Public Workshop

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Public Workshop

• Reasonably Available Control Technology (RACT)
• Senate Bill 656
• November 15,2006
• By
• David L. Jones, Air Pollution Control Officer
• Julie Damo, Air Quality Engineer
• Debbi Klossing, Air Quality Specialist
• Kern County Air Pollution Control District

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Purpose of Workshop

• Provide an overview of the ozone SIP
• Provide regulatory background for RACT
• Provide overview of the RACT analysis
• Discuss ozone precursor control measure concepts
• Provide RACT rule development implementation
  schedule

• Discuss PM control measure problems and some
  possible solutions
• Provide regulatory background for SB 656
• Provide overview of SB 656 control measure
  analysis
• Provide SB 656 rule development implementation
  schedule
• Open discussions

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What is ozone

• Ozone (O3) is reactive toxic gas consisting of
  three oxygen atoms.
• Not emitted directly into atmosphere
• Formed through a chemical reaction between
  volatile organic compounds (VOCs) and nitrogen
  oxides (NOx) in the presence of sunlight.

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Federal Clean Air Act (FCAA)

• Preventing and controlling air pollution is
  primarily the responsibility of state and local
  government with federal oversight
• Sets general requirements for what state
  implementation plans (SIPS) must include, EPA
  interprets FCAA and provides more specifics in
  guidance and implementation rules
• Remedies include sanctions and federal takeover
  if insufficient action taken by state or local
  agency citizen suits if EPA fails to take action
  or enforce

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Federal National Ambient Ozone Standard (NAAQS)

• 1-hr ozone NAAQS (.12 ppm) promulgated 1979 and
  revoked 2004
• 8-hr ozone NAAQS (.08 ppm) promulgated 1997
• Final 8-hr. designations classifications signed
  4/15/04, effective 6/15/2004
• KCAPCD designated nonattainment under subpart 1
  of FCAA
• Control requirements tied to the applicable
  subpart and the areas classification

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KCAPCD Design Value Site
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8-hour SIP Requirements

• Emission Inventory
• Attainment Demonstration
• New Source Review
• Reasonable Further Progress Demonstration
• Control Strategy (RACT, RACM, other necessary
  controls)
• Public Workshops on SIP and Hearing
• Due June 15, 2007 to EPA, earlier to ARB

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Control Strategies

• Reasonably Available Control Technology
• Reasonably Available Control Measures
• Other SIP Control Measures
• Contingency Measures

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Reasonably Available Control Technology (RACT)
CAA 172(c)(1), 182(b)(2), 182(f)

• RACT for subpart 1 areas 51.912 (c)
• None, if projecting attainment by 6/15/2009
• Due with Attainment Demonstration SIP (6/15/2007)
  if area will attain after 6/15/2009
• All RACT should be adopted at time of SIP
  submittal

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What is RACT?

• Reasonably Available Control Technology
• Lowest emission limitation that a particular air
  contaminant source is capable of meeting by the
  application of control technology that is
  reasonably available considering technological
  and economic feasibility
• The federal Clean Air Act requires implementation
  of RACT in ozone non-attainment areas.

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How did we identify RACT

• CTG/ACT
• Region IX Guidance Steckel/Karperos 4/4/06
  letter

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US EPA Region IX Guidance

• Describe efforts to identify all RACT source
  categories and major non-CTG sources
• Submit negative declarations
• List the regulation that implements RACT.
• Describe the basis for concluding that the
  regulations fulfill RACT and
• CAPCOAs (California Air Pollution Control
  Officers Association) September 2002 Potential
  All Feasible Measures (AFM) Report

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What KCAPCD rules categories qualify as RACT?

• Cement Kilns
• Turbines
• Tanks
• Evaporative Gasoline Sources
• Dry cleaners

• Coating Operations Metal Parts Products,
  Architectural, Automotive Traffic Markings
• Cutback Asphalt
• Ink Paint Manufacture
• Municipal Waste Combustion

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What rules are RACT but are subject to future
scrutiny?

• Boilers
• ICE
• Graphic Arts
• Degreasing

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Two KCAPCD RACT deficiencies

• Aerospace Assembly and Component Manufacturing
  Operations
• Polyester Resin

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Why do we need a new aerospace rule?

• Two major stationary sources are military bases
• KCAPCD currently does not have an SIP-approved
  aerospace rule
• KCAPCD Aerospace BACT not federally enforceable
• Districts surrounding KCAPCD have adopted an
  aerospace rule

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What is the basis for the new aerospace coatings
rule?

• RACT determination from states All Feasible
  Measures, Identification of Performance Standards
  http//www.arb.ca.gov/ssps/aero.pdf
• Report compares several district rules and NESHAP
  (MACT standards)
• San Joaquin Rule 4605

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Why San Joaquin Rule 4605

• Some rules have not been amended in some time
• Rule is not the most stringent
• KCAPCD is not required to adopt most stringent
  http//www.arb.ca.gov/drdb/sju/curhtml/r4605.pdf

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KCAPCD Criteria for Selecting an Aerospace Rule

• Applicable to both aerospace components and
  aerospace vehicles
• Fairly current coating VOC content limitations
• Up-to-date solvent cleaning techniques
• Complete list of application equipment

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What will the aerospace coating requirements be?

• VOC coating content ablative, various types of
  adhesives, bearing, caulking and smoothing
  compounds, chemical agent resistant, various
  primers, corrosion prevention compound, cryogenic
  coatings, extreme performance interior coating,
  barrier, fastener coatings, fire resistant, fuel
  tank coating, insulation covering, metallized
  epoxy coating, various sealants, thermal control,
  all other general coatings and maskants.

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What will the aerospace coating requirements be?

• Application equipment
• Electrostatic
• Electrodeposition,
• High Volume Low Pressure (HVLP) spray guns,
• Flow,
• Roll,
• Dip and/or brush.

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What will the aerospace coating requirements be?

• Solvent usage
• Surface cleaning 200 g/L or 45 mm Hg _at_ 68?F.
• Coating application equipment cleaning
  Enclosures and/or VOC limitation
• Stripping 300 g/L _at_ 9.5 mmHg 68?F

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What will the aerospace coating requirements be?

• Clean-up requirements
• Wipe cleaning
• Containers from which solvents are applied
  without a propellant-induced forced
• Closed cleaning equipment container
• Remote reservoir cold cleaner
• Enclosed system
• Non-atomized solvent flow method
• Solvent flushing

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Why do we need a polyester resin rule?

• KCAPCD currently has no standard.
• Potential growth 90 of states emissions will
  occur in the Mojave Desert Air Basin in 2015 and
  2020. http//www.arb.ca.gov/app/emsinv/fcemssumcat
  2006.php

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What is the basis for the new polyester resin
rule?

• Ventura County APCD 74.14 http//www.arb.ca.gov/dr
  db/ven/curhtml/r74-14.pdf
• Butte County APCD 232 http//www.arb.ca.gov/drdb/b
  ut/curhtml/r232.pdf

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Why VCAPCD Rule 74.14 or Butte County AQMD Rule
232

• Combination of the two rule would create a middle
  ground
• KCAPCD is not required to adopt most stringent

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What are the requirements that the District is
considering?

• Fairly stringent monomer content
• General purpose polyester resin 35
• Corrosion-resistant 48
• Fire retardant 42
• High strength 48
• Clear gel coat 50
• Pigmented gel coat 45
• Specialty resin 45

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What are the other requirements that the District
is considering?

• Other requirements
• Resin containing vapor suppressant
• Closed-mold system
• Airless spray, air-assisted airless spray and
  HVLP spray

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What will the RACT implementation schedule be?

• Aerospace rule by 6/15/07
• Polyester resin rule by 6/15/07
• Both rules needs to be submitted as part of the
  SIP
• Public review and comment period

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What is SB656

• Senate Bill 656 (Sher) http//www.arb.ca.gov/pm/pm
  measures/pmmeasures.htm
• Codified as Health and Safety Code (HSC) section
  39614 http//www.arb.ca.gov/bluebook/bb06/hea39614
  /hea_39614.htm
• Reduces exposure to particulate matter
• Most readily available, feasible and cost
  effective control measures

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What was the SB 656 process

• 103 control measures from stationary, area and
  mobile rules and regulations
• Control measures were ranked according to
  applicability to District and cost effectiveness
• Applicability was determined using the Emission
  Inventory ratios, permits, complaints, other
  inspection activities.

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What is particulate matter

• Particulate matter (PM) consists of very small
  liquid or solid particles in the air.
• The size of the particulate matter can vary from
  coarse, wind-blown particles to fine particles of
  combustion.
• The greatest public health concern are the
  particles that can reach the deepest part of the
  lungs.

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What is Particulate Matter
Hair cross section (70 mm)
Human Hair (70 µm diameter)
M. Lipsett, California Office of Environmental
Health Hazard Assessment
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Particle Deposition

• Larger particles gt PM10 deposit in the upper
  respiratory tract.
• Smaller particles lt PM10/2.5 penetrate into the
  lungs.

• Smallest particles (ultrafines, PM0.1) may enter
  bloodstream.

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Particles Affect the Lungs and Heart

• Respiratory system effects
• Chronic bronchitis
• Asthma
• Respiratory symptoms (cough, wheezing, etc.)
• Decreased lung function
• Airway inflammation
• Cardiovascular system effects
• Heart attacks
• Changes in heart rate
• Blood component changes

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Some Groups Are More at Risk

• People with heart or lung disease
• Conditions make them vulnerable
• Older adults
• More susceptible to heart and lung disease
• Children
• More likely to be active
• Breathe more air per pound
• Bodies still developing

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PM-10 and 2.5 IS A GRAB BAGOF POLLUTANTS

• Complex mixture

PM-10, 2.5
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Sources of PM-10 2.5

• Includes motor vehicles, wood burning stoves
  fireplaces, dust from construction and
  agriculture, industrial sources windblown dust
  from open or disturbed land.
• SB 656 requires that the ARB all 35 Air
  Districts adopt a list of the most readily
  available, feasible, cost effective control
  measures to reduce PM- 10 2.5.

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Almond Harvest Dust
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Road Dust
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Road Track Out
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Agricultural Farming
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Trenching Dust Control
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What SB 656 control measures were chosen

• Modification of Rule 402 Inactive disturbed
  land, carryout and track out
• Agricultural operations Cease operations during
  tilling and mulching during high wind events
• Windblown dust Ceasing and/or restricting
  non-agricultural operations during high wind
  events

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What is the basis for the PM control measures

• Inactive disturbed areas SJVAPCD Rule 8021
  (11/15/01) http//www.arb.ca.gov/drdb/sju/curhtml/
  r8021.pdf and SCAQMD Rule 403 (2/14/97)
  http//www.arb.ca.gov/drdb/sc/curhtml/r403.pdf
• Carry out and trackout SJVAPCD Rule 8041
  (11/15/01) http//www.arb.ca.gov/drdb/sju/curhtml/
  r8041.pdf
• Agricultural operations, tilling and mulching
  SCAQMD Rule 403.1 (1/5/93) http//www.arb.ca.gov/d
  rdb/sc/curhtml/r403-1.pdf
• Windblown dust SCAQMD 403

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What will the SB 656 implementation schedule be?

• Fugitive dust by 12/31/07
• Address inactive disturbed land
• Address carryout and trackout
• Agricultural operations by 12/31/08 tilling and
  mulching
• Windblown dust by 12/31/09
• At least one more workshop for each category
• Public review and comment period

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Questions/Discussions

• Ozone SIP
• RACT
• Proposed aerospace rule
• Proposed polyester resin rule
• SB 656
• PM problems

• Carryout/track out control measure
• Agricultural operations tilling/ mulching control
  measures
• Windblown dust control measure
• Implementation schedules