As part of this effort, staff will continue to evaluate current permit requirements and associated public feedback, and will return to the Board with appropriate recommendations. Inspections associated with compliance checks will be absorbed by current AQMD staff. The proposed rule reflects the requested 24-month implementation period. The AQMD agrees that all sources should be treated equally. The Resolution will reflect this.
Cost estimates indicates that the catalytic oxidizer is a cost-effective control option.
EPA traditionally requires daily records for demonstrating compliance with a rule limit or exemption level that is based on an underlying daily or hourly air quality standard. However, due to the very small number of facilities anticipated to request this exemption and the amount of emissions that would theoretically result from these sources in a worst-case scenario calculation, EPA has indicated that weekly records are acceptable in this limited circumstance. EPA has stated that this flexibility in extending the recordkeeping time period is not a precedent for other rules. Under-fired charbroilers, which represent the majority of emissions, do not require controls. This proposed rule is the first step in significantly controlling emissions from chain-driven charbroilers and will advance technology for the industry by specifying future evaluation of control methods for other cooking equipment.