress on the SIP emission reduction commitment, the

approved AQMP inventory will be used. More specifically, emission reductions due to

mandatory or voluntary, but enforceable, actions will be credited under SIP obligations.
Appendix B: New and Revised Stationary Source Control Measures

B - 4

It should also be noted that given the 1997 AQMP baseline emission inventories, the

SIP commitments provided by the 1999 AQMP Amendment for emission reductions

from the stationary sources that the District is responsible for implementing are

listed in Table 2-6. The information listed for individual measures is provided as

supporting documentation to illustrate how the overall reduction commitments were

derived. . The District will adopt these individual measures unless they are found to be

infeasible and equivalent replacement measures are sought. This approach ensures

expeditious progress and attainment on schedule.

Rule Compliance

This section was designed to satisfy requirements in the 1990 Clean Air Act in which

EPA has indicated that it is necessary to have a discussion of rule compliance with each

control measure. This section discusses the recordkeeping and monitoring requirements

envisioned for the control measure. As discussed under this section of the control

measure, the District would continue to verify rule compliance through site inspections

and submittal of compliance plans.

Test Methods

In addition to requiring recordkeeping and monitoring requirements, EPA has stated that “An

enforceable regulation must also contain test procedures in order to determine whether sources

are in compliance.” This section of the measure identifies appropriate approved District, ARB,

and EPA source test methods.

Cost Effectiveness

The Discounted Cash Flow (DCF) method is used to calculate the cost-effectiveness of

each control measure. The cost analysis is in 1993 dollars. As control measures undergo

the rulemaking process, more detailed control costs will be developed, and therefore,

may differ from the data presented here. In addition, among various control options

identified as potential control methods the cost effectiveness analysis often selects one

typical control technology to provide an indication of possible control costs.

Furthermore, because these costs vary with the stringency of control levels, it is

inevitable, in many cases, to assume certain control efficiency to calculate the costs.

These assumptions should not be viewed as the intended control targets proposed by the

control measures.

Implementing Agency and Implementation Schedule

This section identifies the agency or agencies responsibility for implementing the control

measure. Also included in this section is a description of any jurisdictional issues that

may affect the control measure’s implementation. In addition, the starting

implementation and the date of full implementation are presented in this section.
Appendix B: New and Revised Stationary Source Control Measures

B - 5

References

This section identifies directly cited references, or those references used to provide

general background information.

LISTING OF STATIONARY SOURCE CONTROL MEASURES

The control measures in the Proposed 1999 Amendment are presented in the following

sections in six subcategories or groupings:

Group 1: Control Measures with Expedited Adoption/Implementation Schedules;

Group 2: New Stationary Source Control Measures;

Group 3: Remaining 1997 AQMP Stationary Source Control Measures; and

Group 4: Long-Term Stationary Source Control Measures.
Appendix B: New and Revised Stationary Source Control Measures

B - 6

This page intentionally left blank.
GROUP 1

Control Measures with Expedited Adoption/Implementation

Schedules
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-02C(P2)

B - 7

FURTHER EMISSION REDUCTIONS FROM

SOLVENT CLEANING OPERATIONS (RULE 1171)*

[VOC]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: SOLVENT CLEANING AND DEGREASING OPERATIONS

CONTROL METHODS: NEAR-ZERO OR ZERO-VOC COATING FORMULATIONS

EMISSIONS (TONS/DAY):

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 35.5 29.4 30.7

VOC REDUCTION 9.6 10.0

VOC REMAINING 19.8 20.7

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 39.6 32.6 34.0

VOC REDUCTION 10.6 11.0

VOC REMAINING 22.0 23.0

CONTROL COST: $900 PER TON OF VOC REDUCED

IMPLEMENTING AGENCY: SCAQMD

* This measure was adopted in October 1999 by the District Governing Board.

DESCRIPTION OF SOURCE CATEGORY

This control measure proposes to lower the VOC content limits wherever feasible from solvent

cleaning operations.

Background

Solvent cleaning and degreasing is the use of VOC containing solvents to remove uncured

coatings, inks, and adhesives, and/or contaminants such as dirt, soil, oil, and grease. Solvent

cleaning operations are applicable to four major industrial operations, namely: production, repair,

maintenance, and servicing. These operations apply to the cleaning of products, tools,

equipment, machinery, general work areas, and the storage and disposal of materials used in the

cleaning process. Cleaning operations are currently regulated under Rule 1171 which was

adopted in 1991 and subsequently amended several times with the most recent amendment in

June 1997.

ARB’s Solvent Cleaning/Degreasing Study

In December 1995, the ARB conducted a study to develop a comprehensive base year inventory

of total organic gases (TOG) for the solvent cleaning and degreasing source category. Through

this study, significant improvements were made in the solvent cleaning emissions inventory.

Improvements to the inventory methods include speciation of 15 solvent groups and three
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-02C(P2)

B - 8

equipment groups as well as the use of actual 1993 end-user data. As a result, 32 equipment and

solvent types were created in the inventory tracking system.

Due to the ARB study, this source category becomes a major source targeted for emission

reductions. Rule 1171 - Solvent Cleaning Operations was originally adopted in August 1991 and

recently amended in 1997. After implementation of Rule 1171 these source categories are

expected to continue to be major sources of VOC emissions. Emission reductions would require

the development of aqueous cleaning and degreasing materials for almost all applications. Nearzero- and zero-VOC cleaning and degreasing materials are available and it is believed that

industry is currently using solvent material which emit at a lower VOC content than the 50 grams

per liter limit required by the rule. Thus, the objective of this control measure is to get EPA

approval of an existing SCAQMD test method/protocol which can detect the VOC content level

of solvents with concentrations of less than 50 grams per liter. With EPA’s approval of a new

test method, the VOC limits in Rule 1171 can be lowered to facilitate the introduction of super

clean solvents.

PROPOSED METHOD OF CONTROL

In general, implementation of this advanced control measure will rely on the current SCAQMD

Method 313, Determination of Volatile Organic Compounds (VOC) by Gas Chromatography/

Mass Spectrometry (GC/MS) to analyze the VOC content limit below 50 grams per liter. This

test method is currently used to determine applicability for SCAQMD’s Clean Air Solvent (CAS)

Certificate but has yet been approved by EPA. The test evaluates the sample for the presence of

Volatile Organic Hazardous Air Pollutants (VOHAPs), Ozone Depleting Compounds (ODCs)

and Global Warming Compounds (GWCs). The issuance of the certificate depends on no

detection of VOHAPs, ODCs and GWCs in a solvent which has a VOC content limit no more

than 50 grams per liter. The test should be able to measure the exact VOC content limit of the

solvent material. To achieve lower VOC limits, certain affected sources are expected to use

zero- or near-zero-VOC coating formulations and aqueous cleaning materials; others will

continue to use higher VOC materials depending on the availability of the technology. When

setting the VOC limits, the availability of technology, the product performance, and other

environmental issues will be considered.

In addition, in seeking additional reductions the District would also assess if emission sources can

be grouped into an existing source category that is more definitive, a new source category is

needed, or that the miscellaneous category is appropriate.

EMISSIONS REDUCTION

Emission reductions estimated to further reduce VOC emissions are approximately 11 tons per

day, beyond the existing rule requirements, by 2010. However, reductions that have occurred

through other actions, either mandatory or voluntary, that are enforceable will be credited

towards SIP obligations. Any additional reductions achieved and/or rule amendments shall be

credited toward CM#99ADV-CLNG commitments.
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-02C(P2)

B - 9

Emission inventory and anticipated reductions for 2006 and 2010 are summarized in the Control

Measure Summary.

RULE COMPLIANCE

Rule compliance would be similar to compliance requirements under Rule 1171. Recordkeeping

and monitoring requirements would be similar to Rules 109 and 1171.

TEST METHODS

Test methods include the following:

• U.S. EPA Test Methods 2, 2A, 2C, or 2D, measurements of ventilation rate in a hood or

enclosure and District Method 1.1, measure of traverse points.

• U.S. EPA Reference Method 24, Code of Federal Regulations Title 40, Part 60, Appendix A -

Determination of Volatile Matter Content, Water Content, Density Volume Solids, and

Weight Solids of Surface Coatings. District Section III, Method 22, Determination of Exempt

Compounds;

• U.S. EPA Test Method 25, 25A, or District Method 25.1 for the determination of total

organic compound emissions;

• ASTM Method D2879;

• ASTM Method D-1078-78, Standard Test Method for Distillation Range of Volatile Organic

Liquids;

• District Method 303, 304, 313, 308 and

• District Methods 19 and 22 - Laboratory Methods of Analysis for Enforcement SamplesSection III, Determination of Exempt Compounds Content.

COST EFFECTIVENESS

The cost effectiveness of this control measure is estimated to be about $900/ton.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has authority to regulate VOC emissions from solvent cleaning operations. The

measure as adopted by the District requires full implementation by November 2001. For SIP

purposes, reductions are taken in 2002.

REFERENCES

ARB, 1995. Solvent Cleaning/Degreasing Source Category Emissions Inventory. California Air

Resources Board. December 1995.
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-07(P3)

B - 10

FURTHER EMISSION REDUCTIONS FROM ARCHITECTURAL

COATINGS AND CLEANUP SOLVENTS (RULE 1113)

[VOC]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: ARCHITECTURAL COATINGS, CLEANUP SOLVENTS

CONTROL METHODS: NEAR-ZERO OR ZERO-VOC COATING FORMULATIONS

EMISSIONS (TONS/DAY)

 1:

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 56.3 38.2 25.1

VOC REDUCTION 2.6 8.3

VOC REMAINING 35.6 16.8

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 66.4 45.1 29.6

VOC REDUCTION 3.1 9.8

VOC REMAINING 42.0 19.8

CONTROL COST: $22,000 PER TON OF VOC REDUCED

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

This control measure proposes to further control VOC emissions from various architectural

coating categories.

Background

Architectural Industrial Maintenance (AIM) coatings are used to beautify and protect homes,

office buildings, factories, and their appurtenances on a variety of surfaces - metal, wood, plastic,

concrete, wallboard, etc. These coatings are applied to the interior and exterior of homes and

offices, factory floors, bridges, stop signs, roofs, swimming pools, driveways, etc. AIM coatings

may be applied by brush, roller or spray gun; by consumers, painting contractors, or maintenance

personnel.

AIM coatings are one of the largest non-mobile sources of VOC emissions in the Basin. Because

AIM coating surfaces cannot be painted within an enclosure vented to an air pollution control

device, the most cost-effective method to control VOC emissions from AIM coatings is to

reduce the VOC content of the coating.

 

1 Baseline emissions inventory reflects remaining emissions after implementation of short- and

intermediate- term measures.
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-07(P3)

B - 11

The 1994 SIP included control measure CM# 94CTS-07: Further Emission Reductions from

Architectural Coatings. This control measure proposed to reduce VOC emissions through

establishing lower VOC-limits and expanding the applicability of Rule 1113. The estimated VOC

emission reductions anticipated from implementation of this control measure was 75 percent.

Appendix IV, Section 1 of the 1997 AQMP included a control measure for architectural

coatings: CM# 97CTS-07: Further Emission Reductions from Architectural Coatings (Rule

1113). This measure proposes to establish lower-VOC limit for numerous, large volume coating

categories. CM#97CTS-07 was implemented by two amendments to Rule 1113, occurring in

November 1996 and May 1999. Both amendments established two-tiered VOC content

reductions from various coating categories, resulting in estimated VOC emission reductions of

approximately 50 to 63 percent. However, further technology assessments are needed prior to

rule adoption for additional reductions from this source category. Thus, the objective of this

control measure is to allow for the development of advanced near-zero- and zero-VOC coatings

to further reduce architectural coatings by an additional 12 percent to yield an overall reduction

of 75 percent, consistent with the 1994 SIP measure.

Regulatory History

District Rule 1113 - Architectural Coatings, was originally adopted on September 2, 1977, to

regulate VOC emissions from the application of architectural coatings. Since its adoption, this

rule has been amended numerous times incorporating more stringent VOC limits as the

technology for lower-VOC coatings has become available.

PROPOSED METHOD OF CONTROL

Implementation of this control measure will rely on establishing VOC limits beyond short- and

intermediate-term control measures. To achieve lower VOC limits affected sources are expected

to use near-zero- and zero-VOC paints and to broaden the application of such paints for various

substrates. In support of this control measure, a contract has been initiated for the development

and assessment of low- and zero-VOC coatings for additional coating categories, including clear

wood finishes, stains, and waterproofing sealers. The evaluation would include a variety of

performances to be conducted on the various coating categories, as well as a thorough

assessment of any hazardous air pollutants or safety issues with the use of this new technology.

The development and demonstration efforts are expected to be completed by mid-2000.

Successful commercialization of these zero-VOC coatings would result in the implementation of

this control measure. Reduction opportunities from cleanup solvents associated with

architectural coating use will also be examined to be consistent with Rule 1171.

EMISSIONS REDUCTION

The estimated emission reductions for 2006 and 2010 are summarized in the Control Measure

Summary. Emission reductions from these source categories are in addition to those reductions

anticipated through implementation of the counterpart short- and intermediate-term control

measures identified in Section 1 of Appendix IV of the 1997 AQMP. Furthermore, the emissions

inventory and estimated reductions are based on the 1999 California Air Resources Board

Survey.
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-07(P3)

B - 12

RULE COMPLIANCE

This control measure would incorporate rule compliance requirements similar to those identified

in Rule 1113.

TEST METHODS

Test methods include the following:

• U.S. EPA Reference Method 24, Code of Federal Regulations Title 40, Part 60, Appendix A -

Determination of Volatile Matter Content, Water Content, Density Volume Solids, and Weight

Solids of Surface Coatings. District Section III, Method 22, Determination of Exempt

Compounds;

• ASTM Test Method D1613-85 - Determination of Acid Content of Coating;

• District Method 303, 304, 311, and

• District Methods 19 and 22 - Laboratory Methods of Analysis for Enforcement Samples-Section

III, Determination of Exempt Compounds Content.

COST EFFECTIVENESS

The cost effectiveness of this advanced control measure has been estimated to be $22,000 per

ton.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has authority to regulate VOC emissions from architectural coating. Implementation

of this control measure would begin in 2006 and would be fully implemented by the end of 2008

with 9.5 tons/day of VOC emission reductions.
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-08

B - 13

FURTHER EMISSION REDUCTIONS FROM

INDUSTRIAL COATING AND SOLVENT OPERATIONS*

[VOC]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: INDUSTRIAL COATING AND SOLVENT OPERATIONS

REGULATED UNDER EXISTING REGULATION XI RULES

CONTROL METHODS: LOW-VOC COATING FORMULATIONS

EMISSIONS (TONS/DAY):

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY N/A 24.5 27.1

VOC REDUCTION 2.4 5.0

VOC REMAINING 22.1 22.1

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY N/A 24.5 27.1

VOC REDUCTION 2.4 5.0

VOC REMAINING 22.1 22.1

CONTROL COST: $2,000 TO $7,700 PER TON OF VOC REDUCED

IMPLEMENTING AGENCY: SCAQMD

* The District amended Rule 1130 in October 1999 to achieve 1.9 tons/day of VOC emission

reductions, which will be credited to the commitment of this measure.

DESCRIPTION OF SOURCE CATEGORY

Background

The District currently regulates industrial coating and solvent operations through numerous

source-specific regulations. The primary control strategy is to set VOC content limits for various

coating applications.

The objective of this control measure is to further assess industrial coating operations to identify

those emissions within this category that can be either further reduced or better categorized in

order to establish appropriate controls.

Regulatory History

This source category represents a wide variety of industrial coating operations. The type of

operation, industry, and size of the source would determine which rule(s) or regulation(s) that

these sources are regulated under. Currently, industrial coating operations are regulated under

District Regulation XI and Regulation IV.
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-08

B - 14

PROPOSED METHOD OF CONTROL

The primary control method to be considered would be coating reformulation. Other

technologies such as UV and EB applications can also be viable compliance options that

individual sources may choose. District staff will conduct a comprehensive evaluation of existing

Regulation IX to identify further emission reduction potential. Sources of information to assist in

this evaluation include comparable rules adopted by other districts in the state and past BACT

determination for low-VOC materials. If deemed technically feasible and cost-effective, existing

Regulation XI will be amended to seek additional reductions. It is anticipated that the

implementation of this control measure would involve multiple rulemaking proceedings.

EMISSIONS REDUCTION

Based on the comprehensive evaluation of existing source-specific regulations and emission

source categories, the proposed control strategy targets 5 tons/day VOC reductions by 2010.

However, reductions that have occurred through other actions, either mandatory or voluntary,

that are enforceable will be credited towards SIP obligations.

Emission inventory and estimated reductions for 2006 and 2010 are summarized in the Control

Measure Summary.

RULE COMPLIANCE

Rule compliance would be similar to compliance requirements under Regulation XI - Source

Specific Rules. Recordkeeping and monitoring requirements would be similar to Rule 109.

TEST METHODS

Test methods include the following:

• U.S. EPA Test Methods 2, 2A, 2C, or 2D, measurements of ventilation rate in a hood or

enclosure and District Method 1.1, measure of traverse points.

• U.S. EPA Reference Method 24, Code of Federal Regulations Title 40, Part 60, Appendix A -

Determination of Volatile Matter Content, Water Content, Density Volume Solids, and

Weight Solids of Surface Coatings. District Section III, Method 22, Determination of Exempt

Compounds;

• U.S. EPA Test Method 25, 25A, or District Method 25.1 for the determination of total

organic compound emissions;

• ASTM Method D2879;

• ASTM Method D-1078-78, Standard Test Method for Distillation Range of Volatile Organic

Liquids;

• ASTM Test Method D1613-85 - Determination of Acid Content of Coating;
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-08

B - 15

• District Method 303, 304, 313, 308, 311, and 313; and

• District Methods 19 and 22 - Laboratory Methods of Analysis for Enforcement SamplesSection III, Determination of Exempt Compounds Content.

COST EFFECTIVENESS

The cost effectiveness of this control measure has not be determined. However, it is anticipated

that the cost effectiveness would fall within the range of recently adopted VOC rules (i.e., $1,400

- $3,700 per ton).

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has authority to regulate VOC emissions from industrial coating and solvent

operations. Implementation of this measure would begin in 2004 with full implementation by

2008 with 4.7 tons/day of VOC emission reductions.
Appendix B: New and Revised Stationary Source Control Measures CM #99PRC-06

B - 16

FURTHER EMISSION REDUCTIONS FROM INDUSTRIAL PROCESSES

[VOC]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: MANUFACTURING OPERATIONS (E.G., POLYESTER RESIN

OPERATIONS; RUBBER, PLASTIC AND OTHER CHEMICAL

MANUFACTURING; BREWERIES; FOOD FLAVORING

OPERATIONS; PAINT MANUFACTURING)

CONTROL METHODS: LOW VOC MATERIALS, ADD-ON CONTROLS, PROCESS

CHANGES, PROCESS CONTROLS, IMPROVED HOUSEKEEPING

EMISSIONS (TONS/DAY):

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 5.5 9.0 10.4

VOC REDUCTION 1.4 2.1

VOC REMAINING 7.7 8.3

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 7.7 12.7 14.6

VOC REDUCTION 1.9 3.0

VOC REMAINING 10.8 11.6

CONTROL COST: NOT DETERMINED

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

Background

The source categories targeted under this control measure include several types of manufacturing

operations and industrial processes. These categories include, but are not limited to, polyester

resin operations (fiberglass); plastics, synthetic rubber and other chemical manufacturing;

breweries; food flavoring operations, and paint manufacturing. VOC emissions from polyester

resin operations are associated with the evaporation of styrene from gel coat or resin during the

application process and curing phase. For synthetic rubber products, plastics manufacturing, and

chemical processes (vulcanizable elastometric materials), VOC emissions primarily occur during

the curing, mixing, storage and handling of materials containing VOC. The primary source of

VOC emissions from beer brewing is ethanol which is released during grain drying, fermentation

process, and packaging operations. With regard to the food flavoring products, VOC emissions

are primarily associated with the use of alcohols (as carriers) from the spray dryers and the flavor

encapsulation processes. VOC emissions from paint manufacturing primarily occur during the

mixing and blending of solvents, resins, and pigments.
Appendix B: New and Revised Stationary Source Control Measures CM #99PRC-06

B - 17

Regulatory History

The source categories identified in this control measure are for the most part not regulated under

source-specific District rules (and are exempt under Rule 219) except for polyester resin

operations that are regulated under Rule 1162 which limits the monomer content in polyester

resin materials and requires process controls. The majority of polyester resin operations use a

spray-up, hand lay-up, brush-up and contact-molding type of process in manufacturing their

products. Rule 219 also exempts hand lay-up, brush-up and spray-up of less than one gallon of

gel coat or resin.

PROPOSED METHOD OF CONTROL

The potential control methods for reducing VOC emissions from these source categories include

adsorbers, thermal oxidizers, scrubbers, process changes/controls, low monomer content

materials, the use of vapor suppressant, the use of photoinitiation, lowering the resin molecular

weight, or the use of other low- or no-VOC monomers. Improved housekeeping practices for

rubber, plastics and chemical manufacturing operations, especially during transportation, mixing

or storage of materials can be an effective means of reducing emissions. Containers, tanks and

mixers should also be covered at all times, if feasible, except for filling or emptying these

receptacles. This control measure may entail multi-phase rulemaking to address different source

categories. Feasible control methods and their reduction potential will be identified for individual

source categories during rulemaking.

EMISSIONS REDUCTION

The projected emissions for 1993, 2006 and 2010 are provided in the Summary section. The

proposed control measure is targeted to achieve 3 tons per day by 2010. However, reductions

that have occurred through other actions, either mandatory or voluntary, that are enforceable will

be credited towards SIP obligations. As part of the rule development, further study would be

required to better quantify the emissions as well as the corresponding reductions associated with

these source categories.

RULE COMPLIANCE

Facilities covered in this control measure would be subject to reporting, recordkeeping and

monitoring requirements to demonstrate compliance with the specified emission limits identified

in the applicable rules.

TEST METHODS

VOC monitoring or source testing would follow EPA or approved District guidelines or Test

Methods. Alternative guidelines or test methods may be used, provided they have first been

approved by EPA, ARB, and the District. The test methods used in Rule 1162 will be used for

polyester resin operations.
Appendix B: New and Revised Stationary Source Control Measures CM #99PRC-06

B - 18

COST EFFECTIVENESS

The cost effectiveness of this control measure has not yet been determined and would depend on

the type of emission control method selected.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to regulate VOC emissions from manufacturing operations and

industrial processes. Implementation of this control measure would begin in 2004 and would be

fully implemented by the end of 2007 with 2.7 tons/day of VOC emission reductions.
GROUP 2

New Stationary Source Control Measures
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-09

B - 19

FURTHER EMISSION REDUCTIONS FROM LARGE SOLVENT

AND COATING SOURCES

[VOC]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: COATINGS AND SOLVENTS

CONTROL METHODS: ADD-ON CONTROLS, LOW-VOC MATERIALS, OR SUPER

CLEAN COATING MATERIALS

EMISSIONS (TONS/DAY):

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 19.2 20.5 21.6

VOC REDUCTION 5.0 5.6

VOC REMAINING 15.5 16.0

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 24.0 25.6 27.0

VOC REDUCTION 6.3 7.0

VOC REMAINING 19.3 20.0

CONTROL COST: $6,000 TO $18,000 PER TON OF VOC REDUCED

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

Background

Despite existing District rules, the use of coatings and solvents continue to represent a significant

source of emissions in the South Coast Air Basin (Basin). In 1993, coatings and solvents from

permitted facilities (including both permitted and non-permitted emission sources) contributed to

44 tons per day of VOC emissions in the Basin. A major portion of these emissions were

disproportionately attributed to a small number of large VOC-emitting facilities; i.e., 4% of point

source facilities (120 facilities) were responsible for about 45% of the emissions (19 tons per

day) from the use of coatings and solvents. It is estimated that at least 50% of these emissions

are associated with the spraying and drying of surface coatings in spray booths (i.e., emitted

within the confines of the booths). Although spray booths control particulate emissions (PM)

from spraying operations through standard filtration systems, they do not control VOC

emissions. The VOCs emitted in the spraying and drying processes conducted within the spray

booths are generally released uncontrolled to the atmosphere. Furthermore, significant

technology advancement has occurred in control technologies for reducing VOC emissions from

spray booths in a more cost-effective manner. Therefore, opportunities exist to achieve further

emission reductions from these facilities beyond those required under existing District rules with

AQMP parameters for cost-effectiveness.
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-09

B - 20

Regulatory History

Existing source-specific VOC rules establish VOC content limits for various categories of

coatings and solvents (e.g., metal coatings, wood coatings, plastic coatings, etc.). These rules

also allow for alternative compliance mechanisms through add-on control technologies capable of

achieving specified reduction targets (90 to 95%), equivalent to the reductions anticipated from

compliance with VOC limits requirements. Compliance with these rules, however, is primarily

achieved based on the use of compliant coatings and solvents.

PROPOSED METHOD OF CONTROL

The proposed method of control would be to require the use of add-on controls for spray booths

for controlling VOC emissions or alternative emission control strategies including Super Clean

materials (containing no more than 5% by weight VOC) or low-VOC materials capable of

achieving equivalent emission reductions. Control technologies for reducing VOC emissions

from surface coating operations in spray booths include: 1) Adsorbers, 2) Thermal Oxidizers, 3)

Ultraviolet Oxidation, and 4) Hybrid Systems which are briefly discussed here. Such controls

specified would only be considered if they were truly available for a particular application, costeffective, and assumed best engineering for capture efficiency.

The Adsorption systems consist of solid adsorbent material (e.g., activated carbon, zeolite,

haptite) which adsorb and collect VOCs as the VOC laden air stream passes through beds (or

chambers) of adsorbent material. Once the adsorbent bed(s) are saturated with VOCs, they are

regenerated by passing steam or hot air over the bed(s) to remove VOCs which is often

recovered and re-used. Adsorbers can be designed to have a control efficiency of 90% of

captured vapors and operate over a wide range of VOC concentrations and flow rates.

Thermal oxidizers (or afterburners) can also be used for controlling VOCs from surface coating

operations in spray booths by burning or thermally oxidizing VOCs at high temperatures. The

three main types of thermal oxidizers include the direct flame, the catalytic, and the regenerative

thermal oxidizers. In direct flame thermal oxidizers, the flame comes in direct contact with the

VOC-contaminated gas stream in a combustion chamber at temperatures of about 1400° to

1500° F where VOCs are oxidized to carbon dioxide and water. The catalytic oxidizers are

direct flame oxidizers equipped with catalysts (platinum or other precious metal) which allow the

combustion process to occur at lower temperature of about 600° to 800° F, reducing energy

costs. The regenerative thermal oxidizers consist of two or more chambers containing heat

transfer media (e.g., silica gravel or ceramic beads) which are heated to temperatures of about

1400° to 1500° F. Once the VOC-contaminated gas is passed through the first chamber media

and is oxidized, the heat from the hot combustion gases from the first chamber is transferred to

the second chamber to continue to oxidize the contaminated stream.

In ultraviolet (UV) oxidation, the VOC contaminated air stream is first exposed to ultraviolet

light and then is mixed with ozonated air which breaks down the large VOC molecules into

smaller molecules. The exhaust stream is then passed through an ozonated water scrubber which

provides additional ozone for further VOC breakdown.
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-09

B - 21

Hybrid systems represent the latest innovations in VOC control using both an adsorber

(containing 2 or more beds) and an oxidizer. As one bed is saturated with VOCs, it is

regenerated with hot air and the ensuing stream with high VOC concentration is then vented to

the oxidizer. The hot exhaust stream from the oxidizer is also used to regenerate the VOCsaturated beds. The adsorbers in these systems produce a low volume, high concentration gas

stream from a high volume, low VOC concentration gas stream from the surface coating

processes. As a result, the final stream can be treated by a small oxidizer, thus reducing capital

and operating costs (SCAQMD, 1998).

Depending on the type of surface coating operation, these control technologies can be utilized to

achieve a VOC destruction efficiency of at least 90%. The overall control efficiency would need

to consider capture efficiency that can be achieved. Also, in order to maximize the emission

reduction potential from this control measure, facilities could be required to maximize the use of

their spray booths by conducting all of their coating and cleaning operations within the spray

booths, to the extent possible.

In addition to add-on control technologies, alternative emission reduction strategies exist which

can achieve the required reductions from coatings and solvents. Super Clean materials including

powder coatings, UV cured Coatings, and Electron-beam cured coatings generate zero or very

low VOC emissions. Also, the use of other low-VOC materials that could result in equivalent

emission reductions could also be considered in lieu of add-on controls.

During the rule development process, further analysis will be conducted to evaluate the extent of

emissions from various coating and solvent operations and the extent of spray booth usage as

well as the applicability and feasibility of the proposed controls for large VOC-emitters. As part

of the feasibility evaluation, physical constraints of a particular facility to install add-on controls,

technical limitations on the effectiveness of add-on controls due to low-concentration, large

volume operations, and cost-effectiveness will be considered. If portions of the emission

reductions targeted by measure are deemed infeasible, other substitute measures/controls can be

introduced to meet the SIP obligation.

EMISSIONS REDUCTION

The VOC inventories for 1993, 2006, and 2010 are provided in the Control Measure Summary.

The estimated VOC emission reductions anticipated from implementation of this measure are

identified for 2006 and 2010 based on the annual average and summer planning inventories.

The emission reductions targeted reflect the current knowledge of large VOC sources in the

Basin. As more information is identified during rulemaking, emission reduction potential will be

adjusted accordingly.

RULE COMPLIANCE

This control measure would require monthly recordkeeping of all coatings and solvents under

Rule 109, Recordkeeping for Volatile Organic Compound emissions. Compliance would be

determined and assessed through recordkeeping as well as District inspections.
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-09

B - 22

TEST METHODS

Test methods for VOC emissions could include:

1. U.S. EPA Reference Method 24, Code of Federal Regulation Title 40, Part 60.

2. SCAQMD Test Method 304, Determination of Volatile Organic Compound (VOC) in

Various Materials.

3. U.S. EPA Method 55, Federal Regulation 26865, Efficiency of the Collection Device of the

Emission Control System.

4. U.S. EPA Test Method 25, 25A, or SCAQMD 25.1 for the determination of total organic

compound emissions.

COST EFFECTIVENESS

Implementation of the proposed measure would impose a cost impact on the top VOC emitting

facilities with spray booths in the Basin. Factors affecting cost include type of coatings and

coating operations, material usage, and type and size of add-on controls. Based on a typical addon control system, the cost effectiveness of this measure is estimated to be in the range of $6,000

to $18,000 per ton of VOC reduced.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to regulate VOC emissions from spray booths. Implementation of

this control measure would begin in 2003 and would be fully implemented by the end of 2006

with 6.3 tons/day of VOC emission reductions.

REFERENCES

South Coast Air Quality Management District. 1998. Best Available Control Technology

Guidelines Update (Phase IID), Staff Report. May 28, 1998.
Appendix B: New and Revised Stationary Source Control Measures CM #99FUG-05

B - 23

FURTHER EMISSION REDUCTIONS FROM

LARGE FUGITIVE VOC SOURCES

[VOC]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: ALL

CONTROL METHODS: ADD-ON CONTROLS, LOW-VOC MATERIALS, IMPROVED

INSPECTION AND MAINTENANCE PROGRAMS, PROCESS

CHANGES

EMISSIONS (TONS/DAY):

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 31.3 28.4 29.3

VOC REDUCTION 2.5 2.9

VOC REMAINING 25.9 26.4

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 32.8 29.8 30.8

VOC REDUCTION 2.6 3.0

VOC REMAINING 27.2 27.8

CONTROL COST: UP TO $18,000 PER TON OF VOC REDUCED

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

Background

In 1993, stationary point sources accounted for about 110 tons per day of VOC emissions in the

South Coast Air Basin (Basin). The large VOC-emitting facilities in the Basin have a

disproportionate share of these emissions. Of the 7000 stationary point sources, the top 100

VOC-emitting facilities, representing only 2% of the point sources, contributed to about 31 tons

per day of the VOC emissions (or 34% excluding facilities with large coatings and solvents

operations). The majority of these facilities are currently subject to various source-specific

District rules. However, there is no requirement for these facilities to reduce their facility-wide

mass VOC emissions, and therefore, the sheer magnitude of emissions from these facilities

continues to represent a significant portion of the stationary VOC emissions in the Basin. The

top VOC-emitting facilities targeted in this control measure consist of refineries, oil and gas

production facilities, terminals, chemical plants and manufacturing facilities. Specifically, this

control measure focuses on fugitive VOCs from fugitive components (e.g., valves, connectors,

pump compressors, etc.) as well as emissions from storage tanks, process tanks, oil field

production equipment, and miscellaneous process units. Control of emissions from the large

coatings and solvents operations is addressed separately under Control Measure CTS-08.
Appendix B: New and Revised Stationary Source Control Measures CM #99FUG-05

B - 24

Regulatory History

Existing source-specific VOC rules establish VOC content limits or operating practices, require

add-on controls, or require inspection and maintenance programs depending on the specific

source category. Although effective in reducing emissions, these rules do not impose emission

reductions on a facility basis.

PROPOSED METHOD OF CONTROL

The proposed control measure would require that the top VOC emitters in the Basin implement

emission control strategies to achieve further reductions beyond those required by existing

District rules. The level of emission reduction would take into account technical feasibility and

cost-effectiveness at each facility as well as the contribution of each facility to the amount of

reductions necessary by 2010 to achieve clean air standards.

The control measure will be implemented in two phases. In the first phase, each facility would

submit an Emission Reduction Plan (ERP) to the District which would identify the facility’s

various sources of emissions as well as the facility’s specific plans to achieve further reductions

from these sources. District staff will establish technology-based control targets for various

source categories, taking into account technical feasibility and cost effectiveness. Facilities

would have the flexibility to select the most viable control strategies to meet the required

reductions, including, but not limited to, the use of add-on controls, product reformulations,

process changes, additional controls on above ground storage tanks, or more stringent inspection

and maintenance program to reduce fugitive emissions. Once the facility-specific plan is

evaluated and approved by the District, each facility, in the second phase, would be required to

implement the proposed control strategies according to the schedule outlined in the ERP and

provide periodic reports to the District documenting the progress made. Because of the variation

in the source type, existing controls, and the amount of emissions, ERP would be unique for each

facility. The specific level of control could vary among facilities.

During the rule development process, the emissions and emission source inventories for the large

VOC-emitting facilities as well as the feasibility of various control approaches for affected source

categories will be further evaluated. It could also be noted that due to resource considerations,

this measure may be implemented through multi-phase rule development.

EMISSIONS REDUCTION

The VOC inventories for 1993, 2006, and 2010 are provided in the Control Measure Summary.

The estimated VOC emission reductions anticipated from implementation of this measure are

identified for 2006 and 2010 based on the annual average and summer planning inventories.

However, reductions that have occurred through other actions, either mandatory or voluntary,

that are enforceable will be credited towards SIP obligations.

RULE COMPLIANCE

Facilities subject to this control measure would be subject to reporting, recordkeeping and

monitoring requirements to ensure that the emission control strategies specified in the Emission
Appendix B: New and Revised Stationary Source Control Measures CM #99FUG-05

B - 25

Reduction Plans are implemented and the corresponding emission reduction targets specified for

each facility are achieved. Facilities would provide periodic progress reports to the District

under this program. In addition, District staff would conduct specialized audits of the facility’s

reports and records as well as routine compliance inspections.

TEST METHODS

VOC monitoring or source testing would follow EPA or approved District guidelines or Test

Methods. Alternative guidelines or test methods may be used, provided they have first been

approved by EPA, ARB, and the District.

COST EFFECTIVENESS

Implementation of the proposed measure is expected to impose a cost impact on the top VOC

emitters in the Basin. The cost effectiveness would vary for each facility and would depend on

the type of control strategies employed to achieve the required emission reductions. However,

the facility-wide cost effectiveness based on the available compliance options is not expected to

exceed $18,000 per ton of VOC reduced and much less in many cases.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to require VOC emissions from processes and operations in the

Basin. Implementation of this control measure would begin in 2003 with Phase I reductions,

Phase II beginning in 2004, and Phase III beginning in 2005. A total of 2.9 tons/day of

reductions are expected by the end of 2008 when all three phases are implemented.
Appendix B: New and Revised Stationary Source Control Measures CM #99FUG-06

B - 26

EMISSION REDUCTIONS FROM HYDROGEN PLANT PROCESS VENTS

[VOC]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: HYDROGEN PLANT PROCESS VENTS

CONTROL METHODS: WHERE APPLICABLE, USE OF LOW-METHANOL LTS

CATALYSTS, ADD-ON CONTROLS, AND/OR OPERATING

PARAMETER ADJUSTMENTS

EMISSIONS (TONS/DAY):

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 1.1 1.1 1.1

VOC REDUCTION 0.8 0.8

VOC REMAINING 0.3 0.3

SUMMER PLANNING INVENTORY* 1993 2006 2010

VOC INVENTORY 1.1 1.1 1.1

VOC REDUCTION 0.8 0.8

VOC REMAINING 0.3 0.3

CONTROL COST: $700 PER TON OF VOC REDUCED

IMPLEMENTING AGENCY: SCAQMD

* Emission reductions are not included in the overall SIP commitment because these emissions

may not have been included in the 1997 AQMP baseline emissions inventory.

DESCRIPTION OF SOURCE CATEGORY

Background

Hydrogen is widely used by refineries in a number of refining processes. Among these processes

are hydrocracking and hydrotreating in the production of gasoline and jet fuel. Some refineries

own and operate hydrogen plants on site, while others purchase hydrogen from outside sources.

A total of 14 hydrogen plants located at nine sites have been identified within the District. The

hydrogen design capacity of these plants range from 15 MMscf per day to 100 MMscf per day.

Thirteen of the 14 hydrogen plants affected by this proposed measure use the catalytic steam

hydrocarbon reforming process to produce hydrogen. The process used by the other plant is

non-catalytic partial oxidation of hydrocarbons.

Methanol, a byproduct of the hydrogen manufacturing process, is formed in the shift reactors as a

side reaction between carbon dioxide and hydrogen. Methanol is a VOC and a CAA Title III and

Rule 1401 listed hazardous air pollutant. The emissions from a hydrogen plant include methanol

and non-methanol VOCs and are usually released through process vents such as the CO2 vent,

the deaerator vent and the degassifier vent.
Appendix B: New and Revised Stationary Source Control Measures CM #99FUG-06

B - 27

Regulatory History

The source category identified above is currently not subject to any District source-specific

regulations.

In 1995 US EPA promulgated a regulation restricting hazardous air pollutants (HAPs) from

refineries. The regulation, commonly referred to as the "Refinery NESHAP" or 40CFR63,

Subpart CC, includes a portion, which requires refineries to control emissions of HAPs from

miscellaneous process vents. The NESHAP requires control when the total HAP is 20 ppm or

greater and VOC emissions exceed 72 pounds per day for existing sources or 15 pounds per day

for new sources.

The Refinery NESHAP, which would have applied to hydrogen plant process vents was later

amended by US EPA on August 18, 1998 to exclude vent streams associated with hydrogen

plant process vents. The EPA indicated that little information was available regarding hydrogen

plant vent streams at the time. Later, information showed that the hydrogen plant vents (i.e.,

CO2 vents and deaerator vents) were significantly different from the typical "miscellaneous

process vents" considered in determining the requirements of the Refinery NESHAP. EPA

concluded that it was not appropriate or even possible to apply the miscellaneous process vent

provisions to these hydrogen plant vents. As a result, the hydrogen plant process vents are

currently not subject to any emission reduction regulations.

PROPOSED METHOD OF CONTROL

Methanol byproduct is mainly produced in the shift reactors. For plants that have both High

Temperature Shift (HTS) and Low Temperature Shift (LTS) reactors, the majority of the

methanol is formed in the LTS reactor. Each of the reactors is equipped with a specific catalyst

that promotes the formation of hydrogen.

This control measure recommends consideration of low-methanol producing LTS catalyst as the

primary control method in the reduction of VOC emissions from process vents. In addition,

relatively small amounts of emissions may be reduced by operating parameter changes, such as

lowering LTS temperatures and increasing reactor steam-to-carbon ratios. In cases where nonmethanol VOC emissions are significant add-on controls may be necessary to reduce the

emissions.

EMISSIONS REDUCTIONS

Of the fourteen (14) facilities included in this program, six (6) are responsible for approximately

85 percent of the total 1.1 tons of VOCs emitted per day from all sources. Implementation of

applicable control method(s) is expected to reduce these emissions by about 0.8 tons per day

from the current emission inventory estimate.
Appendix B: New and Revised Stationary Source Control Measures CM #99FUG-06

B - 28

RULE COMPLIANCE

Compliance with this proposed rule will be achieved through source testing. The facility

operators may be required to perform periodic source testing to demonstrate compliance. The

District personnel can also conduct random source testing to verify compliance.

TEST METHODS

Test methods could include District Method 25.3, to determine low concentration non-methane

non-ethane organic compounds. A new test protocol may be developed to better measure

methanol emissions.

COST EFFECTIVENESS

Based on the cost differences between the regular and low-methanol LTS catalysts and the cost

of add-on controls, the cost effectiveness of this measure is expected to be approximately $700

per ton of VOC reduced. This control measure is currently under rule development and a

socioeconomic analysis is being conducted. The cost effectiveness for this control measure may

be revised based more current information.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to regulate emissions from hydrogen plant process vents.

Implementation of this control measure would begin in 2001 and be fully implemented by the end

of 2003 with 0.8 tons/day of VOC emission reductions.

REFERENCES

"Methanol By-Product Formation Over HTS and LTS Catalysts" presented by Jack H.

Carstensen, John Bogid-Hansen and Peter S. Pedersen at 1990 AIChE Ammonia Safety

Symposium, San Diego, CA 8/19-22, 1990.

"Reducing Methanol By-Product Formation over the Low Temperature Shift Converter"

presented by Jack H. Carstensen and Birgitte S. Hammershoi at 1998 AIChE Ammonia Safety

Symposium, Charleston, CA 8/31 - 9/2, 1998.

Status Report "Methanol Emissions from Hydrogen Plants" prepared for American Petroleum

Institute by Hal Taback Company, November 1997.
Appendix B: New and Revised Stationary Source Control Measures CM #99RFL-02(P2)

B - 29

FURTHER EMISSION REDUCTIONS FROM

GASOLINE DISPENSING FACILITIES

[VOC]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: GASOLINE DISPENSING FACILITIES

CONTROL METHODS: ELIMINATION OF AIR INGESTION AND VAPOR GROWTH

DURING FUEL TRANSFER, ENHANCED TESTING

REQUIREMENTS AND FREQUENCY, VAPOR RECOVERY

SYSTEM IMPROVEMENTS

EMISSIONS (TONS/DAY):

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 23.4 22.6 22.8

VOC REDUCTION 2.0 2.0

VOC REMAINING 20.7 20.8

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 23.8 23.0 23.2

VOC REDUCTION 2.0 2.0

VOC REMAINING* 21.0 21.2

CONTROL COST: NOT DETERMINED

IMPLEMENTING AGENCY: SCAQMD AND ARB

* SIP Backstop Commitment

DESCRIPTION OF SOURCE CATEGORY

Background

There are approximately 3,700 retail and 2,000 private-use gasoline dispensing facilities in the

District, dispensing an average of about 17 million gallons of gasoline per day. As gasoline is

transferred from tank trucks to the storage tanks at the dispensing facilities (i.e., Stage I) and

from the storage tanks to the vehicles (i.e., Stage II), emissions could occur for various reasons

including leaks, spills, displacement of vapors by filling operation, and improper use or

maintenance of equipment. Through the implementation of relevant sections of Health and

Safety Code, California Code of Regulations, and District Rule 461 – Gasoline Transfer and

Dispensing, these sources are well regulated and emissions have been reduced significantly.

Nevertheless, there is still room for improvement.

The objective of this control measure is to reduce emissions from this source category through

enhancing existing rule-effectiveness. A phenomenon known as the “vapor growth” caused by

inspiring (or ingestion of) air or vapors into gasoline in the storage tanks during fuel delivery

from the tank trucks can result in significant emissions. When these types of inleakage occur,
Appendix B: New and Revised Stationary Source Control Measures CM #99RFL-02(P2)

B - 30

gasoline vapors grow significantly to saturate and over-pressurize the vapor space in the storage

tank and result in excessive emissions through the vent pipes of the tanks. The excess emissions

due to “vapor growth” at Stage I systems were estimated to be 1 pound (lb) per 1000 gallons of

gasoline delivered (McEntire, 1999). The preliminary result of the District and ARB’s joint

performance testing conducted in early 1999 indicated that 64 percent of the drop tubes had

developed leaks. In addition, based on field observations, District staff estimated that 25 percent

of fuel deliveries had air ingestion or inleakage problems through the delivery hoses. These

estimates and observations support the emission factor of 0.76 lb per 1000 gallons of gasoline

delivered that ARB used to estimate 1993 emissions. In other words, the baseline control

efficiency for the District's Stage I systems associated with gasoline delivery was 92 percent

based on the uncontrolled emission factor of 9.5 lb per 1000 gallons. This control measure will

consider options to increase the performance of Stage I vapor recovery systems.

Another area that may be improved is in Stage II vapor recovery systems for vehicle refueling.

Similar to the situation for Stage I systems discussed above, the baseline emissions from refueling

assumed an emission factor of 1.21 lb per 1000 gallons. This equates to a control efficiency of

87.9 percent since the uncontrolled emission factor for vehicle refueling is 10 lb per 1000 gallons.

This lower than expected efficiency was a result of deficiencies found in Stage II vapor recovery

systems. This measure will evaluate and incorporate feasible control options to further improve

the control performance.

Regulatory History

Gasoline dispensing facilities are currently regulated under Rule 461 – Gasoline Transfer and

Dispensing as well as California Health and Safety Code Sections 41950 et. Seq. and the

associated regulations administered by the ARB. Rule 461 was most recently amended in

September 1995 to partially implement the 1994 AQMP.

PROPOSED METHOD OF CONTROL

This control measure will consider options to, among others, identify and eliminate air or vapor

inleakage at Stage I vapor recovery systems. By observing the gasoline stream through a sight

glass located on the connector, one may identify existence of air ingestion through fuel delivery

hoses. Elimination of air ingestion may be achieved by proper installation of hose connectors and

replacing worn gaskets. Air or vapor ingestion due to inleakage occurring at the drop tubes of

the underground storage tanks may be minimized by the use of rotatable connectors. It may also

be detected by observing the vent streams and verified through appropriate testing. A diagnostic

pressure decay test method currently being developed by ARB specifically for fuel drop tubes

may be used for this purpose. Any component found to be leaking must be replaced or repaired.

Options for improving Stage II vapor recovery efficiency vary significantly depending on the

types of systems used. Enhanced inspection and maintenance with appropriate tracking, site

inspection of new or remodeld sites, training and certification of operators, installers, testers and

repairers are among those that can improve the overall system performance. New or enhanced

test procedures may be instituted to ensure durability and reliability of certified vapor recovery

system components. Various system performance tests may be conducted more frequently,
Appendix B: New and Revised Stationary Source Control Measures CM #99RFL-02(P2)

B - 31

especially for high-volume facilities. In-station diagnostic and/or automatic interlocking systems

may also be effective. In station diagnostic systems may further safeguard against potential

vapor recovery failures. New and less business-distractive diagnostic test methods may be

developed and incorporated to effectively identify and correct system deficiencies. The most

appropriate controls will be developed during rulemaking, which will consider any one or a

combination of options. The District will coordinate its rulemaking efforts with ARB’s efforts to

enhance the vapor recovery program.

EMISSION REDUCTIONS

The projected VOC inventories for 1993, 2006, and 2010 are provided in the Control Measure

Summary. The estimated VOC emission reduction anticipated from implementation of this

measure are about 2 tons per day. These reductions are based on the assumptions that the

overall control efficiencies for both Stage I and Stage II systems will be improved. Emission

reductions resulting from regulatory actions, either by the District or ARB, will be credited under

SIP obligations. These reductions are surplus to the previous reductions claimed in the SIP.

RULE COMPLIANCE

Similar to the existing rule compliance requirements under Rule 461.

TEST METHODS

Test Methods specified for Rule 461 are also applicable to this control measure. In addition, new

diagnostic test methods for both Stage I and Stage II vapor recovery systems, similar to the ones

being developed by ARB, are required. ARB's equipment and component certification testing

procedures and requirements may need to be enhanced to further ensure vapor recovery system

reliability and durability.

COST EFFECTIVENESS

To be determined.

IMPLEMENTATION AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to regulate emissions from gasoline transfer and dispensing and will

coordinate with ARB on its statewide efforts to reduce emissions from this source category. This

control measure would be implemented beginning in 2001 and would be fully implemented by the

end of 2002 with 2.0 tons/day of VOC emission reductions.
Appendix B: New and Revised Stationary Source Control Measures CM #99RFL-02(P2)

B - 32

REFERENCE

Barnard R. McEntire, San Diego County Air Pollution Control District letter to California Air

Resources Board, July 9, 1999, Drop Tube Test Report and Procedure.
GROUP 3

Remaining 1997 AQMP Stationary Source Control Measures
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-02E

B - 33

FURTHER EMISSION REDUCTIONS FROM ADHESIVES - RULE 1168

[VOC]

THE DESCRIPTION PROVIDED IN APPENDIX IV-A OF THE 1997 AQMP

IS STILL APPLICABLE AND IS REPRINTED BELOW.

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: ADHESIVE APPLICATION

CONTROL METHODS: LOWER-VOC MATERIALS, DEMONSTRATE DAILY

COMPLIANCE, RECORDKEEPING

EMISSIONS (TONS/DAY):

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 14.6 8.6 9.4

VOC REDUCTION 0.0 0.9

VOC REMAINING 8.6 8.5

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 20.4 12.0 13.2

VOC REDUCTION 0.0 1.3

VOC REMAINING 12.0 11.9

CONTROL COST: $6,850 PER TON OF VOC REDUCED

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

Background

Adhesives are used in almost every aspect of manufacturing from forming wood laminates to

attaching rear view mirrors and automobile windshields. Almost all of the 40,000 permitted

companies in the District use some form of adhesives. Adhesives are used heavily in the

manufacturing of wood laminates, clothing and furniture, and in attaching plastic tops to

automobiles. Large amounts of adhesives are used in the construction industry; those uses

include gluing wall and floor panels to the main frame, attaching roofs, and installing water

supply lines and drains. Other uses include gluing pictures to frames, the building of Rose Parade

Floats, manufacturing of t-shirts, the installation of floor carpet, etc. The VOC emissions occur

when the adhesive dries or cures.

Regulatory History

Rule 1168 - Control of Volatile Organic Compound Emissions from Adhesive Application, was

adopted in 1989 to reduce VOC emissions from adhesive use. The general limit was 250 g/l of

VOC with higher limits for many specialty categories. The VOC limits for those categories was
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-02E

B - 34

to go to 250 g/l in 1991. The rule was amended in 1991 and 1992 to extend the compliance date

for some specialty coatings. The latest amended rule, December 1993, contains only a few limits

for specialty adhesives; some of those are below the general limit of 250 g/l. Consumer

adhesives are currently regulated by the ARB.

PROPOSED METHOD OF CONTROL

The potential method of control would include the use of waterborne, hot melt, UV cured or

reactive diluent adhesives. Reactive diluent coatings include moisture cured adhesives such as

cyanoacrylate, and metal ion - anaerobic metal to metal adhesives, waterborne adhesives, hot

melts, and catalyzed two component adhesives. Traditional zero-VOC adhesives have been hot

melt, UV cured, moisture cured, and waterborne. Technologies that are replacing the high-VOC

adhesives are UV cure, waterborne and catalysis cured adhesives.

Add-on controls such as carbon absorption and afterburners are more costly for these operations

and generally not used.

EMISSIONS REDUCTION

The projected VOC inventories for 1993, 2006, and 2010 are provided in the Control Measure

Summary. The estimated VOC emission reductions anticipated from implementation of this

measure are identified for 2006 and 2010 based on the annual average and summer planning

inventories. Emission reductions are based on an estimated overall VOC emission reduction of

approximately 10 percent in 2010.

RULE COMPLIANCE

Compliance would be determined as is currently assessed under Rule 1168, with recordkeeping

and District inspections.

TEST METHODS

District methods for VOC analysis used today may not be adequate for the waterborne, UV

cured or reactive diluent adhesives used to comply with the proposed limits. The accuracy of

SCAQMD Method 304 diminishes as the water content of an adhesive exceeds 70 percent and/or

the VOC content goes below 5 percent. Thus, additional test methods may have to be

developed.

Other applicable test methods could include EPA Reference Method 24, Code of Federal

Regulations Title 40, Part 60, Appendix A - Determination of VOC Content of Coatings.

COST EFFECTIVENESS

Implementation of the proposed measure would impose a cost impact on adhesive operations in

the Basin. Factors affecting cost include product reformulations. Based on a control efficiency

of approximately 10 percent, the cost effectiveness of this measure is estimated to be $6,850 per

ton of VOC reduced.
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-02E

B - 35

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to regulate VOC emissions from the use of adhesives.

Implementation of this control measure would begin in 2007 and would be fully implemented by

the end of 2008 with 1.3 tons/day of VOC emission reductions.

REFERENCES

South Coast Air Quality Management District. Rule 1168 - Control of Volatile Organic

Compound Emissions from Adhesive Applications. Amended August 2, 1991.
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-02O

B - 36

FURTHER EMISSION REDUCTIONS FROM

USAGE OF SOLVENT - RULE 442

[VOC]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: USAGE OF SOLVENTS

CONTROL METHODS: REFORMULATED LOW-VOC MATERIALS, MORE EFFICIENT

APPLICATION METHODS

EMISSIONS (TONS/DAY):

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 6.3 4.5 4.2

VOC REDUCTION 0.8 0.8

VOC REMAINING 3.7 3.5

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 8.2 6.0 5.6

VOC REDUCTION 1.1 1.0

VOC REMAINING 4.9 4.6

CONTROL COST: $2,470 PER TON OF VOC REDUCED

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

Background

Rule 442 - Usage of Solvents, formerly Rule 66, was among the first District rules to regulate

emissions of organic compounds. This rule classifies a solvent as either photochemically or nonphotochemically reactive, based on the volume percentages of individual components in the

solvent. This classification is then used to determine the degree of control. Photochemically

reactive solvents are limited to 7.9 pounds per hour (not to exceed 39.6 pounds per day) and

non-photochemically reactive solvents are limited to 81 pounds per hour (not to exceed 600

pounds per day). Heat cured or heat-baked materials are limited to 3.1 pounds per hour (not to

exceed 14.3 pounds per day).

Regulatory History

Rule 442 was originally adopted on May 7, 1976 and amended four times. The last amendment

in March 1982 was to allow more flexibility in coating formulations and make Rule 442

consistent with coating rules in Regulation XI. This consistency was achieved by eliminating the

ambiguity of these compounds being exempt in the 1100 series rules but requiring control under

Rule 442.
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-02O

B - 37

PROPOSED METHOD OF CONTROL

This control measure proposes to reduce VOC emissions from usage of organic materials by

using reformulated low-VOC content organic materials and more efficient application methods.

This replaces the approach of restricting photochemically reactive solvents. In addition, sources

currently subject to Rule 442 will be evaluated to determine if they should be regulated under any

source-specific rules. Remaining sources will continue to be regulated under Rule 442.

EMISSION REDUCTION

The projected VOC inventories for 1993, 2006, and 2010 are provided in the Control Measure

Summary. The estimated VOC emission reductions anticipated from implementation of this

measure are identified for 2006 and 2010 based on the annual average and summer planning

inventories. However, reductions that have occurred through other actions, either mandatory or

voluntary, that are enforceable will be credited towards SIP obligations.

RULE COMPLIANCE

This control measure would require recordkeeping of all coatings and solvent usage similar to

recordkeeping requirements under Rule 109 - Recordkeeping for Volatile Organic Compound

Emissions.

TEST METHODS

Test methods for VOC emissions could include:

1. U.S. EPA Reference Method 24, Code of Federal Regulations Title 40, Part 60, Appendix A

- Determination of Volatile Matter Content, Water Content, Density Volume Solids, and

Weight Solids of Surface Coatings. SCAQMD Method 303, Determination of Exempt

Compounds.

2. SCAQMD Test Method 304, Determination of Volatile Organic Compound (VOC) in

Various Materials.

3. U.S. EPA Method 55, Federal Register 26865, Efficiency of the collection device of the

emission control system.

4. U.S. EPA Test Method 25, 25A, or SCAQMD Method 25.1 for the determination of total

organic compound emissions.

COST EFFECTIVENESS

Implementation of the proposed measure would impose a cost impact on certain unregulated

operations using organic solvents in the Basin. Factors affecting cost include product

reformulations. The cost effectiveness of this measure is estimated to be $2,470 per ton of VOC

reduced.
Appendix B: New and Revised Stationary Source Control Measures CM #99CTS-02O

B - 38

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to regulate emissions from usage of solvents. Implementation of

this control measure would begin in 2002 with 1.1 tons/day of VOC emission reductions.
Appendix B: New and Revised Stationary Source Control Measures CM #99FUG-03

B - 39

FURTHER EMISSION REDUCTIONS FROM FLOATING ROOF TANKS

[VOC]

THE DESCRIPTION PROVIDED IN APPENDIX IV-A OF THE 1997 AQMP

IS STILL APPLICABLE AND IS REPRINTED BELOW WITH MINOR

UPDATES.

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: FLOATING ROOF TANKS

CONTROL METHODS: STEP I: QUANTIFY EMISSIONS FROM STORAGE TANKS

INCLUDED IN THIS CONTROL MEASURE

STEP II: IF EMISSIONS ARE SIGNIFICANT, IDENTIFY COST

EFFECTIVE AND TECHNOLOGICALLY FEASIBLE CONTROL

OPTIONS

EMISSIONS NOT DETERMINED

CONTROL COST: THE COST-EFFECTIVENESS OF THIS CONTROL MEASURE IS

NOT DETERMINED

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

Background

The majority of organic liquid storage containers are above-ground storage tanks. These tanks

can be categorized as either a fixed shell with an external floating roof or a fixed shell with a

fixed roof. Currently, the control technology for a fixed roof tank is an internal floating roof or a

connection to a vapor gathering system. Emissions originate from breathing/evaporation losses

and working emissions for the product stored in the tank. For a fixed roof tank with a fixed roof,

emissions result from displacement of the vapor space during filling of the tank and from

expansion of the vapor from increases in daily temperatures. For a tank with a floating roof,

emissions result from evaporation of “wicking” at the roof seal edge and from evaporation of

“clingage” on the shell as the roof lowers.

Currently there are approximately 1,250 tanks with either an internal floating cover or an external

floating roof regulated under District Rule 463 - Storage of Organic Liquids. Presently, Rule

463 places exemptions on both tank capacity and vapor pressure of the organic solvent stored.

However, emissions from smaller capacity tanks storing organic solvents, along with organic

solvents with the lower vapor pressures, may be a significant source of emissions.
Appendix B: New and Revised Stationary Source Control Measures CM #99FUG-03

B - 40

This control measure will focus on those organic liquid storage tanks, both floating and fixed

roof, that are currently exempt from Rule 463 based on capacity or vapor pressure. Bulk

terminals that are currently exempt under Rule 463 are not expected to be regulated under this

control measure. Thus, this control measure will not affect facilities subject to the Bulk Terminal

Exemption of existing Rule 463.

Regulatory History

On August 15, 1977, Rule 463 - Organic Storage of Liquids, was adopted to control

hydrocarbon (VOC) emissions from above-ground stationary tanks. Subsequently the rule was

amended in 1984 and require double sealed tanks or vapor recovery systems to reduce tank

emissions. This rule applies to the following: 1) any stationary storage tank storing (or holding)

39,630 gallons, or greater, of organic liquid with a true vapor pressure of 0.5 psi or greater,

under actual storage condition; 2) any above ground stationary storage tank storing (or holding)

greater than 19,815 gallons, but less than 39,630 of organic liquid with a true vapor pressure 1.5

psi, or greater; 3) any above-ground stationary tank storing (or holding) 19,815 gallons, or less,

of gasoline. Number 3 does not apply to above-ground stationary tank 2,000 gallons, or less,

and installed and in service prior to January 9, 1976, nor to any above-ground stationary tank

251 gallons, or less, installed on or after January 9, 1976.

The District, in October 1989, initiated a pilot compliance reporting program which was

completed in April 1991. This program was a process by which facilities conducted and

documented inspections of their own operations in a method determined by the District and

agreed to in a Memorandum of Understanding by the participants. Additionally, a training and

certification course was conducted by the District as part of the program This certification and

self-inspection program appears to have increased both compliance with the rule and timely

detection and repair of tank defects (SCAQMD, 1991). However, this study was not able to

quantify emission reduction from this program.

On March 11, 1994, Rule 463 was amended by the District Board to help streamline, or improve,

a facility operator’s compliance status. These administrative changes also addressed rule

deficiencies identified by the EPA and the ARB. Part of these administrative changes will require

self-inspection and compliance reporting by all operators of internal and external floating roof

tanks. (It should be noted that the EPA and ARB are still reviewing these amendments.)

On January 20, 1993, the Bay Area Air Quality Management District (BAAQMD) amended its

Regulation 8 (Organic Compounds), Rule 5 (Storage of Organic Liquids). The BAAQMD rule

applies to stationary storage tanks having a capacity of greater than, or equal to, 1.0 m3 (264

gal). This rule also considers the storage of organic liquid with a true vapor pressure of greater

than 0.5 psia in storage tanks less than, or equal to, 39,626 gallons.

PROPOSED METHOD OF CONTROL

This control measure will be implemented in two steps. In Step I, the District will assess

emissions from tanks exempt from Rule 463 based on the tank capacity and vapor pressure or the

organic material stored. If the emissions from these storage tanks are significant, the District will

proceed with Step II which will include identification of the appropriate control options based on
Appendix B: New and Revised Stationary Source Control Measures CM #99FUG-03

B - 41

the technical feasibility and cost-effectiveness considerations. Control methods for Step II could

include current technologies as discussed below, or different control options that are identified

during Step II.

To control VOC emissions from internal and external floating roof tanks, the current technology

is to install seals. There are three seal categories, termed A, B, and C class. Most vapor

reduction for tanks is accomplished by the secondary seal. All three seal categories have

approximately the same VOC control efficiency (e.g. approximately 90 percent); their difference

is in longevity and maintenance requirements. Class A is more expensive and requires additional

maintenance. Many older tanks have a Class C-type secondary seal, even if they have a Class A

primary seal.

For some fixed roof and internal floating roof tanks, the current technology is to install a vapor

recovery system. Vapor recovery is about 95 percent efficient in the control of VOCs; however,

it is more expensive to retrofit and operate. In November 1997, District staff conducted an

inventory study and determined that the emissions from tanks exempt from Rule 463 to be about

0.4 tons per day. The study recommended further evaluation in the next AQMP revision to

develop alternative approaches to reduce emissions from storage tanks.

EMISSIONS REDUCTION

Potential emission reductions will be assessed in the future based on the inventory and control

options identified.

RULE COMPLIANCE

Compliance can be achieved through self-inspection and compliance reporting by all operators of

internal and external floating roof tanks. This type of program is a process by which facilities

conduct and document inspections of their own operations in a manner prescribed by the District

and agreed to in a Memorandum of Understanding with the program participants.

TEST METHODS

Test methods could include the following:

• EPA Method 25 - Determination of Total Gaseous Non-methane Organic Emissions as

Carbon; or EPA Method 25A - Determination of Total Gaseous Organic Concentration

Using a Flame Ionization Analyzer; or SCAQMD Test Method 25.1 - Determination of

Total Gaseous Non-methane Organic Emissions as Carbon.

• ASTM 1078 - Organic Liquid Storage for use in determining the true vapor pressure

limits.

• SCAQMD Test Method 303 - Determination of Exempt Compounds, for use in

determining exempt compounds.

• EPA Method 21 - Determination of Volatile Organic Compounds Leaks, for use in

determining vapor tightness.
Appendix B: New and Revised Stationary Source Control Measures CM #99FUG-03

B - 42

• SCAQMD Test Method 315 - Determination of Hydrogen Sulfide Mercaptan in Oil and

Sludge Samples, for use in determining hydrogen sulfide concentration in crude oils.

• SCAQMD Test Method 501.1 - Determination of Total Non-Methane Organic Vapors

from Organic Loading and Storage, for use in determining efficiency of vapor recovery

systems.

• EPA Method 18 or ARB Method 422 - Measurement of Gaseous Organic Compound

Emission by Gas Chromatography, for use in determining exempt compounds from

source gases.

COST EFFECTIVENESS

The cost effectiveness of this control measure has not yet been determined. The District will

continue to analyze the potential cost impact associated with implementing this control measure

and will provide cost effectiveness information as it becomes available.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to regulate VOC emissions from the storage of organic liquids.

The implementation schedule for this control measure will be determined in the future.

REFERENCES

South Coast Air Quality Management District. “Draft Staff Report for Proposed Amended Rule

463: Storage of Organic Liquids.” January 11, 1994.

South Coast Air Quality Management District. Rule 463 - Storage of Organic Liquids.

December 7, 1990.

Bay Area Air Quality Management District. Regulation 8 - Organic Compounds - Rule 5 -

Storage of Organic Liquids. January 20, 1993.

SCAQMD. Rule and Control Measure Forecast Report. November 1997.

Western States Petroleum Association. Meeting with SCAQMD. June 28, 1994.
Appendix B: New and Revised Stationary Source Control Measures CM #99FUG-04

B - 43

FURTHER CONTROL OF EMISSIONS FROM FUGITIVE SOURCES

[VOC]

THE DESCRIPTION PROVIDED IN APPENDIX IV-A OF THE 1997 AQMP

IS STILL APPLICABLE AND IS REPRINTED BELOW WITH MINOR

CLARIFICATIONS.

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: PETROLEUM REFINERIES, CHEMICAL PLANTS, OIL & GAS

PRODUCTION FIELDS, NATURAL GAS PROCESSING PLANTS

AND PIPELINE TRANSFER STATIONS

CONTROL METHODS: LEAKLESS COMPONENTS, INSPECTION AND MAINTENANCE

EMISSIONS (TONS/DAY)

1

:

ANNUAL AVERAGE 1993 20062

2010

VOC INVENTORY 12.3 7 6.1

VOC REDUCTION * *

VOC REMAINING * *

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 12.5 7 6.2

VOC REDUCTION * *

VOC REMAINING * *

CONTROL COST: THE COST-EFFECTIVENESS OF THIS CONTROL MEASURE IS

NOT DETERMINED.

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

Background

This control measure is designed to control fugitive VOC emissions from petroleum- and

chemical-related industries such as from petroleum refineries, chemical plants, oil and gas

production fields, natural gas processing plants, and pipeline transfer stations. As currently

proposed, this control measure is not intended to control fugitive VOC emissions at Publicly

Owned Treatment Works.

 

1 The emissions data presented in this control measure reflect currently available data. As more information is

collected during the rule development process emissions and cost data will be developed/revised.

2 Emission reductions in 2006 and 2010 baselines (inventories) reflect the potential impact of modifications that

would be subject to Regulation XIII - New Source Review Best Available Control Technology requirements.

* Due to potential double-counting, emission reductions from this measure are included as part of FUG-05.
Appendix B: New and Revised Stationary Source Control Measures CM #99FUG-04

B - 44

The District has approximately 12 refineries, 61 chemical facilities, 517 oil and gas production

fields, 10 natural gas plants, and 5 pipeline transfer stations (SCAQMD, 1992). Sources of

fugitive VOC emissions at these facilities are from process and transfer areas that contain a wide

variety of VOC-containing petroleum products and chemicals. Generally any process or transfer

area where leaks can occur are sources of fugitive VOC emissions. These areas include, but are

not limited to valves, connectors (i.e. flanged, screwed, welded or other joined fittings), pumps,

compressors, pressure relief devices, diaphragms, hatches, sight-glasses, stuffing-boxes, agitator

seals and meters. The emissions from those fugitive sources are generally dependent on the type

of fluid (light or heavy), the characteristics of leak paths, the inspection frequency, and the

operating conditions. The reduction of valve leaks can produce the most significant emission

reductions on account of their large population. Compressors, which operate at higher pressures,

generally show the highest emission rates, but have the smallest population. Fugitive emissions

for compressors usually occur at the junction of the moving shaft and stationary casing. Hatches,

sight-glasses, meters, and connectors are usually less prone to leakage, but require regular

inspection and maintenance for leak-free operation.

The first point at an oil field where the oil and gas reaches the surface is the wellhead. This

component functions to maintain surface control of the well. Typically, the wellhead is made of

steel and forms a seal to prevent well fluids from blowing or leaking at the surface. The kind of

wellhead and the configuration of the components above the wellhead is determined by

characteristic of the crude and oil field conditions. Some wellheads may be a simple assembly to

support the weight of tubing in the well and may not be built to hold pressure.

Wells with high pressure (or corrosive gases) are usually equipped with heavy valve fittings and

seals to control pressure that may reach 20,000 psi. As crude oil passes through equipment

components of the wellhead, the cutting effect of very fine sand particles or high-speed liquid

droplets may erode valves, fittings, or chokes in the equipment components. As these parts are

worn, VOCs may be released from the valves, flanges, seals and threaded connections. A CEPA

survey conducted in 1990 reported that approximately half the wellheads in the District are fitted

with vapor controls to collect the fugitive VOC emissions (A. L. Wilson, 1994).

About half of the estimated 4,200 uncontrolled wells in the District are found in oil fields where

there is a potential to emit VOCs from the wellhead casing directly to the atmosphere. These are

generally newer oil fields that produce a relatively high volume of gas. Direct venting from the

wellhead could occur during upset conditions at oil fields where there are no gas pipelines, or in

situations where there is a diminished market for the gas.

Regulatory History

District Rule 1173 - Fugitive Emissions of Volatile Organic Compounds, regulates fugitive VOC

emissions sources at industrial facilities by requiring periodic inspection, repair and maintenance.

While Rule 1173 establishes minor and major leak levels at 1000 ppm to 10,000 ppm, and greater

than 10,000 ppm, respectively, much lower levels are possible. The Bay Area Air Quality

Management District’s (BAAQMD) Rule 8-18 requires that leaks in excess of 500 ppm be

minimized within 24 hours and repaired within 7 days after discovery. The leak standard drops

to 100 ppm on January 1, 1997.
Appendix B: New and Revised Stationary Source Control Measures CM #99FUG-04

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District Rule 1148 - Thermally Enhanced Oil Recovery Wells, limits VOC emissions from oil

wells that are enhanced by steam injection to 4.5 pounds per day. While oil fields are regulated

under Rule 1173, non-steam-enhanced wellheads have been exempt. Direct venting of wellhead

gas occurs when the gas is not recovered for beneficial use (SCAQMD 1994). Gases can also be

released directly to the atmosphere from wells that are configured to collect the gas for sale.

This can occur during upset conditions or when there is not a market for wellhead gas. At the

present, there are no accurate data on the number of wells that vent gas, the frequency of

venting, or the total VOC emissions from those wellheads.

PROPOSED METHOD OF CONTROL

This control measure proposes to further reduce VOC emissions from fugitive sources. The goal

is to minimize and decrease the frequency of leaks. Leaks can be minimized and repaired by

tightening, adjustment or replacement of seals and/or packing in the relevant types of equipment.

In addition, equipment can be retrofitted with leakless components for some applications.

This control measure also recommends consideration of the following:

• Improved inspection and repair programs by developing and the use of a certified

inspector program.

• Establish protocols for component identification, count, and leak detection.

EMISSIONS REDUCTION

The projected VOC inventories for 1993, 2006, and 2010 are provided in the Control Measure

Summary. The estimated VOC emission reductions anticipated from implementation of this

measure are identified for 2006 and 2010 based on the annual average and summer planning

inventories. Emission reductions, based on an estimated overall VOC emission reduction of eight

percent in 2010, are included as part of FUG-05.

RULE COMPLIANCE

Compliance with this control measure can be achieved through Rule 1173 compliance reports

and field inspections.

TEST METHODS

Test methods could include: EPA Reference Method 21 to determine fugitive VOC emissions;

ASTM Method E 168-88, E 169-87, E260-85, to determine VOC content of fluids; ASTM

Method D 4457-85 to determine exempt compounds, ASTM Method D 86-82 to determine

initial boiling point of liquids; and ASTM Method D 287 to determine the API gravity of crude

oil.
Appendix B: New and Revised Stationary Source Control Measures CM #99FUG-04

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COST EFFECTIVENESS

The cost effectiveness of this control measure has not yet been determined. The District will

continue to analyze the potential cost impact associated with implementing this control measure

and will provide cost effectiveness information as it becomes available.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to regulate emissions from fugitive sources. The implementation

schedule would be incorporated into control measure FUG-05.

OTHER IMPACTS

Implementation of this control measure will reduce toxic, odorous and greenhouse emissions.

REFERENCES

South Coast Air Quality Management District. Staff Report. Proposed Rule 1173 - Fugitive

Emissions of Reactive Organic Compounds. May 17, 1989.

South Coast Air Quality Management District. Best Available Control Technology Guidelines.

Office of Stationary Source Compliance.
Appendix B: New and Revised Stationary Source Control Measures CM #99CMB-06

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EMISSION STANDARDS FOR NEW COMMERCIAL

AND RESIDENTIAL WATER HEATERS

[NOX]

THE DESCRIPTION PROVIDED IN APPENDIX IV-A OF THE 1997 AQMP

IS STILL APPLICABLE AND IS REPRINTED BELOW TO REFLECT THE

MOST RECENT TECHNICAL INFORMATION.

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: RESIDENTIAL AND COMMERCIAL WATER HEATERS (LESS THAN

75,000 BTU/HR)

CONTROL METHODS: LOW-NOX BURNERS; OTHER CONTROL METHODS, SUCH AS SOLAR

WATER HEATING, AND ELECTRIC THERMAL STORAGE SYSTEMS.

EMISSIONS (TONS/DAY):

ANNUAL AVERAGE 1993 2006 2010

NOx INVENTORY 11.4 13.1 14.0

NOX REDUCTION 3.6 7.6

NOX REMAINING 9.5 6.4

SUMMER PLANNING INVENTORY* 1993 2006 2010

NOX INVENTORY 11.4 13.1 14.0

NOX REDUCTION 3.6 7.6

NOX REMAINING 9.5 6.4

WINTER PLANNING INVENTORY 1993 2006 2010

NOX INVENTORY 11.4 13.1 14.0

NOX REDUCTION 3.6 7.6

NOX REMAINING 9.5 6.4

CONTROL COST: $3,400 TO $11,400 PER TON OF NOX REDUCED

(BASED ON REVISED INVENTORY)

IMPLEMENTING AGENCY: SCAQMD AND LOCAL GOVERNMENTS

* Current rulemaking activity indicates that the baseline emissions are smaller than the estimates

provided in the 1997 AQMP, primarily due to federal and state energy efficiency standards.

The emissions inventory will be revised during rule development.

DESCRIPTION OF SOURCE CATEGORY

Background

In the South Coast Air Basin, there are approximately 4 million natural gas-fired residential-type

water heaters in residential establishments, including mobile homes, and 36,000 additional

residential-type water heaters located in commercial establishments. Based on 1998 data, each
Appendix B: New and Revised Stationary Source Control Measures CM #99CMB-06

B - 48

unit consumes on average about 215 therms of natural gas per day and has an average unit life of

about ten years.

Storage tank-type water heaters are the most common of type of water heaters used in the

residential sector (So Cal Gas, 1999). Storage tanks range in size from 20 to over 80 gallons,

with the most common being between 40 and 50 gallons. In addition to the conventional tanktype water heaters, other types of natural gas-fired water heaters are available such as demand,

tankless coil, and indirect water heaters.

Storage tank water heaters work by heating water in an insulated tank and storing it for use. In

general, a storage water heater operates by releasing hot water from the top of the tank when the

hot water tap is turned on. To replace the hot water, cold water enters the bottom of the tank,

ensuring the tank is always full. Various design improvements have been developed to increase

the efficiency and performance of conventional gas-fired water heaters, such as multiple flues,

submerged combustion chambers, induced-draft blowers, power venting, and condensing water

heaters.

Most residential natural gas-fired water heaters are equipped with atmospheric (natural draft),

multiple port, partially premixed stamped steel burners that can attain NOx emission levels of less

than 40 ng/J. Atmospheric burners naturally pull air in for combustion by the action of a stream

of low-pressure gas expanding through an orifice, thus no blower or fan is required. In

comparison to single-port burners, multiple-port burners provide better distribution of the flame

and heat, thereby eliminating "hot spots", and better controlling thermal NOx.

There are currently five major water heater manufacturers in the United States that produce

about 99 percent of the water heaters sold in the Basin. The five major manufacturers are

American Water Heaters Company; A.O. Smith; Bradford-White Corporation; Rheem

Manufacturing Company; and State Industries, Incorporated (GATC, 1994). These water

heater manufacturers are located outside of California.

Regulatory History

In December 1978, the District’s Governing Board adopted Rule 1121 – Control of NOx from

Residential-Type, Natural Gas Fired Water Heaters. Rule 1121 regulates NOx emissions from

gas-fired water heaters less than 75,000 Btu per hour that are used in residences, mobile homes,

and commercial establishments. In 1982, Rule 1121 required that any gas-fired water heaters

sold, distributed, or installed meet an emission limit of 40 nanograms of NOx (calculated as NO2)

per joule of heat output (ng/J) for a domestic water heater and 50 ng/J for a mobile water heater.

Based on an average life expectancy of ten years, full emission reductions for Rule 1121 was

anticipated by the end of 1992.

The NOx emission limits of Rule 1121 apply to new water heaters. As a result, Rule 1121 is

enforced at the manufacturer, distributor, retailer, and installer level. Water heater manufacturers

that intend to sell natural gas-fired water heaters in the Basin are required to test and obtain

certification that each model is compliant.
Appendix B: New and Revised Stationary Source Control Measures CM #99CMB-06

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Following the adoption of Rule 1121, the District introduced a control measure for residential

and commercial water heaters in the 1989 AQMP. This measure was updated in the 1991

AQMP as Control Measure A-D-3: Control of Emissions from Residential and Commercial

Water Heating. This measure was revised again for the 1994 and 1997 AQMPs as Control

Measure CMB-06: Emission Standard for New and Commercial and Residential Water Heaters.

In 1995, Rule 1121 was amended to incorporate a new certification test protocol, NOx

Compliance Testing for Natural Gas-Fired Water Heaters and Small Boilers, which replaced

requirements for certification pursuant to ANSI standard Z21.10.1-1975. Initially, the objectives

of the 1995 amendments to Rule 1121 were to develop a new certification test protocol, expand

the scope to include water heaters and boilers between 75,000 and 2 million Btu per hour, and

lower the NOx limit.

During the rulemaking for amendments to Rule 1121, it was recommended through an advisory

committee to maintain the existing scope of Rule 1121 and to pursue additional NOx reductions

through a market-based program. As a result, in January 1998 the District’s Governing Board

adopted Rule 1146.2 – Emissions of Oxides of Nitrogen from Large Water Heaters and Small

Boilers which establishes NOx limits for water heaters and boilers between 75,000 and 2 million

Btu per hour. In addition, in April 1997 the District’s Governing Board adopted Rule 2506 –

NOx and SOx Area Source Credits, allowing water heater manufacturers to generate emission

credits for over controlling NOx emissions from water heaters. To date no water heater

manufacturers have participated in this program.

In 1999, the District initiated rulemaking to amend Rule 1121 to implement control measure

CMB-06 from the 1997 AQMP. Proposed amendments to Rule 1121 would reduce the NOx

emission limit from 40 ng/J to 10 ng/J for domestic and mobile home water heaters. Similar to

the current version of Rule 1121, the proposed amendments would apply to new gas-fired

residential type water heaters less than 75,000 Btu/hour.

Other Regulatory Programs

Over the next five years, there are a series of new standards and regulations that will impact the

water heater industry. The most significant change is the American National Standard Institute

(ANSI) Z21.10.1 standard for water heaters that incorporates a new testing protocol to address

the flammable vapor ignition issue. In addition to the revised ANSI standard, the Department of

Energy (DOE) is expected to revise energy efficiency requirements, and EPA's requirements to

phase-out the blowing agent HCFC 141b is expected to affect the foam currently used to insulate

water heaters. There are existing mandatory energy efficiency standards enforced by the

Department of Energy and California Energy Commission and their associated emission

reductions are incorporated into the proposed control measure reductions.

PROPOSED METHOD OF CONTROL

The primary means of reducing emissions from natural gas-fired residential and commercial water

heaters would be use low-NOx burners. Low-NOx burners are designed to control the

combustion process with proper air/fuel mixing and increased heat dissipation to minimize

thermal NOx formation. There are three categories of burner technologies available to reduce
Appendix B: New and Revised Stationary Source Control Measures CM #99CMB-06

B - 50

NOx emissions for natural gas-fired water heaters: (1) atmospheric fully premixed burners; (2)

atmospheric partially premixed burners; and (3) forced draft fully premixed burners.

Atmospheric Fully Premixed Burners

There are two general types of fully pre-mixed burners, radiant and steel burners. In fully premixed, radiant burners, air and fuel are combusted slowly on the porous surface of the burner at

the air-gas interface. Radiant burners are generally made of ceramic or metal fibers. In radiant

burners, even distribution of heat stabilizes the flame and prevents "hot spots," thereby reducing

thermal and prompt NOx. There are a variety of burner manufacturers that have developed

atmospheric, fully pre-mixed, ceramic or metal fiber matrix or metal burners: Alzeta, AcotechFurigas, Polidoro, Solaronics, and Schott Gas Systems.

Alzeta has developed a ported ceramic fiber burner for residential tank-type water heaters in

1991 under a contract sponsored by the District, the Gas Company, and A.O. Smith. The burner

is a flat plate matrix of ceramic fibers consolidated with inorganic binders. Laboratory tests

indicate that the burner can achieve less than 10 ppmv NOx, air free, dry (about 6 ng/J at 80%

recovery efficiency, air free, dry) over 1600 hrs of operation. In addition, the combustion

chamber is sealed, increasing its resistance to flammable vapors.

This technology has been field tested in about 180 water heaters and demonstrated to be

technically feasible for residential water heaters. Field tests were conducted using A.O. Smith

assembled water heaters with Alzeta burners, and installed in residences over a period of 9

months to a year. The field test was concluded in December 1995. The consumer’s response

was generally positive. However, installers raised issues of: 1) cost, 2) ease of serviceability, 3)

availability of standard parts and controls, and 4) burner life. (Alzeta, 1991). (Alzeta, 1991A).

Alzeta has continued to make improvements to their burner design to lower costs and address

issues initially raised. In 1998, under a contract sponsored by the California Energy Commission

and A.O. Smith, Alzeta streamlined the burner processing steps to reduce the manufacturing

costs and modified the water heater design to achieve a low-cost removable burner to improve

the serviceability. (Alzeta, 1998). This burner has not yet been field tested.

Acotech-Furigas, Polidoro, and Schott Gas Systems manufacture low-NOx atmospheric ceramic

and metal fiber burners or materials for these burners that are commercially available in other

applications such as demand or instantaneous water heaters. Although these burners have not

been used in tank-type water heaters, transferring this technology to tank-type residential water

heaters is technically feasible. (Acotech, 1999). (Polidoro, 1999). (Schott Gas, 1999).

(Solaronics, 1999).

Atmospheric Partially Premixed Burner

Atmospheric (natural draft) partially premixed stamped steel low-NOx burners are similar to and

rely on existing burner design technologies. The District is aware of two developers of low-NOx

atmospheric partially premixed stamped steel burners: Altex, and Gas Research Institute (GRI)

and Arthur D. Little. Both of these companies have developed burners specifically for storage

tank type water heaters.
Appendix B: New and Revised Stationary Source Control Measures CM #99CMB-06

B - 51

GRI and Arthur D. Little have a patent for their burner design. This burner relies on three basic

concepts to lower the NOx emissions: 1) staging the combustion air, 2) using a device to stabilize

the primary flame, and 3) using a device to create an internal recirculating of combustion

products into the primary flame zone. A prototype storage tank type water heater was developed

and tested using ANSI and DOE test standards. The NOx emissions were reported to decrease

from 104 to 20 ppmv (3% O2 dry), and the recovery efficiency increased from 75% to 82%

(GRI, 1997).

Under a contract with EPA, Altex Technologies Corporation has designed a low–NOx and lowcost burner for storage tank type water heater. This burner has not been patented. A prototype

water heater was built and laboratory tested. The NOx emissions were reported in a range of 17

to 19 ng/J. (Altex, 1999).

Forced Draft Fully Premixed

A combustion air blower offers another way to control the amount of excess air and the mixing

between air and fuel, thermal and prompt NOx. In addition, the recovery efficiency of the water

heater with a blower is higher compared to that of the atmospheric unit. Several water heater

manufacturers have incorporated the use of combustion air blowers into their designs for

commercial and residential applications, e.g. Power Venting by A.O. Smith. There are a variety

of burner manufacturers with forced draft fully premixed burners.

Additional control technologies capable of achieving equivalent (or greater) NOx emission

reductions such as heat pump water heaters, instantaneous water heaters, electric, or solar are

not excluded from future consideration.

Implementation Approaches

The equipment in this control measure could be implemented through a manufacturer’s

certification program similar to the current Rule 1121. Conceptually, water heaters within the

same model family that have similar operating characteristics and emissions profiles could be

certified. The certifications would be performed at the manufacturers’ level with the District’s

approval. Emissions assigned to the equipment would be based on typical use for specific

applications. Equipment certification is expected to minimize recordkeeping and monitoring

impacts, while providing a level of certainty for emissions reductions. Alternative compliance

schedule is also being considered to provide adequate time for technology development while

achieving targeted remaining emission levels.

EMISSIONS REDUCTION

The projected NOx inventories for 1990, 2006, and 2010 are provided in the Control Measure

Summary. The estimated NOx emission reductions anticipated from implementation of this

measure are identified for 2006 and 2010 based on the annual average, summer planning, and

winter planning inventories. Emission reductions will occur as new water heaters are purchased,

with the life expectancy of an average water heater being 10 years. As previously stated,

emission reductions achieved through other regulatory requirements or voluntary actions shall be

credited under SIP obligations.
Appendix B: New and Revised Stationary Source Control Measures CM #99CMB-06

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RULE COMPLIANCE

Similar to implementation of Rule 1121, compliance with this control measure can be achieved

through a manufacturer’s certification program for water heaters. A certification program would

require water heater manufacturers to have each model tested for compliance with the applicable

emission limits.

TEST METHODS

Measurement of NOx emissions shall be conducted in accordance with applicable EPA test

methods, or other test methods approved by the EPA, ARB, and District.

COST EFFECTIVENESS

The cost effectiveness of this control measure was estimated to be between $3,400 to $11,400

per ton of NOx reduced. The cost effectiveness is based on a revised emission inventory for

CMB-06. The lower range of the cost effectiveness represents the low-NOx portion burner

technology. The upper range of the cost effectiveness represents modifications to the whole

water heater that would achieve the NOx emission limits as well as meet other non-District

related regulatory requirements.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District would be the implementing agency for the water heater certification program.

Implementation of this control measure would be in 2002 for new water heaters with 7.6

tons/day of NOx emission reductions. At the time of rule adoption, the implementation schedule

may change based on the evidence presented at the public hearing.

OTHER IMPACTS

Residential and commercial natural gas consumption may be reduced in the Basin. In addition,

there may be impacts associated with an additional power source used in a forced draft fully

premixed burner.

REFERENCES

South Coast Air Quality Management District. Final Air Quality Management Plan. Appendix

VII-A, Measure N2. El Monte, CA. October 1982.

South Coast Air Quality Management District. Addendum to the Staff Report for Proposed Rule

1146-”Emissions of Oxides of Nitrogen from Industrial, Institutional and Commercial Boilers,

Steam Generators, and Process Heaters.” February 19, 1988.

Southern California Gas Company. “Fact Sheet”. 1987.

South Coast Air Quality Management District. Technology Advancement Office, 1992 Progress

Report, Volume II: Project and Technology Status. October 1992.
Appendix B: New and Revised Stationary Source Control Measures CM #99CMB-06

B - 53

California Department of Finance. 1992. California Statistical Abstract. November 1992.

Pacific Consulting Services. 1994. Electrotechnology Descriptions: Dry Cleaning, Restaurants,

and Swimming Pools (Interim Report). March 1994.

SoCalGas. 1999b. www.socalgas.com/residential/energyhome/ operating.html. August 11,

1999.

SoCalGas. 1999a. www.socalgas.com/residential/energyhome/ operating.html. August 11,

1999.

GRI. 1997. U.S. Patent, Patent Number 5,645,413, Date of Patent: July 8, 1997, Inventors:

Karen Benedeck, Philip Carbone, Bo-Xiong He, Peter J. Loftus, and Charles E. Benson.

Alzeta. 1991. Phase 2, Low Nox Residential Water Heater, Final Report, Alzeta Report No.

93-7057-185, 1991 Contract with SCAQMD, Contract No. C-91210.

Alzeta. 1991A. Phase 3, Low Nox Residential Water Heater, Final Report, Alzeta Report No.

96-7074-206, 1991 Contract with SCAQMD, Contract No. C-91210A.

Alzeta. 1998. Residential Water Heater Burner Cost Reduction, Final Report, Alzeta Report

No. 98-7099-215, Contract with California Energy Commission, Contract No. 500-95-020.

Altex. 1999. Letter from John Kelly to Minh Pham on August 27, 1999.

Acotech. 1999. Acotech-Furigas Manufacturer's Catalog.

Schott. 1999. Schott Gas Systems Inc. Manufacturer's Catalog.

Polidoro. 1999. Polidoro Manufacturer's Catalog.

Solaronics. 1999. Letter from Farshid Ahmady to Minh Pham. July 21, 1999.
Appendix B: New and Revised Stationary Source Control Measures CM #99MSC-01

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PROMOTION OF LIGHTER COLOR ROOFING AND ROAD MATERIALS

PROGRAMS

[ALL POLLUTANTS]

THE DESCRIPTION PROVIDED IN APPENDIX IV-A OF THE 1997 AQMP

IS STILL APPLICABLE AND IS REPRINTED BELOW WITH MINOR

CLARIFICATIONS.

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: ROOFING, PAVING, AND BUILDING MATERIALS AND TREE

PLANTING PROJECTS

CONTROL METHODS: USE OF MORE REFLECTIVE AND LIGHTER COLOR SURFACES

ON EXTERIOR SURFACES LOCATED IN URBAN AREAS

EMISSIONS: IMPLEMENTATION OF THIS CONTROL MEASURE IS

EXPECTED TO LOWER AMBIENT TEMPERATURES IN URBAN

AREAS. LOWER AMBIENT TEMPERATURES WOULD

DECREASE THE FORMATION OF OZONE, WHICH IN TURN IS

EXPECTED TO RESULT IN IMPROVED AIR QUALITY.

CONTROL COST: THE COST EFFECTIVENESS OF THIS CONTROL MEASURE IS

NOT DETERMINED.

IMPLEMENTING AGENCY: SCAQMD, CEC, LOCAL GOVERNMENT

DESCRIPTION OF SOURCE CATEGORY

The purpose of this control measure is to encourage activities that would lower ambient

temperatures in urban areas. This control measure focuses on encouraging activities such as

using lighter, more reflective surface materials and increased tree planting.

Background

Over the past four decades, summer temperatures in urban cities throughout the nation have

increased by 2 to 4

°F. Since 1940, it is estimated that peak temperatures in Los Angeles have

increased approximately 5 to 6°F (Akbari, et al, 1990; EPA, 1990). The increased temperatures

are primarily occurring in urban areas. Moreover, studies have shown that summer temperatures

in urban areas are typically 2°F to 8°F higher than in their rural surroundings. (EPA, 1992).

The difference between urban and rural temperatures is referred to as the “urban heat island

effect.” The replacement of natural vegetation such as trees, grass, and soil with concrete and

asphalt reduces the landscape’s ability to lower daytime temperatures and loses the benefits of

shade. In addition, the use of dark colored materials and surfaces that absorb, rather than reflect

incoming solar energy adds to the effect, thus increasing temperatures in cities and urban areas.
Appendix B: New and Revised Stationary Source Control Measures CM #99MSC-01

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The urban heat island effect has adverse impacts on air quality and energy demands. The

increased solar gain absorbed by the city can increase energy demands for cooling and accelerate

ozone formation. Studies indicate that in large metropolitan cities such as Los Angeles, utility

peak loads will increase 1.5 to 2 percent for every 1°F increase in temperature. In Los Angeles,

energy loads for both Los Angeles Department of Water and Power (LADWP) and Southern

California Edison (SCE) increase by about 2 percent per °F with respect to the base load (Taha,

et al, 1992). In addition, summer heat islands may increase the incidence of smog production.

The ability of a surface to reflect is referred to as albedo and is measured from zero to one, with

one representing the most reflective and zero representing the most absorbent. Most buildings

and cities have albedos between 0.20 and 0.35 (Akbari, et al, 1990). To reduce urban

temperatures, albedos can be increased by using lighter, more reflective materials on surfaces of

roofs and pavement (roads and parking lots). In addition to providing shade to buildings and

surfaces, trees cool the air directly by evapotranspiration and block solar radiation and prevent

these structures and surfaces from heating up beyond the ambient temperature (LADWP, 1992).

Moreover through evapotranspiration, the natural releasing of water vapor from leaves and, trees

cools the environment, thus bringing down the temperature of the entire area.

A preliminary air quality modeling analysis indicates cooler surfaces and tree planting can

improve the ozone air quality in Los Angeles. Initial results indicate that through cooler surfaces

for homes, office-building roofs, and paved surfaces, and planting 11 million trees in Los

Angeles, that the heat island effect can be reduced as much as 3 to 7

°F (Rosenfeld, et al, 1996).

This could potentially reduce ozone exceedances by 12 percent, relative to the state ozone

standard.

In 1998, Environ International Corporation completed a study funded by the SCAQMD. The

objectives of this study were to develop and apply an appropriate air quality modeling approach

to quantify the benefits of the Cool Communities strategy. Environ’s modeling approach focused

on addressing the effects of Cool Communities on temperature and dispersion fields and

incorporating these effects into the latest Urban Airshed Model (UAM) AQMP inputs. In

addition to the UAM modeling, Environ described a modeling approach to identify emission

reduction scenarios that should produce similar ozone benefits to the Cool Communities concept.

Ultimately, such an approach could assist in quantifying VOC and NOx emissions benefits from

implementation of Cool Communities strategies. Due to the relatively small magnitude change

due to Cool Communities relative to ambient ozone, as well as the large Basin-wide natural

variability in meteorological conditions and ozone concentration, Environ was unable to make

recommendations regarding a field demonstration of the Cool Communities concept. This

project addressed critical questions on the potential effects of the control strategy. This

information, in turn, can be used in identifying possible follow-up areas including identification

and implementation of improvements in SCAQMD’s modeling capabilities that can be used to

better assess the potential air quality benefits of the Cool Communities concept.

In addition, U.S. EPA has initiated an evaluation of the Heat Island/Cool Communities concept.

In 1997, EPA initiated a pilot project involving five U.S. cities in an effort to quantify the

potential benefits associated with heat island mitigation in terms of energy savings and improved
Appendix B: New and Revised Stationary Source Control Measures CM #99MSC-01

B - 56

air quality. Based on the results of the modeling and other relevant information, EPA plans to

develop and evaluate a method that outlines how states could earn “credit” for ozone reductions

in their State Implementation Plans through widespread implementation of the heat island

reduction measures. This would take the form of an EPA guidance document. Subsequently,

EPA will implement this modeling on three major cities as an experimental program. These are

Salt Lake City in Utah, Sacramento in California and Baton Rouge in Louisiana. More recently,

the U.S. EPA is working with the City of Los Angeles to develop a demonstration program and

methodologies to quantify the benefits of a Cool Communities program in Los Angeles.

Regulatory History

In January 1992, the EPA introduced a publication, Cooling Our Communities: A Guidebook on

Tree Planting and Light-Colored Surfacing. This guidebook discussed the causes, magnitude and

impacts of increased urban heat islands. In October 1993, President William Clinton and Vice

President Albert Gore introduced as part of their Climate Action Plan an action item to expand

EPA’s Cool Communities program in cities and federal facilities.

There are communities within the Basin which have tree planting programs and ordinances

already in effect. In addition, some utilities provide educational guidance brochures regarding

tree planting.

PROPOSED METHOD OF CONTROL

This control measure proposes to develop a program to promote the use of light colored roofing

and pavement and increased tree planting. Programs to promote use of more reflective pavement

and tree planting could be a required element for new sources, or could be included as

recommendations through the District’s California Environmental Quality Act (CEQA) Air

Quality Handbook. Sources such as builders, utilities, private citizens, etc. that promote the use

of lighter colored materials and increased tree planting could be eligible for an emission credit.

Emission credits could be issued based on types of surface materials used or numbers of trees per

unit or area that meet or exceed a specified benchmark.

There are a variety of techniques that can be implemented to reduce urban temperatures and

increase the albedo of roofs, pavements, and building surfaces. Most of these techniques can be

implemented during the maintenance or modification of existing structures or during the building

stages of new structures.

Roofing Materials

The reflectivity of roofs is measured in terms of roof temperature at noon on a clear summer day,

with an air temperature of 90oF, averaged over the warranted life of the roof. A gray roof with a

smooth or washable texture would have a roof temperature under the aforementioned conditions

of approximately 160oF. A light green roof has a higher albedo, and accordingly a lower surface

temperature of 135oF.
Appendix B: New and Revised Stationary Source Control Measures CM #99MSC-01

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One method of achieving higher albedos is to coat existing surfaces or modify the makeup of new

surfaces so that they incorporate lighter colored materials. Available techniques for roof

whitening include, but are not limited to the following (Taha, et al, 1992):

• adding light-colored aggregate to the roofing material;

• light-colored rocks on flat or gently-sloped roofs;

• colored or painted roofs;

• coating with elastomeric coatings and single plies; and

• using light-colored concrete tiles on sloping roofs.

Pavement and Building Surface Materials

Within the city, there are a number of urban surfaces such as streets, sidewalks, parking lots,

school yards, and other similar surfaces, that have dark surfaces. The following identifies

techniques that can be implemented to lighten urban surfaces (Taha, et al, 1992, Pomerantz,

1996):

• using light-colored aggregates in the upper layer of the asphalt in new pavements;

• using a light-colored slurry or chip seal when resurfacing;

• using concrete rather than asphalt, with a light-colored aggregate and binder;

• whitetopping (light-colored concrete pavements);

• using artificial lighteners in preparing the mixtures of asphaltic concrete and slurry seals;

and

• using paints of light colors that are designed specifically to resist weathering, wear and

tear, and other environmental effects.

In addition to selecting materials with high albedos, other considerations are important to ensure

that materials maintain their original albedos. Considerations that should be taken into account

include, but are not limited to material wear resistance, effects of soiling, and surface texture. In

addition, in selecting materials for roads, parking lots, and driveways, it is important that the

light-colored surface has a non-skid finish.

Tree Planting

To help lower an entire city’s temperatures through evapotranspiration, street trees need to be

planted in public as well as private spaces such as parking lots, plazas, street meridians,

sidewalks, residential yards, corporate lawns, parks, and shopping plazas (EPA, 1992). For

homes and buildings, the most dramatic cooling takes place when trees directly shade windows,
Appendix B: New and Revised Stationary Source Control Measures CM #99MSC-01

B - 58

walls, roofs, and air-conditioning units (LADWP, 1992). For residences, most experts suggest

planting three or more trees, placing them so they will shade the home and outdoor living areas

during the summer months (SCE, 1991). The air conditioning savings are even greater when the

tree shades an office building with large windows and long air conditioning hours.

A general rule of thumb is to plant at least five to ten feet from a structure; moreover, the shape

and projected mature spread of the tree should be taken into account in this distance (LADWP,

1991). To maximize the evaportranspiration of tree planting programs, the placement of trees in

cities is important. The following identifies tree planting strategies that should be considered to

maximize the cooling benefits associated with increased tree planting:

• shade east- and west facing walls and windows of home or building to reduce air

conditioning energy consumption,

• shade roofs to lower the temperature of interiors of homes and buildings, external

surfaces, and surrounding environment,

• shade outdoor air conditioning units to increase its efficiency,

• shade nearby walls and flat surfaces such as walkways, driveways, alleys, and the

streets, and

• plant trees to influence wind movement and circulation around and through residences

and buildings.

In selecting shade trees for large-scale planting, they must be low biogenic emitters (Benjamin &

Winer, 1994). Consideration should also be taken for their tolerance to air pollution, water

requirements, effect (or lack of effect) on sidewalks, sewer lines and overhead electric lines, and

insect and pest resistance (Corchnoy, et al, 1991). The shape, size, species, as well as fire

hazards are important to consider in selecting shade trees. In selecting species, it is important

that trees with the potential to produce biogenic hydrocarbon emissions be avoided. The District

would work with interested parties to develop a list of species of trees that would be

recommended for shading.

EMISSIONS REDUCTION

Implementation of this control measure is expected to decrease ambient temperatures in the

Basin, particularly during summer months. Improved air quality is expected as a result of lower

urban temperatures.

RULE COMPLIANCE

Implementation of this measure could be based on the following:

• local government model ordinances;
Appendix B: New and Revised Stationary Source Control Measures CM #99MSC-01

B - 59

• legislative strategies for incentives; and

• public outreach for consumer awareness.

In addition, the District may consider the development of an emissions credit mechanism to

provide emission credits based on the number of units modified or installed that use materials and

colors meeting or exceeding a specified benchmark.

TEST METHODS

ASTM Committee E6.04 will publish in 1996 test procedures and ratings for the temperature rise

of roofs and pavements, and DOE will propose a Solar Reflectance Index.

COST EFFECTIVENESS

The cost effectiveness of this control measure is estimated as high but has not yet been fully

determined. The District will continue to analyze the potential cost impact associated with

implementing this control measure and will provide cost effectiveness information as it becomes

available.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

Implementation of this measure is expected to require the partnership of the District, CEC, and

local government. This is a voluntary program and currently does not have any specific

implementation schedule unless a mandatory program is developed.

REFERENCES

Rosenfeld et. al. “Policies to Reduce Heat Islands: Magnitudes of Benefits and Incentives to

Achieve Them,” EE-1, U.S. Department of Energy, Washington, D.C. MS 90-2000, Lawrence

Berkeley National Laboratory, Berkeley, California. 1996.

Pomerantz, M., H. Akbari, A. Chen, H. Taha, A.H. Rosenfeld. “Paving Materials for Heat Island

Mitigation,” LBL 38074, Berkeley, CA. 1996.

U.S. Environmental Protection Agency. Cooling Our Communities. A Guidebook on Tree

Planting and Light-Colored Surfacing. January, 1992.

Akbari, H., Rosenfeld, A.H., Taha, H. “Summer Heat Islands, Urban Trees, and White

Surfaces.” January, 1990.

Taha, H., R. Ritschard, and B. Huang. “Urban Climates, Global Change, and Energy Use: A

Preliminary Investigation of the Potential for Offset with High Albedo and Increased Vegetation

Cover, “ DRAFT, Lawrence Berkeley Laboratory, December 1992.
Appendix B: New and Revised Stationary Source Control Measures CM #99MSC-01

B - 60

Taha, H., D. Sailor, and H. Akbari. “High-Albedo Materials for Reducing Building Cooling

Energy Use.” Heat Island Project Energy and Environment Division Lawrence Berkeley

Laboratory. January 1992.

Los Angeles Department of Water and Power. “Smart Planting for the New Urban Forest. A

Guide to Planting Trees Around Your Home.” 1992.

Southern California Edison. “Trees Saving Energy Naturally.” 1991.

Corchnoy, B. Stephanie, Janet Arey, Roger Atkinson. “Hydrocarbon Emissions from Twelve

Urban Shade Trees of the Los Angeles, California, Air Basin.” November 1991.

ENVIRON International Corporation. “Air Quality Modeling Evaluation of the Cool

Communities Ozone Control Strategy." March 1998.

United States Environmental Protection Agency. Personal conversation/written communication

with Virginia Gorsevski. September 1999.
Appendix B: New and Revised Stationary Source Control Measures CM #99MSC-03

B - 61

PROMOTION OF CATALYST-SURFACE COATING TECHNOLOGY

PROGRAMS

[O3, CO]

THE DESCRIPTION PROVIDED IN APPENDIX IV-A OF THE 1997 AQMP

IS STILL APPLICABLE AND IS REPRINTED BELOW WITH MINOR

CLARIFICATIONS.

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: RESIDENTIAL AND STATIONARY AIR CONDITIONING UNITS

CONTROL METHODS: INCORPORATE SURFACE COATING-CATALYST

TECHNOLOGIES IN AIR CONDITIONING UNITS

EMISSIONS: IMPLEMENTATION OF THIS CONTROL MEASURE IS

EXPECTED TO RESULT IN THE CONVERSION OF AMBIENT

OZONE AND CARBON MONOXIDE INTO OXYGEN AND

CARBON DIOXIDE, RESPECTIVELY.

CONTROL COST: THE COST-EFFECTIVENESS OF THIS CONTROL MEASURE IS

NOT DETERMINED.

IMPLEMENTING AGENCY: SCAQMD, LOCAL GOVERNMENT

DESCRIPTION OF SOURCE CATEGORY

The purpose of this control measure is to encourage the incorporation of surface coating-catalyst

technologies in residential and commercial air conditioning units, in order to promote the

conversion of ground-level ozone and carbon monoxide into oxygen and carbon dioxide. To

maximize air quality benefits, this control measure would be primarily implemented in those areas

within the South Coast Air Basin that experience the highest ambient ozone levels.

Background

Ozone concentrations in the SCAQMD have decreased significantly over the past twenty years.

As air quality continues to improve in the Basin, high ozone concentrations occur less frequently

and in limited, localized areas. Similarly, exposure to high ozone concentrations occurs over

smaller areas. These trends make it more cost-effective to plan and implement local

concentration reduction strategies in characteristically high ozone exposure receptor areas rather

than implementing more stringent District-wide emission control programs for stationary and

mobile sources.

One such ozone control strategy which has been proposed is the use of air-conditioner-bound

catalysts for ozone scrubbing. Surfaces that come into contact with large volumes of ambient air

can be coated with catalysts, which chemically convert ambient ozone and carbon monoxide
Appendix B: New and Revised Stationary Source Control Measures CM #99MSC-03

B - 62

(CO) into harmless gases. Applicable surfaces with regard to stationary source applications

include residential and commercial air conditioning units, utilizing the existing condenser surface

area or perhaps adding a catalyzed filter across the exhaust air stream. These catalytic coatings

could also be applied to heating and ventilation equipment as well. Such catalysts are unique in

that they can reduce: (1) ambient ozone in high ozone receptor areas, and (2) individual ozone

exposures.

Up to 1997, the preponderance of work evaluating the effectiveness of surface coating-catalyst

technology was performed by Engelhard Corporation. Their work has focused on the use of this

technology on motor vehicle radiator surfaces, due to the large amount of ambient air flow

across this surface type. Field tests made on vehicle radiators confirmed that 80 percent of ozone

contacting PremAirTM treated radiators was destroyed.

In 1997, an augmentative investigation, using Engelhard Corporation's PremAirTM catalyst, was

conducted by Systems Application International, Inc. (SAI) under contract with the South Coast

Air Quality Management District (SCAQMD) to better understand the design parameters and air

quality benefits. A rigorous air quality modeling assessment was conducted to estimate the

potential magnitude of control expected with the implementation of the ozone-scrubbing catalyst.

This effort focused on determining the ozone concentration reduction, equivalent pollutant

reduction potential, and cost-effectiveness of the catalyst. The exposure modeling results

suggest that changes in exposure due to the simulated ozone scrubbing range from less than one

percent to 17 percent, depending on the exposure measure and method used. The study

addressed critical questions on the potential effects of a scavenger-based control strategy.

Although the ozone modeling results indicate that ozone-scrubbing catalyst technologies would

likely provide a relatively small area-wide ozone benefit, the exposure modeling results indicate a

greater potential benefit.

Regulatory History

There is currently no regulatory history with regard to the use of surface coating-catalyst

technology for the direct reduction of ground level ozone and CO emissions for stationary source

applications. To date, the regulatory and analytical framework for addressing ozone reductions

has historically been based on directly reducing emissions of VOC and NOx (ozone precursors).

However, recently ARB adopted a methodology to calculate emission reduction credits

associated with the use of the catalyst technology in mobile source applications as part of phase

II of the Low Emissions Vehicle control program. As part of the next comprehensive plan

update, the methodology will be assessed to determine if it could potentially be applied to

stationary sources.

PROPOSED METHOD OF CONTROL

This control measure proposes to develop a program to promote the use of surface coatingcatalyst technologies in residential and commercial air conditioning units. The program would

specifically focus on those areas in the South Coast Air Basin that exhibit the highest ozone

levels in order to maximize the emission reduction potential of this control strategy. The use of

surface coating-catalyst technology could be a required element for new sources, or could be
Appendix B: New and Revised Stationary Source Control Measures CM #99MSC-03

B - 63

included as a recommendation through the SCAQMD’s California Environmental Quality Act

(CEQA) Air Quality Handbook. The issuance of emission reduction credits could also be used to

promote the implementation of this technology.

EMISSIONS REDUCTION

Implementation of this control measure is expected to decrease ambient ozone and carbon

monoxide emission levels in the Basin, particularly during summer months. While the District is

unable to quantify emission reductions at this time, the catalyst manufacturer has provided

information to indicate that on an individual air conditioning unit basis, the proposed technology

could achieve an air benefit equivalent to eliminating VOC exhaust emissions from a new vehicle

meeting California’s ULEV standard.

RULE COMPLIANCE

Implementation of this measure could be based on the following:

· local government model ordinances;

· legislative strategies for incentives; and

· public outreach for consumer awareness.

In addition, the SCAQMD may consider the development of an emissions credit mechanism to

provide emission credits based on the number of air conditioning units that are modified or

installed that use surface coating-catalyst technology.

COST-EFFECTIVENESS

Due to the small magnitude of the effects of the ozone scrubbing process relative to ambient

ozone, as determined in the SAI study, the cost-effectiveness of this control measure has not yet

been fully determined. The PremAirTM catalyst is commercially available. The degree to which

technologies, such as PremAirTM, are actually commercialized will be affected by factors such as

incentives, adoption of control strategies focusing on localized high ozone receptor areas, and the

degree of emphasis on reducing ozone exposure.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

Implementation of this measure is expected to require the partnership of the SCAQMD and local

government agencies. This is a voluntary program at this time and if specific mandatory

regulations are developed, an implementation schedule may be specified.

REFERENCES

Johnson, David, E3 Ventures. Written communications with Mike Nazemi. November to

December, 1995.

Johnson, David, E3 Ventures. Written communications with Dr. Alan Lloyd. June, 1995.
Appendix B: New and Revised Stationary Source Control Measures CM #99MSC-03

B - 64

Sierra Research. “An Evaluation of On-Road Ozone Destruction Using a Catalyst-Coated

Automobile Radiator.” Report No. SR95-03-06, prepared for Engelhard Corporation, March 30,

1995.

Systems Applications International, Inc. "Estimation of the Effects of an Ozone Control Strategy

Focusing on Air Conditioning-Bound Catalysts for Ozone Scrubbing." Report No. SYSAPP98-

97/59rl, prepared for the South Coast Air Quality Management District, February 1998.
Appendix B: New and Revised Stationary Source Control Measures CM #99PRC-03(P2)

B - 65

EMISSION REDUCTIONS FROM

RESTAURANT OPERATIONS - PHASE II

[VOC, PM]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: RESTAURANT OPERATIONS

CONTROL METHODS: EXHAUST CONTROL TECHNOLOGY; ADD-ON CONTROLS; GRILL

DESIGN CHANGES

EMISSIONS (TONS/DAY):

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 1.7 1.3* 1.3*

VOC REDUCTION 0.9 0.9

VOC REMAINING 0.4 0.4

PM INVENTORY 11.8 10.6* 10.6*

PM REDUCTION 7.0 7.0

PM REMAINING 3.6 3.6

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 1.7 1.3* 1.3*

VOC REDUCTION 0.9 0.9

VOC REMAINING 0.4 0.4

CONTROL COST: $2,800 TO $9,300 PER TON OF VOC AND PM REDUCED

IMPLEMENTING AGENCY: SCAQMD

* Inventory adjusted to account for implementing Rule 1138 PM and VOC reductions from

chain-driven charbroilers by November 1999.

DESCRIPTION OF SOURCE CATEGORY

Background

Information presented in this control measure (e.g., emissions inventory, control efficiency, and

cost-effectiveness) represents the current understanding of the source category. During the rule

development process, the District will continue to collect and assess information, as it becomes

available. Information collected during the rule development process will be appropriately

reflected in the rule applicability and requirements as for all other measures.

This control measure covers restaurant facilities which use charbroilers, the equipment

responsible for 94% of the emissions from this source category. This currently represents

approximately 37% of the estimated 29,000 restaurants in the Basin. Restaurants employ a

number of cooking devices, such as charbroilers, deep fat fryers, griddles, ovens, rotisseries, etc.,
Appendix B: New and Revised Stationary Source Control Measures CM #99PRC-03(P2)

B - 66

which emit VOC and/or PM pollutants. Testing has shown the majority of PM emissions are

measured at 2.5 microns and below.

Charbroiling Operations

Charbroiling operations are the most common method of direct meat-firing by "quick service"

and full-service restaurants. The charbroiler can be located either against the wall where the

exhaust flows to a wall-mounted hood, or in the middle of the kitchen where the exhaust flows to

an island-type hood. Depending on the number of hoods and the ventilation configuration, other

equipment such as deep fat-fryers and griddles may be vented to the same hood.

Charbroiling consist of three main components: a heating source, a high-temperature radiant

surface, and a grill. The grill, which is grated, holds the meat while exposing it to the radiant

heat. When grease (fat) and meat additives such as tenderizers fall from the cooking meat onto

the high-temperature radiant surface, both volatile organic compounds (VOC) and fine

particulate matter (PM) emissions are generated. The decomposition of fat and food additives

releases various gaseous organics including aldehydes, organic acids, alcohol, and nitrogen and

sulfur compounds. Particulate emission result from the fat being entrained when dripping grease

flares up.

Charbroilers are further distinguished as either chain-driven or under-fired. A chain-driven

charbroiler is a semi-enclosed device with a mechanical chain, which automatically moves the

food through the device. Under-fired means the heat source in located below the food.

Restaurants chiefly operate flame-fired broilers during the dinner hours of 6PM to 8 PM.

However, many "quick service" food establishments have direct-flame broilers with peak

operations from 11 AM to 2 PM and from 5 PM to 7 PM.

Deep-fat Frying and Indirect-fired Grills (Griddles)

An estimated 62% of all restaurants within the Basin use deep-fat fryers and 55% have griddles.

Source tests have shown that the PM emissions are below the detectable range for deep-fat fryers

and comprise 5% of the total PM inventory for griddles. Likewise, the deep-fat fryers contribute

2% of the VOC emissions inventory from this category and griddles make up 4% of the total.

Therefore, this control measure is directed at under-fired charbroilers.

Deep-fat frying involves the cooking of food products such as potatoes, corn chips, donuts, fish

sticks, and poultry parts in hot oil or fat. The cooking medium is usually vegetable oil (e.g.,

cottonseed and sunflower) or animal fat (lard) at 3250 F to 4000 F. Most of the raw food

products have a water content ranging from 10 to 75 percent prior to the frying. Immersion of

these raw materials into hot oil results in vaporization of their water content. VOC and PM

emissions from deep-fat frying occur as a result of carry-over of oil mist and some degree of oil

distillation upon water vaporization (Walden 1971). Source testing has shown a strong

correlation between emissions and the type of food cooked.

Indirect-fired grills have no flame contact between the material being cooked and the heat source

and the temperatures involved in cooking are lower than in charbroiling. Thus, the emissions

associated with grilling are much less than those which come from charbroiling.
Appendix B: New and Revised Stationary Source Control Measures CM #99PRC-03(P2)

B - 67

REGULATORY HISTORY

Rule 219 – Equipment not Requiring a Written Permit Pursuant to Regulation II, was amended

September 11, 1998 to specifically exempt the following equipment from written permit

requirements of Rules 201 – Permit to Construct and 203 – Permit to Operate:

"Equipment used in eating establishments for the purpose of preparing food for human

consumption, including commercial charbroilers and associated control equipment subject to

Rule 222."

Rule 222 – Filing Requirements for Specific Emission Sources not Requiring a Written Permit

Pursuant to Regulation II, is a permit streamlining rule which requires sources subject to its

provisions, to obtain a filing rather that a permit from the District. Sources operating by a filing

and not a permit are not required to install Best Available Control Technology (BACT). Deepfat fryers and griddles, due to their negligible emissions, are also exempt from permit and they are

additionally exempted from filing requirements. These equipment may, however, share a hood

which is venting a charbroiler and if control equipment is installed the emissions from all

commonly vented equipment would be reduced.

Charbroilers, although exempted from permit and thus BACT, must comply with Rules 401 –

Visible Emission and 401 – Nuisance. In September 1998, Rule 401 was amended to allow

commercial charbroilers to comply with the state standard of Ringleman 2 (40%) opacity reading

for a period not to exceed three years (September 2001), instead of the more stringent Ringleman

1 (20%) standard applied to most equipment operating in the Basin. This provision was made in

recognition of the unavailability of cost-effective control technology for under-fired charbroilers.

Commercial restaurant establishments must also comply with the state requirements, which

usually follow the standards set forth by the Building Officials, and Code Administration's Basic

Mechanical Code and the National Fire Protection Agency's National Fire Codes as well as

Health Department standards. These codes require restaurant facilities to operate and maintain

sufficient grease removal devices and exhaust and ventilation systems. Such devices reduce

grease particulate emissions but are not considered air pollution controls by the District.

November 14, 1997, the District adopted Rule 1138 – Control of Emissions from Restaurant

Operations. Specifically, this rule applies to commercial cooking operations using chain-driven

charbroilers. Sources were given until November 14, 1999, to install a flameless catalytic

oxidizer control device, or something equivalent in obtaining emission reductions. The catalyst

was cost-effective (calculated at $1680/ton) and reduced PM and VOC emissions by

approximately 83%. The rule, at full implementation, was estimated to reduce emissions from

this portion of the restaurant source category by 0.5 tons/day of PM and 0.2 tons/day of VOC

emissions.

PROPOSED METHOD OF CONTROL

Testing is currently underway to identify an effective control technology for under-fired

charbroilers, which contribute approximately 85% of the total PM emissions inventory and 72%

of the total VOC emissions inventory from this sector. Recent testing of potential control
Appendix B: New and Revised Stationary Source Control Measures CM #99PRC-03(P2)

B - 68

technologies and one redesign piece of basic equipment gave results ranging from a 22% to a

71% reduction of VOCs and 40% to 75% reduction of PM emissions. Staff anticipates further

development of prototypes and testing will result in emission reductions ranging from 70% to

85% for PM and 25% to 70% of VOCs. The SmoklessTM broiler testing gave emission

reductions of approximately 71% for VOCs and 75% for PM emissions. The SmoklessTM broiler

is not a charbroiler but is designed to approximate the characteristics obtained by cooking on a

charbroiler. The design prevents grease from the broiling food from dripping onto the hot burner

components or radiants, thus resulting in the reduction in the formation of PM and VOC

emissions.

Other technologies being tested include a water-wash/filter system, which currently does little to

reduce VOC emissions and a ceramic microwave technology. Future development of these

technologies or others may yield as high as 90 percent reduction in PM and VOC emissions.

Presently available catalysts require high temperatures to remove PM and VOC efficiently.

Under-fired charbroilers, due their disperse surface area, do not create a high enough

temperature to effectively operate a catalyst. However, manufacturers of these catalysts expect

that further development may yield greater than 70% reduction in both VOC and PM emissions.

Systems considered but not practical at this time for reasons varying from safety to cost, include

electrostatic precipitators, carbon adsorption filter systems, afterburners, and catalyst.

EMISSION REDUCTIONS

The projected VOC and PM inventories for 1997, 2006, and 2010 are provided in the Control

Measure Summary. Although the add-on exhaust control technology proposed above is

estimated to be from 20 to 75% efficient in reducing VOC and PM emissions, not all restaurants

will be subject to the proposed rule (i.e., the restaurants without charbroilers). The target

emission controls are based on control equipment yielding a 70% reduction from the under-fired

charbroiler in both VOC and PM emissions, resulting in an overall reduction of the total

inventory of approximately 50% for VOC and 60% for PM. The estimated emission reductions

anticipated from implementation of this measure are identified for 2006 and 2010 based on the

annual average inventory for VOC and PM and the summer planning inventory for VOC.

Emissions data will be updated, as additional data becomes available.

RULE COMPLIANCE

It is proposed that facilities subject to any future rules arising from implementation of this control

measure, maintain records at the restaurant regarding equipment operations and maintenance.

Implementation of an outreach program would improve compliance.

TEST METHODS

In conjunction with the rule development process for Rule 1138 and associated source testing,

the document "Protocol – Determination of Particulate and Volatile Organic Compound

Emissions from Restaurant Operation" was published November 14, 1997. A Flame Ionization

Detector (FID) is used to continuously determine the VOC concentration in the sample gas

stream. The test method for particulate matter is identified as SCAQMD Method 5.1. These test

methods are currently being used for testing of charbroilers and potential control devices.
Appendix B: New and Revised Stationary Source Control Measures CM #99PRC-03(P2)

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COST-EFFECTIVENESS

The cost-effectiveness calculation for PRC-03 ranges from approximately $2,800 to $9,300. The

cost-effectiveness range is based on a structurally different broiler type, a prototype add-on

control, and a projected add-on control with no definitive capital cost, operating cost or emission

reduction potential. The lower value is based, not on a control technology, but on an alternative

basic equipment, referred to as the Smokless broiler. The Smokless broiler is a different

design from an under-fired charbroiler. The upper end of the cost range is based on a control

equipment currently under development which does not now reduce VOC emissions and the final

cost and operating expenses are unknown. An estimated capital cost, as suggested by the

developer, was used. An additional calculation was made for a projected add-on control

assuming a reduction in both PM and VOC emissions and estimating a capital cost.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to regulate VOC and PM emissions generated from restaurant

operations. Implementation of this control measure would begin in 2001 with full

implementation by the end of 2003 with 0.7 tons/day of VOC emission reductions.

REFERENCES

Final report by Pacific Environmental Services, Inc., A Detailed Survey of Restaurant Operations

in the South Coast Air Basin; Contract No. 98089; February 1999.

Final report by University of California Riverside, College of Engineering, Center for

Environmental Research and Technology, Efficient and Cost-effective Control Technologies for

Underfired Charbroilers; Contract No. 98015; February 1999.

Final report by University of California Riverside, College of Engineering, Center for

Environmental Research and Technology, Further Development of Emissions Test Methods and

Development of Emission Factors for Various Commercial Cooking Operations, Contract No.

96027, July 1997.

South Coast Air Quality Management District. Protocol – Determination of Particulate and

Volatile Organic Compound Emissions from Restaurant Operations. November 14, 1997.

South Coast Air Quality Management District. Staff report for Proposed Rule 1138 – Control of

Emissions from Restaurant Operations; October 10, 1997

Walden Research Corporation. Background Information for Establishment of National

Standards of Performance for New Sources – Deep Fat Frying. Prepared for the Office of Air

Programs of the U.S. EPA. October 1971.
Appendix B: New and Revised Stationary Source Control Measure CM#99WST-01

B - 70

EMISSION REDUCTIONS FROM LIVESTOCK WASTE

[VOC, NH3]

THE DESCRIPTION PROVIDED IN APPENDIX IV-A OF THE 1997 AQMP

IS STILL APPLICABLE AND IS REPRINTED BELOW WITH MINOR

CLARIFICATIONS.

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: LIVESTOCK WASTE

CONTROL METHODS: REDUCTION OF DUST EMISSIONS FROM UNPAVED FACILITY

ROADS AND FEED PREPARATION ACTIVITIES. REDUCTION OF

AMMONIA AND VOC EMISSIONS CREDITED FOR OUT-OFBASIN RELOCATION AND OTHER CONTROLS AS NEEDED,

SUCH AS LOW-NITROGEN FEEDS, PROMOTION OF AEROBIC

CONDITIONS, INCLUDING USE OF ENZYMATIC AND

MICROBIAL PRODUCTS, IMPROVED HOUSEKEEPING

PROCEDURES, AND REMOVAL TO COMPOSTING FACILITIES

OR OTHER APPROVED METHODS

EMISSIONS:

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 12.2 11.1 11.1

VOC REDUCTION 3.3 3.3

VOC REMAINING 7.8 7.8

NH3 INVENTORY* 8.6 8.6 8.6

NH3 REDUCTION 4.3 4.3

NH3 REMAINING 4.3 4.3

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 12.1 11.1 11.1

VOC REDUCTION 3.3 3.3

VOC REMAINING 7.8 7.8

CONTROL COST: THE COST-EFFECTIVENESS OF THIS CONTROL MEASURE IS

NOT DETERMINED

IMPLEMENTING AGENCY: SCAQMD WITH THE COOPERATION OF WATER AND

LOCAL AGENCIES

* Dairy emissions only. Total Basin livestock ammonia emissions are 56.5 tons/day.
Appendix B: New and Revised Stationary Source Control Measure CM#99WST-01

B - 71

DESCRIPTION OF SOURCE CATEGORY

Background

Livestock waste emissions are precursors to both ozone and particulate matter (PM10). VOCs

contribute to ozone; dust from corrals and roads yield primary PM10 emissions; and ammonia is a

precursor of secondary PM10. High levels of ammonium nitrate particulates are seen at

monitoring stations downwind of the Chino/Ontario area with its dense concentration of dairy

operations, including the San Bernardino Agricultural Preserve area; these stations typically

record the highest levels of PM10 in the Basin.

With increasing urbanization, dairy and other livestock operations in Los Angeles and Orange

counties relocated eastward, including the Agricultural Preserve. This 15,000 acre area in

southwestern San Bernardino and Riverside county contains approximately 250 dairies with over

300,000 cows, resulting in one of the densest dairy cow populations in the country. The resulting

manure (feces and urine) from these dense herds of cows produces large amounts of ammonia in

a relatively small area. This ammonia is a key contributor to ammonium nitrate; a preliminary

modeling study indicated that ammonia reductions in the Agricultural Preserve area can lead to

significant decreases of ammonium nitrate in peak PM10 areas (SCAQMD, 1993). (Other

contributors to PM10 are NOx and SOx emissions from mobile and stationary sources.) Other

livestock facilities are found to a much lesser extent in the Agricultural Preserve. It should be

noted that livestock facilities are also present in other areas of the South Coast Air Basin,

generally toward its eastern end.

The high concentration of animals per acre of land results in a larger volume of manure stored in

corrals, stockpiles and to a much smaller extent, holding ponds. This high density of livestock, as

well as the location of dairies, limits manure disposal options. Few dairies have pastures on

which to spread the manure, and there are only a few local composters that use the manure.

Large quantities of manure are trucked to out of Basin areas, such as the Imperial County or San

Joaquin Valley, for processing for fertilizer; however, demand for the manure varies from year to

year. Stockpiles of manure may be stored for as long as one year before they are hauled away

(Koopman, 1992). This results in the storage of manure under anaerobic conditions and the

generation of by-product gases. Direct emissions of PM10 arise from wind entrainment from

corral areas and stockpiles, wind entrainment of materials during feed preparation, and road dust

from paved and unpaved roads on the livestock facilities.

Recent Scientific Studies of Livestock Emissions

In response to concerns of the local dairy industry that previous dairy waste emission estimates

(Radian, 1991) were not based on unique local conditions, the District initiated a $130,000 study

of these emissions (SCAQMD, 1996). The results of this study indicated that the ammonia

emission factor (ammonia per cow per year) is approximately 70% less than previous estimates.

The results of this study and a previous study at Northern California dairies, indicate that the

VOC emission factor is also less than previous estimates. The latest estimates indicate that dairy

emissions are approximately 9 tons per day of ammonia, 9 tons per day of PM10, and 6 tons per
Appendix B: New and Revised Stationary Source Control Measure CM#99WST-01

B - 72

day of VOC emissions in the 1993 base year in the Basin, predominately concentrated in the

Chino area. Total 1993 livestock waste emissions over the whole Basin have been estimated at

approximately 56 tons per day of ammonia, 9 tons per day of PM10, and 12 tons per day of

VOC.

Status of the Agricultural Preserve and the Local Dairy Industry

The land occupied by dairies and other livestock facilities in the Agricultural Preserve cannot

currently be sold for non-agricultural purposes, placing a serious restriction on facilities that may

prefer to relocate for other reasons. This is also true for facilities under contract with the State

based on the 1965 Williamson Act. An informal 1987 survey by the California Milk Producers,

which represents approximately two-thirds of the dairy industry in the Basin, indicates that

approximately 65% of the dairy farmers would relocate if not restricted by Agricultural Preserve

and/or Williamson Act requirements. Future legislation changes and possible incorporation of

the Agricultural Preserve into existing cities, may allow those farmers who wish to relocate to do

so.

The agricultural preserve status will end in 1997. The Local Agency Formation Commission has

granted the City of Ontario annexation rights to 8,200 acres and the City of Chino rights to 7,200

acres. Chino has already conducted environmental studies of 1800 acres and a draft

Environmental Impact Report (EIR) should be completed in late 1996. Only 885 of the 1800

acres are suitable for possible development. The rest of the 5,400 acres will be studied in 1997.

The City of Ontario has appointed a committee to determine types of land uses that might replace

the dairies, including residential, commercial, and light industrial development. It must develop

an EIR and hold public workshops before development can occur. It should be noted that flood

control structures installed by developers and urban communities stop at their boundaries,

dumping water directly onto agricultural land areas that do not have improved channels. The

funding and building of flood control infrastructure in the agricultural land will affect the ability

of dairies to relocate, if they wish.

Regulatory History

The District previously has not controlled emissions from livestock operations. The livestock

industry is regulated by federal and state agencies responsible for food safety, as well as water

quality agencies. Superseding regulations by these agencies may limit the types of air emission

control methods that can be used.

PROPOSED METHOD OF CONTROL

Primary PM10:

The PM10 portion of this control measure provided in the 1997 AQMP was implemented with

the adoption of Rule 1186 in February 1997.

Ammonia:

The proposed methods of control are primarily oriented toward reducing emissions of ammonia.

As discussed previously, dairies may be moving from the Basin, and the Agricultural Preserve in
Appendix B: New and Revised Stationary Source Control Measure CM#99WST-01

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particular, due to land use and economic reasons. The control strategy is based on emission

reductions from both relocation and actual control measures. The implementation of various

control methods for dairy operations will follow a two-phase approach:

(1) The 1997 AQMP/PM10 SIP establishes a “carrying” capacity for ammonia emissions,

particularly for livestock emissions. This “carrying” capacity is set to ensure

attainment of the PM10 standards, as determined by the attainment demonstration.

Emission reductions from livestock relocation outside of the Basin will be counted

toward the 50% emission reduction requirement from the 1993 baseline for the

livestock industry. In particular, if sufficient relocation of dairy cows and other

livestock occurs or is committed to occur by January 1, 2004, no further ammonia

controls will be required for the remaining livestock facilities.

(2) If the January 1, 2004 targets are not met, remaining dairy and other livestock facilities

will be subject to ammonia controls. The level of control will be set by the emission

reductions still required to meet the 50% reduction from the 1993 baseline emissions,

after crediting emission reductions due to relocation. Control measures to reduce

ammonia emissions are described below, along with current estimates of their control

efficiency and costs. Dairies and other livestock facilities will be able to choose the

control method(s) based on their own technical and economic considerations, as long

as the required emission reductions are met.

Possible Ammonia Control Methods for Livestock Waste

Ammonia, VOC, and methane emissions are difficult to control in part because the manure

cannot always be economically and quickly removed from facilities and treated. Storage in

corrals and stockpiles is generally under conditions that allow for some anaerobic decomposition.

To reduce emissions of ammonia (and possible VOCs), a number of control methods could be

used. One possibility is altering the livestock feed to reduce the nitrogen content in the resulting

manure (feces and urine). A second possibility is that manure can be removed from the facility in

a timely fashion or stored under conditions that produce less ammonia. Additionally, the farmer

can promote aerobic rather than anaerobic conditions in the animal feed yard floors, corrals, and

manure stockpiles. This can be done by applying enzymatic and/or microbial solutions to the

manure, or keeping the pH of the manure basic (above neutral). In the next sections, each

control method is considered in greater detail.

The District recognizes that additional study will be needed to quantify each of the control

methods and adequately identify the related issues and impacts. As with the livestock waste

emissions study, District staff will seek the cooperation of the livestock industries, the University

of California Cooperative Extension, related regulatory agencies, academia, and others to study

these and other control methods. Some of the control methods were originally proposed for

VOC control and may have to be revised or dropped based on their ammonia emission reduction

potential. The District also recognizes that CDFA and FDA approval may be necessary for some

of the control methods, and will work with the livestock industry to ensure that cross-regulatory

concerns are addressed.
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Nutrition strategies: Lower nitrogen content feeds

Adjusting livestock feed composition to increase nitrogen retention and/or reduce excreted

nitrogen could be the most sustainable method of reducing ammonia, as well as other forms of

nitrogen pollution (UN-ECE, 1996). Feeding strategies may reduce nitrogen intake, resulting in

a reduction of ammonia emissions. For dairy cattle, the greatest effect would be on urea/uric

acid content. Nutrition strategies may be especially effective, since ammonia from urine quickly

volatizes and is less amenable to other methods of control. For poultry, nutrition strategies can

also reduce emissions by increasing the dry matter content of manure, in addition to altering the

urea/uric acid content. Although nutrition strategies are promising, as noted above, additional

studies on live animals will be necessary to quantify emission reductions and assess the impacts

on milk production, animal health, etc.

Reduce amount of moistened manure

The 1995 SCAQMD dairy study measured emissions at all major dairy operational areas. The

results of this study indicated higher emissions where the manure had been wet, including feed

lanes and water trough areas. Cows spend an appreciable time at the feed lanes, and the manure

there is wetter than most corral areas, mainly due to urine. The proposed control could be the

regular scrapping of feed lane manure to stockpiles (the stockpiling of feed lane manure would

reduce the overall surface area of wet manure and the resulting emissions). Leaks from water

troughs can moisten the surrounding areas. The proposed control could include the repair of all

leaking water troughs and connecting pipes.

Composting and/or removal of manure to composting facilities

Aerobic composting offers the opportunity to stabilize the waste and reuse a portion of the

organic and nutrient fraction of the waste for fertilizer. Since it is primarily an aerobic

microbiological process, ammonia, VOC and methane emissions are reduced. In order to gain

substantial emission reductions, composting should be conducted shortly after the livestock

waste is generated to avoid on-site anaerobic storage. Though most dairy farmers compost a

portion of livestock waste, they frequently store the manure for a period of time before shipping

it to compost facilities, in part, because of a relatively low demand for manure by local

composters. A large composting facility is currently operated by the Chino Metropolitan Water

District for composting livestock waste generated in the Dairy Preserve. This facility processes

on average 700 tons per day of manure.

Enhanced biodegradation: application of microbial and/or enzymatic products

Ammonia levels in livestock waste can be reduced by converting it to nitrate, which also

improves its fertilizer value. This conversion of ammonia to nitrate can be accelerated by the

action of bacteria and/or enzymes. Several companies produce a variety of microbial and/or

enzymatic products that can be applied to solid or liquefied waste. Different cultures and

formulations are available for different applications (stockpile, corral, pond, etc.) These products

are typically rehydrated and sprayed on the waste. Several products have been tested and

approved for use with livestock animals, and are not harmful plants, birds, animals, or humans.

Additional studies will be necessary to quantify emission reductions, and these products may

require approval from food and/or water quality agencies.
Appendix B: New and Revised Stationary Source Control Measure CM#99WST-01

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Optimal pH levels for stockpiled manure: chemical oxidizers

Ammonia emissions can be reduced by maintaining the pH of the manure above neutral, and

allowing it to be stored under aerobic conditions. Chemicals can be spread on some manure

storage areas, such as feedlots and holding ponds to help oxidize the waste matter or increase its

pH. An oxidizing agent can be spread on feedlots in quantities and frequencies to maintain an

increased oxidized condition. Additional studies will be necessary to quantify emission

reductions, and these products may require approval from food and/or water quality agencies.

Better aeration of manure stockpiles with more frequent clearing of corrals

Other measures include physically aerating manure storage piles by turning them every 3 to 7

days and by scraping feedlots at least 3 times per year to reduce anaerobic conditions associated

with manure buildup.

Other control methods

As other methods are identified and shown to be effective in reducing ammonia emissions, such

methods can be added to the menu of control options.

Volatile Organic Compounds (VOCs):

Recent studies [EPA(1995) and SCAQMD(1995)] indicate that emissions of VOCs from

livestock wastes are much less than previously estimated. Because of this, no control methods

are particularly recommended for VOC emission reduction. However, controls on ammonia

emissions may result in concomitant VOC reductions.

EMISSIONS REDUCTION

The 1993 base year emissions and projected future year emissions in 2006 and 2001 for

ammonia, VOC and PM10 are provided in the Control Measure Summary. The estimated

emission reductions anticipated from implementation of this measure are identified for 2006 and

2010 based on the annual average inventory for VOC, NH3, and PM10 and the summer planning

inventory for VOC. Overall emission reductions for VOC and PM10 are estimated to be 30 and

47 percent, respectively. Ammonia emission reductions from dairy operations, either through

relocation or control, are estimated to be 50 percent.

RULE COMPLIANCE

Compliance with this control measure can be monitored through recordkeeping and inspections.

For fugitive dust, owners of livestock facilities could provide a survey of paved and unpaved

roads at the facility. Owners of dairy facilities could post hay grinding restrictions where

employees will be aware of them. For ammonia, the District could monitor the overall level of

relocation of dairies from the western portions of San Bernardino and Riverside counties and

determine the resulting ammonia emission reductions. If further controls on the dairies are

warranted, dairies could provide the District with the following information, depending on the

control option they are using: proof of the use of alternate feeds to reduce emissions; repair

records for leaking water troughs and piping; the date of manure removal from feed lanes,
Appendix B: New and Revised Stationary Source Control Measure CM#99WST-01

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corrals or dairy stockpiles along with certification by the person performing the activity; acreage

of the corrals and stockpile areas, and the type and quantity of ammonia inhibitor used (if any).

Poultry farm operators could periodically submit to the District the following information: the

maximum number of poultry managed during the preceding six months; and the type and quantity

of ammonia emission inhibitor used.

COST EFFECTIVENESS

The cost effectiveness of implementing this control measure for ammonia cannot be determined,

since the degree of future dairy relocation is currently unknown.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to implement this measure. However, the alternative uses and

disposal methods for livestock waste described in this measure have been investigated by the

Santa Ana Regional Water Quality Control Board and other local agencies. These agencies have

adopted and implemented an extensive regulatory program to mitigate and control the impacts of

wastes and their composting. Any further regulation to control these wastes for purposes of

mitigating air emissions should be pursued in cooperation with these agencies. This control

measure will be fully implemented by the end of 2004 with 3.3 tons/day of VOC emission

reductions.

OTHER IMPACTS

The alternative uses and disposal methods proposed herein may mitigate some water quality

impacts in the Santa Ana Watershed Basin.

REFERENCES

Earsom, James. Chino Basin Work With Dairies. Soil and Water Conservation Society and

Southern California Coalition of Resource Conservation Districts’ Regional Workshop.

September 1996.

Environmental Protection Agency. Results of the Measurement of Volatile Organic Compounds

(VOCs) from Livestock Waste. January 1995.

Radian, R.J. Dikson. Development of the Ammonia Emission Inventory for the Southern

California Air Quality Study. September 1991.

South Coast Air Quality Management District. Projected Air Quality as a Result of Reducing

Emissions from the Livestock Industry in the South Coast Air Basin. June 1993.

South Coast Air Quality Management District. Results of the Measurement of PM10 Precursor

Compounds from Dairy Industry Livestock Waste. June 1996.
Appendix B: New and Revised Stationary Source Control Measure CM#99WST-01

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United Nations, Economic Commission for Europe, Convention on Long-Range Transboundary

Air Pollution, Working Group on Technology. Report on Abatement Techniques to Reduce

Ammonia Emissions from Agricultural Livestock. January 1996.
Appendix B: New and Revised Stationary Source Control Measures CM #99WST-02

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EMISSION REDUCTIONS FROM COMPOSTING

[VOC, NH3, PM10]

THE DESCRIPTION PROVIDED IN APPENDIX IV-A OF THE 1997 AQMP

IS STILL APPLICABLE AND IS REPRINTED BELOW WITH MINOR

CLARIFICATIONS.

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: COMPOSTING FACILITIES

CONTROL METHODS: REQUIRING ALTERNATIVE COMPOSTING METHODS,

REQUIRING EMISSION CONTROL EQUIPMENT

EMISSIONS (TONS/DAY): NOT DETERMINED

CONTROL COST: THE COST EFFECTIVENESS OF THIS CONTROL

MEASURE IS NOT DETERMINED

IMPLEMENTING AGENCY: SCAQMD, LOCAL GOVERNMENTS

DESCRIPTION OF SOURCE CATEGORY

Background

Composting is the biological decomposition and stabilization of organic substrates; composted

material is often a waste product of other processes. The final composted product is stable, free

of pathogens and can be used as a soil amendment and fertilizer. The bacterial breakdown of

substrates also produces various organic and inorganic gases that can contribute to several

different air pollution problems. Source testing conducted by the District in 1994 and early 1995

indicated that outdoor windrow composting of dewatered sewage sludge releases significant

levels of ammonia, methane and VOCs (SCAQMD, 1995). Of these compounds, ammonia

emission rates are highest. Ammonia is of concern because once airborne, it reacts with

atmospheric nitric acid to form particulate nitrate. Particulate nitrates make up a substantial

portion of PM10 and are estimated to be responsible for 40 percent of the visibility reduction in

the eastern part of the Basin. Organic and inorganic amines and sulfides are emitted at lower

rates and contribute very little to photochemical smog. However, they are largely responsible for

odor problems experienced by areas surrounding this type of compost facility.

The composting industry is expected to expand, in large part because of the enactment of state

legislation (AB939) to reduce landfill disposal of solid wastes, and because other disposal options

are limited. Organic waste most commonly used for composting includes biosolids (dewatered

sewage sludge from waste water treatment plants), green (yard trimming) waste, and manures.

Currently, there are approximately six facilities composting biosolids in the District. These

facilities compost biosolids with green waste, dairy manure, paper sludge, sawdust, horse

bedding, and other animal manures. Approximately six more green waste composting and
Appendix B: New and Revised Stationary Source Control Measures CM #99WST-02

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several other composting facilities are being proposed or are under construction. The majority of

waste (approximately 500,000 tons per year) being composted is dewatered sewage sludge.

Composting processes can be categorized as “agitated static pile (or windrow),” “aerated static

pile (or windrow),” or “in-vessel” systems. The latter systems combines both agitated and

aerated windrows within a enclosed facility, allowing for the capture of emissions for odor

control and destruction. Most composting operations in the Basin use outdoor windrows that

are agitated by a front-end loader or an engine-powered hydraulic windrow turning machine

known as a “Scarab.” Open-air windrows do not use emission collection systems and can

generate significant emissions, particularly when the piles are not turned or properly maintained.

Regulatory History

Composting operators are required to meet the requirements of District Rule 401 - Visible

Emissions, Rule 402 - Nuisance, and Rule 403 - Fugitive Dust. Operators may also have

equipment requiring permits under Rule 203 - Permit to Operate. The California Integrated

Waste Management Board (CIWMB) is responsible for implementing federal regulations, which

establish standards for the use and disposal of sewage sludge. Operators of composting facilities

are required to obtain a “Solid Waste Facilities Permit,” which is usually issued through county

environmental health departments.

PROPOSED METHOD OF CONTROL

As noted in the 1994 AQMP, this control measure will be implemented in two steps. During

Step I, the District is conducting additional studies to quantify emissions from composting

activities in the Basin. In addition during this first step, the District will work with industry

representatives to gather additional information regarding the appropriate emissions sampling

time to ensure quantification techniques accurately reflect emissions from this source category.

An ammonia inventory for composting operations will be developed based on current activity

levels and the emission factors derived from the PTEP and other related studies. Step I will be

completed in 2000. If emissions from this source category are significant, Step II will be

conducted. Step II will include identification of control options to reduce emissions from

composting activities that are cost effective and technically feasible.

Step I:

In late 1995 and early 1996, the District conducted a series of studies at local composting

facilities as part of its PM10 Technical Enhancement Program (PTEP). As called for in the 1994

AQMP, sampling protocols were developed based on these efforts (SCAQMD, 1996). The first

site studied composts a 50:50 mixture of dewatered sewage sludge and wood chips. This facility

is different from most current facilities in that all active composting occurs in a large building that

collects all emissions and vents them to a biofilter for odor and emissions control. The piles are

actively ventilated using forced air through the bottom of the pile, aerating the pile and

promoting aerobic activity. Emissions were measured both with an EPA-approved isolation flux

chamber, which is commonly used for such area sources, and by more traditional stack-type

measurement at the exhaust ducting to the biofilter.
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The second site was a more traditional open-air windrow facility that composts a 4:1 mixture of

cow manure and dewatered sewage sludge. The isolation flux chamber was used to take a series

of measurements of the windrows and stockpiles at different stages of the composting process.

The third and last site was also an open-air windrow facility, but composts a 50:50 mixture of

urban green waste and dewatered sewage sludge. Testing at all sites has been completed and a

summary report of emissions from various types of composting operations is being prepared.

Upon completion of the PTEP studies and the summary report, the District will develop an

emissions inventory for composting operations. An initial study to estimate ammonia emissions

for composting operations is being conducted as part of the overall ammonia emission inventory

revision. The study will be completed by the end of 1999.

Step II:

If necessary based on the results of Step I, Step II will include identification of control options to

reduce emissions from composting activities that are cost effective and technically feasible. The

following provides a brief discussion regarding possible control options for composting systems

that are currently used by facilities in the Basin. During Step II, additional methods of control

may be identified.

Two in-vessel composting systems are currently being operated in the District. Both use control

equipment for ammonia, odors, and VOCs. There are currently many types of enclosed

composting systems used throughout the country, and innovative designs continue to evolve.

Enclosed composting systems are effective in reducing ammonia and VOC emissions from

composting activities.

Most of the composting facilities in the District use outdoor windrow composting methods.

Operators of outdoor windrows may be required to phase-in alternative composting methods to

control emissions. Open windrow emissions can be controlled by operating and managing the

composition and construction according to the best known practices. This means that the piles

must be constructed using the proper C:N ratio, particle size/density, moisture, pH, and

temperature control. Also, an outdoor windrow operation may be modified to use “aerated static

pile windrows.” Such systems use perforated piping to draw air through the pile at negative

pressure, and emissions can then be routed to a biofilter or other control equipment. Other

options include constructing an in-vessel system or a structure to enclose the windrows in order

to collect and control emissions.

In accordance with its goals of increased regulatory flexibility and the use of market-based

forces, the District will consider incentives for the use of lower-emission operations by sources of

manure and/or green waste. This may be coupled with maximum credit for prompt removal of

dairy waste (WST-01, “Emission Reductions from Livestock Waste.”) to foster lower emission

composting operations.

If Step II is necessary, adoption of composting operation rules would occur would begin in 2001,

with implementation to begin by 2004.
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EMISSIONS REDUCTION

Implementation of this control measure is expected to result in emission reductions. During Step

II, the District will continue to work with affected industries to refine emission estimates from

this source category and emission reduction estimates from the proposed control options. If

emissions are significant, cost effective, technically feasible control options will be identified in

the future to reduce emissions from composting activities.

RULE COMPLIANCE

Compost operators would be required to meet minimum emission reductions for given compost

operations. Emission reduction data for various types of systems in many cases will be generated

during development and implementation of this control measure, since emission testing to date is

limited. Recordkeeping would be required to ensure proper maintenance of the composting

systems.

TEST METHODS

Source testing methods will be determined on a case-by-case basis for various composting

equipment. Laboratory methods to be used include District Methods for VOC and EPA Method

17/350.2 for free ammonia.

COST EFFECTIVENESS

The cost effectiveness of this control measure has not yet been determined. The District will

continue to analyze the potential cost impact associated with implementing this control measure

and will provide cost effectiveness information as it becomes available.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to implement this control measure, and would work in cooperation

with local governments that issue solid waste facility permits. This control measure would be

implemented beginning in 2004 with full implementation by the end of 2006. The VOC emission

reductions have not been determined at this time.

REFERENCES

Los Angeles County Sanitation District. Correspondence to the South Coast Air Quality

Management District. July 5, 1994.

South Coast Air Quality Management District. “Emission Rate Characterization of Open

Windrow Sludge Composting Operations.” October 1995.

South Coast Air Quality Management District. “Characterization of Ammonia, Total Amine,

Organic Sulfur Compounds, and Total Non-Methane Organic Compounds (TGNMOC)

Emissions from Composting Operations. January 1996.
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EMISSION REDUCTIONS FROM WASTE BURNING

[VOC]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: WASTE BURNING

CONTROL METHODS: RESTRICT BURNING WHEN THE STATE STANDARD IS

PREDICTED TO BE EXCEEDED

EMISSIONS (TONS/DAY): ALTHOUGH IMPLEMENTATION OF THIS MEASURE IS NOT

EXPECTED TO PRODUCE A NET ANNUAL OR SEASONAL

EMISSION REDUCTION, AN AIR QUALITY BENEFIT IS

EXPECTED ON DAYS WHEN AN OZONE EXCEEDANCE IS

PREDICTED.

CONTROL COST: THE COST-EFFECTIVENESS OF THIS CONTROL MEASURE IS

NOT DETERMINED.

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

Background

Waste burning activities are defined as agricultural burning, range management burning, forest

management burning, and open burning. Most waste burning activities are currently restricted by

a permissive burn/no-burn day program as specified in the California Health and Safety Code.

This program allows the local air districts to declare a permissive burn day or a no-burn day,

requires parties to obtain a burn permit from the local designated county or state agency, and

limits burning to permissive burn days. Waste burning is restricted to days with acceptable air

quality based largely on current and forecasted visibility and particulate levels.

Regulatory History

The District currently regulates open burning under Rule 444 - Open Fires. The rule, adopted on

October 8, 1976, and last amended on October 2, 1987 prohibits open burning on a no-burn day

without a written permit as required by Rule 208 - Permit for Open Burning. Since the rule was

amended, U.S. EPA has released its "Interim Air Quality Policy on Wildland and Prescribed

Fires." This policy, issued in May 1998, set forth requirements that California, and local air

districts develop Smoke Management Plans to minimize impacts to air quality and visibility

reduction due to regional haze originating from burning activities. To date, the ARB is

proposing amendments to Title 17 of the California Code of Regulation - Agricultural Burning

Guidelines. These amendments are expected to be adopted by ARB early in the year 2000. The

revised regulation will be entitled “Smoke Management Program.”

The federal program will not require amendments to Rule 444. However, to implement the

Wildland and Prescribed Fires Policy, EPA recommended that local districts enter into

Memorandum of Understanding (MOU) with the local agencies that manage controlled burn
Appendix B: New and Revised Stationary Source Control Measures CM #99WST-03

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activities. To implement the federal policy, the District has entered into a process to develop a

formal MOU between federal and state land managers to adopt a local Smoke Management Plan

that would meet the criteria specified in EPA’s guidance.

It is anticipated that the MOU process will parallel the state’s Title 17 adoption process. The

final form of Title 17 may require a future amendment to Rule 444.

PROPOSED METHOD OF CONTROL

The proposed measure would complement and expand the current permissive burn/no-burn day

program to incorporate ambient ozone air quality considerations. The purpose of this proposal is

not to ban waste burning but to restrict waste burning to days when ambient ozone

concentrations are within acceptable levels. The proposed amendments to Title 17 have outlined

a policy that allows for flexibility that provides the air quality districts with the option to allow

burning within designated subregions of an air basin if burning would not further impact

subregional air quality. The proposed policy would consider these type of events as "marginal

burn days." On marginal burn days in source receptor areas where the California ambient air

quality standard for ozone (0.09 ppm), all forms of waste burning would be prohibited. All forms

of waste burning will be prohibited on days determined from meteorological dispersion criteria to

be no burn.

In addition, amendments to Rule 444 may be needed to include provisions required by revisions

to Title 17 Smoke Management Program. Amendments will be coordinated with other California

air pollution control districts.

EMISSIONS REDUCTION

This control measure proposes to restrict waste burning activities during days and when in areas

where an exceedance in the state ambient ozone standard are predicted. This control approach

would shift waste burning activities that would occur on ozone exceedance days to only those

days when acceptable ambient ozone concentrations are predicted. Provided acceptable levels of

ozone are predicted, shifting from an exceedance day to a non-exceedance day could occur

irrespective of the summer ozone season. Thus, this control approach would not produce a net

annual or seasonal emission reductions. Implementation of this measure, however, will ensure

that waste burning activities do not worsen ambient air quality when an ozone exceedance day is

predicted.
Appendix B: New and Revised Stationary Source Control Measures CM #99WST-03

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RULE COMPLIANCE

This control measure is expected to amend District Rule 444 to include provisions to restrict

waste burning activities during marginal burn ozone exceedance days in areas not predicted to

exceed the standard. Compliance with this control measure include compliance plans,

recordkeeping, and reporting requirements to ensure compliance.

TEST METHODS

Not applicable.

COST EFFECTIVENESS

The cost effectiveness of this control measure has not yet been determined. The District will

continue to analyze the potential cost impact associated with implementing this control measure

and will provide cost effectiveness information as it becomes available.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to regulate VOC emissions generated during waste burning.

Implementation of this control measure would be by the end of 2002. However, the

implementation schedule may be revised based on the final amendments to Title 17 of the

California Code.

REFERENCES

U.S. EPA (1998), Interim Policy on Wildland and Prescribed Fires, Federal Register, March 29,

1998.

ARB, Proposed Amendments to California Code of Regulations Agricultural Burning Guidelines,

August 1999.
Appendix B: New and Revised Stationary Source Control Measures CM #99WST-04

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EMISSION REDUCTIONS FROM DISPOSAL OF MATERIALS

CONTAINING VOLATILE ORGANIC COMPOUNDS

[VOC]

THE DESCRIPTION PROVIDED IN APPENDIX IV-A OF THE 1997 AQMP

IS STILL APPLICABLE AND REPRINTED WITH BELOW WITH MINOR

CLARIFICATIONS.

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: VOC-CONTAINING WASTE

CONTROL METHODS: STEP I: REFINE EMISSIONS INVENTORY AND ASSESS

CURRENT CONTROL METHODS.

STEP II: IDENTIFICATION AND IMPLEMENTATION OF COST

EFFECTIVE EMISSION CONTROLS SUCH AS, IF APPLICABLE

EMISSIONS (TONS/DAY):

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 2.5 2.2 2.3

VOC REDUCTION 0.7 0.7

VOC REMAINING 1.5 1.6

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 2.5 2.2 2.3

VOC REDUCTION 0.7 0.8

VOC REMAINING 1.5 1.5

CONTROL COST: THE COST-EFFECTIVENESS OF THIS CONTROL MEASURE IS

NOT DETERMINED.

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

Background

This source category includes publicly or privately owned and/or operated facilities dedicated to

the handling, treatment, storage and disposal of VOC-containing wastes. In general, these types

of facilities may include landfills, hazardous waste treatment and storage facilities, and any other

entity where the main business function is to handle, treat, transfer, recover, store, or dispose of

waste materials. VOCs may be released from these facilities during handling, treatment or storage

of VOC-containing wastes.
Appendix B: New and Revised Stationary Source Control Measures CM #99WST-04

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Regulatory History

This control measure is designed to regulate emissions of VOCs primarily from landfills, and

other facilities that handle, treat or dispose of VOC-containing wastes.

The District currently regulates these sources under the following source-specific rules:

• Rule 1176 - VOC Emissions from Wastewater Systems, which regulates VOC

emissions from sumps, wastewater separators, process drains, sewer lines and junction

boxes located at oil production fields, refineries, chemical plants, and industrial facilities

handling petroleum liquids.

• Rule 1150.1 - Control of Gaseous Emissions from Municipal Solid Waste Landfills ,

which is to reduce gaseous emissions from active and inactive landfills to prevent public

nuisance and possible detriment to public health caused by exposure to such emissions.

PROPOSED METHOD OF CONTROL

This control measure will be implemented in a two-step process. During the first step, the

District will work with affected facilities to refine the emissions inventory and assess the existing

regulatory structure and control methods for the source category. Step II will include

identification and implementation of cost effective, technologically feasible control methods that

could include, but are not limited to installing new control equipment and/or increasing the

control efficiency of existing equipment, process modifications or substitutions, or reducing

operating schedules. The District will work with affected facilities and other interested parties in

the development and implementation of Step II.

EMISSIONS REDUCTION

The projected VOC inventories for 1993, 2006, and 2010 are provided in the Control Measure

Summary. The estimated VOC emission reductions anticipated from implementation of this

measure are identified for 2006 and 2010 based on the annual average and summer planning

inventories. Emission reductions are based on an estimated overall VOC emission reduction of

33 percent in 2010. During the development and implementation of Step I and II of this control

measure, the anticipated emission reductions may be revised.

RULE COMPLIANCE

Compliance would be similar to the existing rule compliance requirements, as applicable, under

Rules 1150.1 and 1176.

TEST METHODS

Test Methods specified for Rules 1150.1 and 1176 are also applicable to this control measure.
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COST EFFECTIVENESS

The cost effectiveness of this control measure has not yet been determined. The District will

continue to analyze the potential cost impact associated with implementing this control measure

and will provide cost effectiveness information as it becomes available.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to regulate VOC emissions generated during disposal of materials

containing VOCs. Implementation of this control measure would be in 2002 with 0.7 tons/day of

VOC emission reductions.
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EMISSION CHARGES OF $5,000 PER TON OF VOC FOR STATIONARY

SOURCES EMITTING OVER 10 TONS PER YEAR

[VOC]

THE DESCRIPTION PROVIDED IN APPENDIX IV-A OF THE 1997 AQMP

IS STILL APPLICABLE AND IS REPRINTED BELOW WITH MINOR

CLARIFICATIONS.

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: STATIONARY SOURCES OF VOC EMITTING OVER 10 TONS PER YEAR

CONTROL METHODS: EMISSION CHARGES

EMISSIONS (TONS/DAY): NOT DETERMINED

CONTROL COST: NOT DETERMINED

IMPLEMENTING AGENCY: SCAQMD, POSSIBLY REQUIRING ADDITIONAL LEGISLATION

DESCRIPTION OF SOURCE CATEGORY

Background

District records indicate that there are approximately 600 facilities with VOC emissions greater

than or equal to ten tons per year in the Basin. Although these facilities represent approximately

ten percent of the total number of VOC-emitting facilities, these larger VOC facilities represent

approximately 80 percent of the total VOC emissions from stationary sources in the Basin.

These facilities represent a variety of emission sources such as, but not limited to, coatings,

solvents, graphic arts materials, and fugitive emissions from refineries and chemical plants.

The Lewis Presley Air Quality Management Act authorized the South Coast Air Quality

Management District to collect fees based on emissions. Fees collected would be used for

administrative purposes only. Since 1977, the District has collected emission fees from owners

or operators of permitted equipment based on the total annual weight of VOC emissions. This

contingency control measure proposes to impose an emission charge of $5,000 per ton of VOC

for stationary sources emitting over ten tons per year.

Regulatory History

Pursuant to Health and Safety Code Section 40510, the District has the authority to adopt a fee

schedule for the issuance of permits to cover the cost of evaluation, planning, inspection, and

monitoring related to that activity. Under Rule 301 - Permit Fees, the District requires facilities

with permitted equipment to pay an annual emissions fee, in addition to the annual operating

permit fee. The emissions fee is based on the total weight of emissions of each pollutant emitted,

and is assessed on facilities with total annual emissions greater than four tons.
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Pursuant to the June 1996 amendment to Table III - Emission Fees of Rule 301, the current fee

schedule is $271 for each ton of VOC emissions between 4 and 25 tons per year, $440 for each

ton of VOC emissions between 25 and 75 tons per year, and $659 for each ton of VOC

emissions greater than 75 tons per year.

PROPOSED METHOD OF CONTROL

The l990 federal Clean Air Act requires that the AQMP include all control measures, means or

techniques, including economic incentives such as fees, as may be necessary to reach attainment.

Further, the Act requires that all stationary sources of VOC emissions (greater than 10 tons per

year) in an extreme nonattainment area that has failed to attain the ambient air quality standard

for ozone pay a fee as a penalty for such failure (Title I, Section 185).

This control measure proposes that if the federal ambient air standards are not met by the year

2010, an emissions fee of $5,000 for each ton of VOC emissions in excess of ten tons per year

shall be imposed on each facility. The fee shall be paid for each calendar year after the year 2010

and until the area is redesignated as an ozone attainment area. This fee is in addition to the

annual emission fee required by District Rule 301.

EMISSIONS REDUCTION

Implementation of this measure is expected to result in emission reductions as facilities seek to

further reduce emissions to reduce the fees proposed by this measure. Projected emission

reductions are uncertain at this time, and require further analysis.

TEST METHODS

VOC test methods must follow EPA or District approved guidelines or test methods. EPA and

District-approved VOC test methods include the following:

1. EPA Reference Test Method 24 (CFR Title 40, Part 60, Appendix A) - Determination

of Volatile Matter Content, Water Content, Density Volume Solids, and Weight Solids

of Surface Coatings.

2. SCAQMD “Laboratory Methods of Analysis for Enforcement Samples” Manual -

VOC Concentration of Materials, Test Method #304.

Alternative guidelines may be used provided they are first approved by the EPA, ARB, and the

District.

COST EFFECTIVENESS

The cost effectiveness of this control measure has not yet been determined. The District will

continue to analyze the potential cost impact associated with implementing this control measure

and will provide cost effectiveness information as it becomes available.
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IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority under the Lewis Presley Air Quality Management Act to collect

fees based on emissions. However, implementation of this control measure may require

additional legislation. If it is determined that the District lacks authority to implement this

measure and authority cannot be obtained, this control measure will not be implemented. An

implementation schedule cannot be determined at this time.

REFERENCES

South Coast Air Quality Management District. Rule 301 - Permit Fees. Amended June 1993.
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INTERCREDIT TRADING PROGRAM

[ALL POLLUTANTS]

THE DESCRIPTION PROVIDED IN APPENDIX IV-A OF THE 1997 AQMP

IS STILL APPLICABLE AND IS REPRINTED BELOW WITH MINOR

CLARIFICATIONS.

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: ALL SOURCE CATEGORIES

CONTROL METHODS: ALL AVAILABLE CONTROL METHODS

EMISSIONS: IMPLEMENTATION OF THIS CONTROL MEASURE IS

EXPECTED TO PROMOTE AND COMMERCIALIZE

ADVANCED AIR POLLUTION TECHNOLOGIES.

CONTROL COST: THE COST EFFECTIVENESS OF THIS CONTROL

MEASURE IS NOT DETERMINED.

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

This control measure is designed to enhance the District’s existing regulatory programs to

maximize compliance flexibility, minimize compliance costs, and to promote the

commercialization of advanced pollution control technologies. In concept, this control measure

proposes to expand the existing trading market to allow broader trading of mobile and stationary

source emission credits. In addition, other market incentive provisions such as emissions

averaging are also identified. The concepts presented in this control measure provide additional

compliance flexibility and would be integrated into the existing regulatory program, such that the

integrity of each of the individual programs would be maintained.

BACKGROUND

The existing trading market is comprised of five SCAQMD programs that include provisions for

generating and/or using emissions credits. These five include: Regulation XI - Source Specific

Rules; Regulation XIII - New Source Review (NSR); Regulation XVI - Mobile Source Credits;

Regulation XX - NOx and SOx Regional Clean Air Incentives Market (RECLAIM); and Rule

2202 - On-Road Motor Vehicle Mitigation Options.

Each of the five regulatory programs have unique objectives that target a variety of source

categories. NSR (Regulation XIII) and RECLAIM (Regulation XX) are the only programs that

include provisions for both generating and using emission credits. The Mobile Source Credits

program (Regulation XVI) is strictly a credit generating program, and is designed to interface

with most SCAQMD regulatory programs. Regulation XI and Rule 2202 are primarily command

and control regulations that allow sources to use emission credits as an alternative compliance
Appendix B: New and Revised Stationary Source Control Measures CM #99FLX-01

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mechanism. Although Rule 2202 includes credit generating provisions, this program is primarily

a credit using program since Rule 2202 credits can only be used at the generator’s facility.

Since the existing regulatory programs for credit generation and use were developed

independently, these individual programs were not initially designed to fully interact with each

other. Regulation XVI provides the most interaction with the various regulatory programs in

that MSERCs can be used for additional compliance flexibility under Regulation XI source

specific rules, NSR, RECLAIM, and On-Road Mitigation Options (Rule 2202). Although

Regulation XVI interacts with the various regulatory programs, MSERCs do not link the

programs together. Once MSERCs flow into another program, the MSERCs generally cannot be

traded out of that program. However, there are specific provisions that allow MSERCs that are

traded into RECLAIM to be traded amongst facilities within that program. For Regulation XI

and NSR, however, MSERCs can flow into these programs but cannot be traded with another

facility.

REGULATORY HISTORY

Over the past five years the South Coast Air Quality Management District (SCAQMD) has

adopted a series of innovative regulatory programs such as RECLAIM, Mobile Source Credits,

and On-Road Motor Vehicle Mitigation Options. These market-based regulatory programs are

designed to provide compliance options such that the regulated community can select the most

cost-effective control approach for their particular business.

In maintaining its commitment to work with industries, the environmental community, and others

to further identify cost-effective air quality solutions, in April 1995 the District conducted the

Intercredit Trading Study. After a series of public workshops to discuss preliminary policy

concepts, a series of policy recommendations were identified to allow broader trading of mobile

and stationary source emission credits. In March 1996 the District staff presented a white paper

titled, “Intercredit Trading Study - Proposed Recommendations and Action Plan” to its

Governing Board. This paper identified specific enhancements to the existing regulatory

program that would provide additional compliance flexibility while promoting the

commercialization of advanced pollution control technologies. In summary, the Intercredit

Trading Study made the following findings and recommendations:

− Create a universal trading market with minimal restrictions to allow emission credits to flow

between various regulatory programs.

− Allow more sources to generate and use emission credits.

− Develop a uniform trading instrument to simplify credit transactions while maintaining the

integrity of existing credit programs.

− Determine application of uncertainty factors, and apply discount factors when appropriate to

ensure real and quantifiable emission credits.

− Further evaluate the need for an environmental benefit.

− Provide incentives for interseasonal trading.

− Allow banking to incentivize clean technologies and to promote early reductions, while

ensuring such a program incorporates backstop measures to ensure reasonable further

progress and attainment demonstration.
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− Current PM10 interpollutant trading provisions pursuant to NSR should be retained until

information becomes available to support expansion.

In implementing the policies of the Intercredit Trading Study, six additional design principles are

being used to the degree feasible. The six principles are designed to: (1) establish the criteria for

developing an Intercredit Trading Program; (2) recognize the purpose of such a program; (3)

establish the type of backstop measures needed; (4) ensure that regulations encourage the

broadest market while maintaining the integrity of other regulatory requirements; (5) continue to

work with interested parties to resolve key issues such as banking of RTCs, and use of shutdown

credits; and (6) provide routine monitoring and reporting to the Governing Board.

Recent Emissions Trading Laws

In October 1995 three bills were signed into law that would affect the development of emissions

trading programs in the South Coast Air Basin: Assembly Bill 1777, Senate Bill 1098, and

Senate Bill 456.

· AB 1777 - Emission Reduction Credits, requires the ARB to adopt a methodology for

districts to calculate the value of emission reduction credits from stationary, mobile,

indirect, and area sources when used interchangeably. This law allows credits to be

used in a market-based incentive program that would require annual emission

reductions through declining annual allocations, and to meet other stationary or mobile

source requirements that do not prohibit use of credits.

· SB 1098 - Market-Based Incentive Program requires the District to grant emission

reduction credits to sources that are exempt from specified District rules. Unless

otherwise provided by law, emission reduction credits or marketable trading credits

must be issued without discount or reduction in the quantity of the emissions reduced at

the source for any emission reduction activity that occurred after January 1991.

· SB 456 - Air Pollution requires the District to allow the retirement of marketable

emission credits that are permanent, enforceable, quantifiable, and surplus, to be used in

lieu of any requirement for best available retrofit control technology, if the credit also

complies with all district rules and regulations affecting those credits.

Federal Clean Air Act

Since 1970, the federal Clean Air Act has required that states adopt regulations designed to

attain ambient air quality standards. The Act generally has allowed the states to choose the

appropriate type and mix of control strategies used to achieve attainment. In 1977 and 1990

Congress amended the Act to specify certain emission control requirements that each state

regulatory program must impose. Nevertheless, the basic concept that states may choose the

appropriate type and mix of control strategies has been retained as long as the specific control

requirements of the Act are met (Sections 110, 172, and 182). Thus in general, the federal Clean

Air Act does not prohibit the SCAQMD from expanding or linking emissions trading programs.
Appendix B: New and Revised Stationary Source Control Measures CM #99FLX-01

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EPA has promulgated rules for economic incentive programs (EIPs) which either may or must be

adopted by States for certain ozone and carbon monoxide nonattainment areas upon the failure of

States to submit an adequate showing that an applicable reasonable further progress (RFP)

milestone has been met pursuant to CAA Section 182(g)(3) and (5). These rules require that

EIPs be submitted to the EPA for approval as part of the SIP and that they contain provisions to

ensure the following: (1) the program will not interfere with other CAA requirements; (2)

emission reductions credited are quantifiable; (3) creditable emission reductions are consistent

with SIP attainment and RFP demonstrations; (4) reductions are surplus to reductions required

by, and credited to, other SIP provisions in order to avoid double-counting of reductions; (5) the

program is enforceable by State and Federal authorities; and (6) all creditable emission reductions

are permanent. (See 40 Code of Federal Regulation (CFR) Sections 51.490 to 51.494 and 59

Federal Regulation (FR) 16690 et seq., April 7, 1994).

PROPOSED METHOD OF CONTROL

This control measure is intended to be a voluntary program to provide additional compliance

flexibility to regulated sources in the Basin and to incentivize the commercialization of advanced

pollution control technologies. The overall approach for this control measure is based on

providing a series of enhancements to the existing regulatory program. Enhancements can

include incorporating market incentive provisions in amended or adopted rules to developing a

universal trading market. Implementation of these approaches is expected to provide incentives

to overcontrol and to promote the commercialization of technologies that will be needed to meet

the Basin’s attainment goals.

Market Incentive Provisions in Individual Rules

One approach to implementing market incentive approaches is to include emissions averaging

provisions in individual rules. As the District amends and adopts tougher rules and regulations,

emissions averaging provides an additional compliance tool to allow sources to meet compliant

emission limits through an emissions averaging program. In concept, sources that elect to

participate in an emission averaging provision would be allowed to average emissions from a

prescribed universe of sources over a specific timeframe. To comply with EPA’s EIP guidelines,

sources that elect to participate in an averaging provision would be subject to a 10 percent

environmental benefit.

Creating a Universal Trading Market

To facilitate added compliance flexibility, one overall or universal trading market would be

developed. The universal trading market would be designed to maximize the trading interaction

between the different regulatory programs, expand the universe of credit generators and users,

and standardize the trading instrument. The universal trading market would include all existing

and future District programs with credit generation and use provisions. Sources participating in

the universal trading market would generate Universal Trading Credits (UTCs) that could be

used by new sources, RECLAIM, Rule 2202, and Regulation XI facilities as an alternative

method of compliance. The universe of credit generators would be expanded to include area

sources, permitted sources earning credits from modifications or overcontrol, and mobile sources

under Regulation XVI.
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In addition to developing a universal trading market, this control measure would include

provisions for interseasonal trading for VOC emissions. The provisions for interseasonal trading

would be based on providing incentives to sources to voluntarily shift VOC emissions from the

ozone to non-ozone season. Air quality analyses conducted during the Intercredit Trading Study

indicate that shifting VOC emissions from summer to winter months would improve summer

ozone concentrations and provide a net air quality benefit. This is because the atmosphere can

tolerate greater VOC emissions in the winter months without compromising air quality as a result

of less sunlight to drive the photochemistry.

Emissions Banking

The concept of emissions banking is based on saving emission credits generated in one year for

use in another. In general, credits are issued for reductions achieved in excess of current

requirements. Where control costs are more cost-effective, emissions banking provides an added

incentive to install advanced pollution control technologies which is expected to accelerate: (1)

emission reductions during the early years of the program improving air quality and reducing

ozone exposure, and (2) the introduction and commercialization of pollution control technologies

that are needed for the Basin’s attainment strategy.

EMISSIONS REDUCTION

Implementation of this control measure is expected to accelerate emission reductions during the

early years of the program through development and commercialization of advanced pollution

control technologies, produce a net air quality benefit. Programs such as emissions averaging are

expected to produce a 10 percent environmental benefit. Due to the voluntary nature of this

control measure, potential emission reductions associated with the early introduction of advanced

pollution control technologies cannot be quantified. As currently proposed, implementation of

this control measure is not designed to result in direct emission reductions since emission

reductions associated with credit generation activities would be offset by the use of the emission

credits. Thus, although no direct emission reductions are anticipated it is important to note that

this control measure will be designed to ensure that the added compliance flexibility does not

compromise the Basin’s overall progress towards achieving its air quality attainment goals.

RULE COMPLIANCE AND TEST METHODS

Compliance with the provisions of this control measure would be based on monitoring,

recordkeeping, and reporting requirements that have been established in existing source specific

rules and regulations. In addition, compliance would be verified through inspections and other

recordkeeping and reporting requirements.

Emissions quantification protocols will establish the appropriate test methods that applicable

source categories will be required to use when generating and using emission credits under this

program.
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B - 96

COST EFFECTIVENESS - ECONOMIC FEASIBILITY

The cost effectiveness of this control measure has not yet been determined. Since this measure is

voluntary, implementation of this control measure is expected to reduce the overall cost of

compliance with District rules and regulations. Implementation of this control measure is

expected to maximize trading opportunities and provide sources with more cost-effective

compliance methods. The District will continue to analyze the potential cost impact associated

with implementing this control measure and will provide cost effectiveness information as it

becomes available.

IMPLEMENTING AGENCY AND IMPLEMENTATION SCHEDULE

The District has the authority to regulate emissions from stationary sources. An implementation

schedule has not been determined at this time.

REFERENCES

South Coast Air Quality Management District. “Intercredit Trading Study. Proposed

Recommendations and Action Plan.” January 1996.
GROUP 4

Long-Term Stationary Source Control Measures
Appendix B: New and Revised Stationary Source Control Measures CM #99ADV-CLNG

B - 99

LONG-TERM CONTROL MEASURE FOR SOLVENT CLEANING AND

DEGREASING OPERATIONS

[VOC]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: SOLVENT CLEANING AND DEGREASING OPERATIONS

CONTROL METHODS: NEAR-ZERO OR ZERO-VOC COATING FORMULATIONS

EMISSIONS (TONS/DAY)

 1:

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 31.9 34.1

VOC REDUCTION 13.3 14.4

VOC REMAINING 18.4 19.7

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 35.3 37.8

VOC REDUCTION 14.9 16.0

VOC REMAINING 20.4 21.8

CONTROL COST: NOT DETERMINED

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

This control measure proposes to further control of VOC emissions from solvent cleaning and

degreasing operations.

Background

Solvent cleaning and degreasing is the use of VOC containing solvents to remove uncured

coatings, inks, and adhesives, and/or contaminants such as dirt, soil, oil, and grease. Solvent

cleaning operations are applicable to four major industrial operations, namely: production, repair,

maintenance, and servicing. These operations apply to the cleaning of products, tools,

equipment, machinery, general work areas, and the storage and disposal of materials used in the

cleaning process.

Degreasing is generally carried out in packaged degreaser units in which chlorinated synthetic

solvents or petroleum-based solvents are used to remove contaminants. The types of equipment

used in this method are categorized as batch-loaded cold cleaners, open-top vapor degreasers

and conveyorized degreasers. The two most significant VOC sources are evaporative losses,

during start-up, idling, and shut down, and drag-out losses, as parts are removed from the

degreaser.

 

1 Baseline emissions inventory reflects remaining emissions after implementation of short- and

intermediate- term measures.
Appendix B: New and Revised Stationary Source Control Measures CM #99ADV-CLNG

B - 100

PROPOSED METHOD OF CONTROL

In general, implementation of this advanced control measure will rely on establishing VOC limits

beyond short- and intermediate-term control measures. To achieve lower VOC limits affected

sources are expected to use near-zero- and zero-VOC cleaning and degreasing materials.

Although, significant advancements have been made relative to the development and application

of zero- or near-zero-VOC coating formulations and aqueous cleaning and degreasing materials,

additional progress is needed to achieve reductions beyond short- and intermediate-term control

measures.

This proposed control measure is to conduct the technology assessment in 2003-2004 as required

by the amended Rule 1171 (adopted in 1999) to determine if technologies to implement the 2005

VOC limits are expected to be available.

EMISSIONS REDUCTION

The targeted emission reductions for 2006 and 2010 are summarized in the Control Measure

Summary. Emission reductions from the source category are in addition to those reductions

anticipated through implementation of the counterpart short- and intermediate-term control

measures identified in Section 1 of Appendix IV of the 1997 AQMP and the 1999 Amendment.

However, reductions that have occurred through other actions, either mandatory or voluntary,

that are enforceable will be credited towards SIP obligations.

RULE COMPLIANCE

Rule compliance would be similar to compliance requirements under Rules 442, 1122, and 1171.

Recordkeeping and monitoring requirements would be similar to Rule 109.

TEST METHODS

Test methods include the following:

• U.S. EPA Test Methods 2, 2A, 2C, or 2D, measurements of ventilation rate in a hood or

enclosure and District Method 1.1, measure of traverse points.

• U.S. EPA Reference Method 24, Code of Federal Regulations Title 40, Part 60, Appendix

A - Determination of Volatile Matter Content, Water Content, Density Volume Solids,

and Weight Solids of Surface Coatings. District Section III, Method 22, Determination of

Exempt Compounds;

• U.S. EPA Test Method 25, 25A, or District Method 25.1 for the determination of total

organic compound emissions;

• ASTM Method D2879;

• ASTM Method D-1078-78, Standard Test Method for Distillation Range of Volatile

Organic Liquids;
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B - 101

• District Method 303, 304, 313, 308 and

• District Methods 19 and 22 - Laboratory Methods of Analysis for Enforcement SamplesSection III, Determination of Exempt Compounds Content.

COST EFFECTIVENESS

The cost effectiveness of this advanced control measure has not been determined.

IMPLEMENTING AGENCY/SCHEDULE

The District has authority to regulate VOC emissions from solvent cleaning and degreasing, and

other solvent-containing material operations. The proposed implementation schedule and

associated rulemaking activities are outlined as follows:

Milestone Completion Date

Technology Assessment Reports 2003-2004

SIP Submittal 2004

Rule Implementation 2005

REFERENCES

ARB, 1995. Solvent Cleaning/Degreasing Source Category Emissions Inventory. California Air

Resources Board. December 1995.
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LONG-TERM CONTROL MEASURE FOR MISCELLANEOUS

INDUSTRIAL COATING AND SOLVENT OPERATIONS

[VOC]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: MISCELLANEOUS INDUSTRIAL COATING AND SOLVENT

OPERATIONS

CONTROL METHODS: NEAR-ZERO OR ZERO-VOC COATING FORMULATIONS

EMISSIONS (TONS/DAY)

 1:

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 17.1 16.5

VOC REDUCTION 1.8 6.0

VOC REMAINING 15.3 10.5

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 15.8 15.1

VOC REDUCTION 1.8 6.0

VOC REMAINING 14.0 9.1

CONTROL COST: NOT DETERMINED

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

Background

Consistent with state and federal law, the District maintains an emissions inventory for a wide

variety of source categories and industries. The emissions inventory for the Basin includes nearly

180 different major source categories, and within the major categories, there are multiple source

categories that are even more defined. Miscellaneous Industrial Coating Operations is a generic

category that represents a wide range of unpermitted industrial coating and solvent operations.

Emissions are categorized as Miscellaneous Industrial Coating Operations when there is either

insufficient information to place the emissions in an existing source category or the source

category is so unique that a source category does not currently exist.

The objective of this advanced control measure is to further assess Miscellaneous Industrial

Coating Operations to identify those emissions within this general category that can be placed in

an existing source category or those emissions that require establishing a new source category.

Similarly, inventory and technical assessment will be conducted to seek further emission

reduction opportunities. Based on the results of these initial assessments, the District will

implement mechanisms to reduce VOC emissions.

 

1 Baseline emissions inventory reflects remaining emissions after implementation of short- and

intermediate- term measures.
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B - 103

Regulatory History

This source category may represent a wide variety of unpermitted industrial coating and solvent

operations. The type of operation, industry, and size of the source would determine which

rule(s) or regulation(s) that this source is regulated under.

PROPOSED METHOD OF CONTROL

Based on current information regarding miscellaneous industrial coatings and solvents, this

portion of this control measure would be implemented in two steps. The first step represents

assessment of the miscellaneous industrial coatings and solvents portion of the Basin’s emissions

inventory. The District will assess if emissions within this category can be grouped into an

existing source category that is more definitive, a new source category is needed, or that the

miscellaneous category is appropriate. Based on the results of the first step, the appropriate

control strategy to reduce VOC emissions beyond short- and intermediate-term emission

reductions would be developed.

EMISSIONS REDUCTION

The targeted emission reductions for 2006 and 2010 are summarized in the Control Measure

Summary. Emission reductions from these source categories are in addition to those reductions

anticipated through implementation of the counterpart short- and intermediate-term control

measures identified in Section 1 of Appendix IV of the 1997 AQMP. However, reductions that

have occurred through other actions, either mandatory or voluntary, that are enforceable will be

credited towards SIP obligations.

RULE COMPLIANCE

Rule compliance would be similar to compliance requirements under Regulation XI - Source

Specific Rules. Recordkeeping and monitoring requirements would be similar to Rule 109.

TEST METHODS

Test methods include the following:

• U.S. EPA Test Methods 2, 2A, 2C, or 2D, measurements of ventilation rate in a hood

or enclosure and District Method 1.1, measure of traverse points;

• U.S. EPA Reference Method 24, Code of Federal Regulations Title 40, Part 60,

Appendix A - Determination of Volatile Matter Content, Water Content, Density

Volume Solids, and Weight Solids of Surface Coatings. District Section III, Method

22, Determination of Exempt Compounds;

• U.S. EPA Test Method 25, 25A, or District Method 25.1 for the determination of total

organic compound emissions;

• ASTM Method D2879;
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B - 104

• ASTM Method D-1078-78, Standard Test Method for Distillation Range of Volatile

Organic Liquids;

• ASTM Test Method D1613-85 - Determination of Acid Content of Coating;

• District Method 303, 304, 313, 308, 311, and 313; and

• District Methods 19 and 22 - Laboratory Methods of Analysis for Enforcement

Samples-Section III, Determination of Exempt Compounds Content.

COST EFFECTIVENESS

The cost effectiveness of this advanced control measure has not be determined.

IMPLEMENTING AGENCY/SCHEDULE

The District has authority to regulate VOC emissions from industrial coating and solvent

operations The implementation schedule and associated rulemaking activities is described as

follows:

Milestone Completion Date

Technology Assessment and Control Strategy Development 2000-2002

Rule Development and Adoption 2003-2005

Rule Implementation 2006-2010

The following identifies projects to foster commercialization of advanced technologies for

industrial solvent and coating operations that are planned under the District’s Technology

Advancement Office.

• Technology assessment of advanced solvent and coatings formulations and applications

technologies.

• Industry and user workshops to identify priorities for joint research and development, and

commercialization.

• Formal solicitation of research, development and demonstration projects.

• Formation of joint industry/government Commercialization Coordination Councils, by

market segment, fuel type or technology type.

Specific projects may include the following:

• Phase III vernonia oil coatings.

• Phase III Coating Research Inst. development and demonstrations.

• Phase II wet cleaning technology demonstration to wider market segments.

• Phase III development and demonstration of Reactive Aqueous Defluxing Systems with

aerospace companies; associated technology transfer workshops, etc.

• Phase III Aerospace VOC technology development, demonstration and technology

transfer.
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B - 105

• High performance wood furniture coatings.

• Air Vest technology.

• Catalyst surface coating technology with catalyst manufacturers.
Appendix B: New and Revised Stationary Source Control Measures CM #99ADV-FUG

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LONG-TERM CONTROL MEASURE FOR FUGITIVE EMISSIONS

[VOC]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: ORGANIC LIQUID TRANSFER AND LOADING, CHEMICAL

STORAGE TANKS, PETROLEUM REFINERIES, CHEMICAL

PLANTS, OIL AND GAS PRODUCTION FIELDS, GASOLINE

DISPENSING FACILITIES, NATURAL GAS PROCESSING PLANTS

AND PIPELINE TRANSFER STATIONS.

CONTROL METHODS: PHASE I: TECHNOLOGY ASSESSMENT AND EMISSIONS

CHARACTERIZATION

PHASE II: DEVELOPMENT AND IMPLEMENTATION OF

CONTROL STRATEGIES

EMISSIONS (TONS/DAY)

 1:

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 24.2 22.2

VOC REDUCTION 1.1 5.0

VOC REMAINING 23.1 17.2

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 24.2 22.2

VOC REDUCTION 1.1 5.0

VOC REMAINING 23.1 17.2

CONTROL COST: NOT DETERMINED

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

Background

The emission sources targeted under this control measure include a variety of fugitive emissions

from organic liquid storage tanks (above-ground and under-ground), petroleum and chemical

products processing and transfer facilities, oil field production facilities, and gasoline marketing

terminals and dispensing facilities. Although these fugitive emission source categories have been

reduced over time and will be further reduced through the short-and intermediate-term measures

as proposed, in aggregate, they will still represent a significant emission source. Therefore, it is

necessary to further consider reducing emissions from this source category.

The objective of this control measure is to further develop data and methodology to better define

and refine emissions from each specific source categories. In addition, new technologies,

methods, and work practices need to be identified and evaluated that could locate, eliminate,

 

1 Baseline emissions inventory reflects remaining emissions after implementation of short- and

intermediate- term measures.
Appendix B: New and Revised Stationary Source Control Measures CM #99ADV-FUG

B - 107

and/or reduce fugitive emissions more effectively and efficiently. These developments will

provide opportunities for further reduction in fugitive emissions.

Regulatory History

Fugitive emissions are currently regulated under various District rules including Rule 1173, Rule

1176, Rule 461, Rule 462, and Rule 463.

PROPOSED METHOD OF CONTROL

This control measure will be implemented in two phases. In the first phase emissions data and

characteristics for each source category will be developed and refined. Technology assessments

will be conducted to identify and evaluate any control technology, method or work practices that

may be applied to each affected source category. Alternative leak detection methods, for

example, are being developed that have the potential to be more efficient in detecting fugitive

leaks from pipeline components, process equipment, and oil/gas production facilities. Low

emitting packing and seals, leakless devices, and durable and reliable vapor recovery systems may

be applicable more widely to petroleum products processing, distribution and gasoline dispensing

facilities. New storage tank accessories or better roof seals are other examples that may become

available to further reduce fugitive emissions. Depending on the result of the assessment, specific

control strategies will be developed for implementation in the second phase.

EMISSIONS REDUCTION

The projected VOC emissions for 2006 and 2010 are provided in the Control Measure Summary.

The targeted emission reductions are identified for 2006 and 2010 based on the annual average

and summer planning inventories. However, reductions that have occurred through other

actions, either mandatory or voluntary, that are enforceable will be credited towards SIP

obligations.

RULE COMPLIANCE

Similar to the existing rule compliance requirements under Rules 461, 462, 463, 1173, and 1176.

TEST METHODS

Test methods specified for Rules 461, 462, 463, 1173, and 1176 are also applicable to this

control measure. However, additional test methods may need to be developed once specific

control methods are defined.

COST EFFECTIVENESS

To be determined.

IMPLEMENTING AGENCY/SCHEDULE

The District has the authority to regulate emissions from fugitive emissions. The proposed

implementation schedule and associated rulemaking activities are outlined as follows:
Appendix B: New and Revised Stationary Source Control Measures CM #99ADV-FUG

B - 108

Milestone Completion Date

Technology Assessment and Control Strategy Development 2000-2002

Rule Development and Adoption 2003-2005

Rule Implementation 2006-2010

The following identifies projects to foster commercialization of advanced technologies to control

fugitive VOC emissions that are planned under the District’s Technology Advancement Office.

• Technology assessment of advanced fugitive emission control technologies and substitute

processes, focused on specific market segments.

• Industry and user workshops to identify priorities for joint research and development, and

commercialization.

• Formal solicitation of research, development and demonstration projects.

• Formation of joint industry/government Commercialization Coordination Councils, by market

segment, fuel type or technology type.

Specific projects may include the following:

• Production of Clean Fuels from municipal waste, biomass and other waste streams.

• Phase II asphalt emissions study and technology assessment.

• Fugitive emission control technology assessment.

• Solicitation of R & D proposals regarding control of fugitive emissions from specific types of

facilities, such as refineries, chemical facilities, oil/gas production facilities, etc.
Appendix B: New and Revised Stationary Source Control Measures CM #99ADV-PRC

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LONG-TERM CONTROL MEASURE FOR

INDUSTRIAL PROCESS OPERATIONS

[VOC]

CONTROL MEASURE SUMMARY

SOURCE CATEGORY: MISCELLANEOUS CHEMICAL PROCESS INDUSTRY

CONTROL METHODS: PHASE I: EMISSION INVENTORY STUDY AND TECHNOLOGY

ASSESSMENT

PHASE II: CONTROL STRATEGY DEVELOPMENT AND

IMPLEMENTATION

EMISSIONS (TONS/DAY)

 1:

ANNUAL AVERAGE 1993 2006 2010

VOC INVENTORY 5.5 7.7 8.3

VOC REDUCTION 0.1 0.7

VOC REMAINING 7.6 7.6

SUMMER PLANNING INVENTORY 1993 2006 2010

VOC INVENTORY 7.7 10.8 11.6

VOC REDUCTION 0.2 1.0

VOC REMAINING 10.6 10.6

CONTROL COST: NOT DETERMINED

IMPLEMENTING AGENCY: SCAQMD

DESCRIPTION OF SOURCE CATEGORY

Background

The source categories targeted under this control measures are those small VOC emitters and/or

unpermitted facilities that are involved in manufacturing or fabrication of rubber, plastic,

fiberglass products, or chemical compounds, as well as those involved in the processing, handling

or storage of VOC containing materials. Sources of emissions are primarily generated from

material handling, use of chemicals, volatile liquids during reaction, emissions of solvents during

storage, handling, and processing of resins, or the drying/cooling of finished products.

Regulatory History

Rubber product and plastic product manufacturing operations, and fiberglass fabrication and

impregnation processes are not currently regulated under a source-specific District rule for the

pollutant identified. However, they could be subject to Rule 402 which limits the discharge from

 

1 Baseline emissions inventory reflects remaining emissions after implementation of short- and

intermediate- term measures.
Appendix B: New and Revised Stationary Source Control Measures CM #99ADV-PRC

B - 110

any source causing a public nuisance. In addition, Rule 442 may also be applicable, which

controls the discharge of organic solvents into the atmosphere.

PROPOSED METHOD OF CONTROL

Since most of the source categories targeted by this measure are not permitted or regulated, it is

necessary to first identify and refine emission inventory, sources of emissions, and industry

operations and practices. Based on the findings, appropriate control methods can then be

developed. Potential control methods include enhanced inspection and maintenance and other

housekeeping work practices to reduce fugitive emissions from material transfer, storage, and

processing. Process modification may also provide an effective control option to minimize or

eliminate emission sources. This measure will seek emission reductions from the processes that

can potentially be modified, controlled, or converted.

EMISSIONS REDUCTION

The projected VOC emissions for 1993, 2006 and 2010 are provided in the Control Measure

Summary. The targeted emission reductions are identified for 2006 and 2010 based on the

annual average and summer planning inventories.

RULE COMPLIANCE

Depending on the control methods proposed, appropriate rule compliance requirements will be

developed, which may include, but are not limited to, operator inspection, maintenance, and

recordkeeping. It is also necessary to develop innovative rule implementation programs dealing

with numerous non-permitted small sources.

TEST METHODS

To be determined.

COST EFFECTIVENESS

To be determined.
Appendix B: New and Revised Stationary Source Control Measures CM #99ADV-PRC

B - 111

IMPLEMENTING AGENCY/SCHEDULE

The District has the authority to regulate VOC emissions from industrial processes. The

proposed implementation schedule and associated rulemaking activities are outlined as follows:

Milestone Completion Date

Emission Inventory Studies and Technology Assessments 2000-2002

Rule Development and Adoption 2003-2005

Rule Implementation 2006-2010

The following identifies projects to foster commercialization of advanced technologies to control

VOC emissions from industrial processes that are planned under the District’s Technology

Advancement Office.

• Technology assessment of advanced emission control technologies and substitute processes

for a variety of small sources, focused on specific market segments.

• Industry and user workshops to identify priorities for joint research and development, and

commercialization.

• Formal solicitation of research, development and demonstration projects.

• Formation of joint industry/government Commercialization Coordination Councils, by market

segment, fuel type or technology type.

Specific development and/or demonstration projects may include the following:

• Biofilter technologies.
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