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BlueScape Pressure on Metal Facilities is Heating Up! Update on the Los Angeles Air Toxics Initiative Webinar 092817

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Metal processing facilities are facing regulatory scrutiny and air emission controls unlike ever before, in a snowball effect of agency action.

You may have heard about metal processing facilities such as Exide in Vernon. Or Anaplex in Paramount. Fast-forward to 2017, the South Coast Air Quality Management District (SCAQMD) has made findings of elevated and significant airborne levels of hexavalent chromium (CrVI) in Paramount and Compton. The findings were made by extensive ambient fenceline and community monitoring near metal processing facilities.

Now, some metal processing facilities in the LA area are undergoing Order for Abatement actions to protect public health by SCAQMD, by controlling emissions and odors, and even by shutting down operations, at high capital cost. State and local rules are changing, to accelerate the allowed enforcement use of fenceline monitoring and expedited Orders for Abatement, and to codify stringent CrVI, lead, arsenic, cadmium and nickel air emission controls.

The City of Los Angeles just announced that 21,000 metal processing sites will be prioritized for investigation for possible public health impacts from CrVI sources. These developments have implications in LA, California and beyond.

This webinar discusses:

• The background to SCAQMD’s Community Air Toxics Initiative.
• Update of enforcement activities in Paramount and Compton.
• What is the role public nuisance laws, monitoring, source testing and health risk modeling have in all this?
• SCAQMD rule developments that may impact your operations; 1407, 1420, 1426, 1430 & 1469
• Relevant State legislation and other local actions flowing from the Air Toxics Initiative.
• How to assess your status before SCAQMD visits your facility - what is a “bad” operation and what is “good”
• Options to avoid enforcement action and revised SCAQMD toxics rule requirements, and streamline compliance costs.
• How to proactively reduce emissions, including enclosures, scrubbers, dust collectors, housekeeping and other measures.

The instructors for the webinar are James A. Westbrook, President of BlueScape, and Michael Stewart, Project Manager. Since 1987, BlueScape has managed or completed more than 100 air toxics related projects for metal processing facilities. BlueScape has been working with aerospace companies, metal finishing facilities and foundries on issues related to the Air Toxics Initiative.

BlueScape can be reached at training@bluescapeinc.com or 877-486-9257 for questions, customized training, and support for your air permitting, compliance and HRA projects.

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BlueScape Pressure on Metal Facilities is Heating Up! Update on the Los Angeles Air Toxics Initiative Webinar 092817

  1. 1. Pressure on Metal Facilities is Heating Up! Update on the Los Angeles Air Toxics Initiative James Westbrook, CPP | President Michael Stewart, PE | Project Manager September 28, 2017
  2. 2. Webinar  Topics   •  Background to the Air Toxics Initiative •  Summary of Enforcement and Rulemaking •  Impacts on Metal Processing Facilities •  Recommendations for Evaluation & Next Steps
  3. 3. Poll – How did the LA Air Toxics Initiative Begin? •  SCAQMD enforcement action against high- emitters •  Erin Brockovich lawsuits •  A facility “turned themself” in to the health dept. •  Community action •  The Exide Vernon case
  4. 4. Background to the Los Angeles Air Toxics Initiative
  5. 5. Air  Toxics  &  the  Snowball  Effect  
  6. 6. Air Toxics Initiative Timeline 2007 – 2015: Exide Lead SCAQMD Rules 1420.1 and 1420.2 2017 - 2024??: - SCAQMD Air Toxics Initiative - State & Local Rule Developments -  Enforcement & Monitoring in Paramount, Compton and Long Beach -  LA City Motion -  What’s NEXT? 2012-2017: -  Paramount CrVI Monitoring -  Anaplex, Aerocraft and Carlton Forge 2010 – 2015: -  Hixson Metal CrVI -  Rule 1402 Risk Reduction
  7. 7. CrVI – One Bad Hombre (and the other guys) •  CrVI is a state that occurs in high-heat or strong oxidation processes, or introduced in compound form –  Cr to CrVI - Furnaces, heat treating, welding rod use, laser or arc cutting and other types of “hot work” –  Chrome plating, anoziding, chromic acid baths with heating or sparging –  Cr compounds used in coating pigments and spray booths, military spec •  CrVI is very toxic and known to cause cancer & other long-term chronic health effects •  How can CrVI get into the air? •  Lead, nickel, arsenic, cadmium, beryllium
  8. 8. Summary of Enforcement & Rulemaking Activities
  9. 9. Nuisance, Public Health, and SCAQMD Enforcement •  SCAQMD has various tools to regulate air toxic metal emissions –  Rule 1401/permits, Reg. IV rules, Rule 1402/AB2588 –  But have to be a “fit” •  Public Nuisance laws primary enforcement tool –  SCAQMD Rule 402, H&S Code 41700 –  “ shall not discharge … contaminants .. which cause injury, detriment, nuisance or annoyance to any considerable number of persons or to the public .. or which endanger the comfort, repose, health or safety …” •  “Imminent and substantial endangerment” language not in nuisance regulations •  Orders for Abatement issued by the Hearing Board –  Process, Evidence, Action •  SCAQMD’s mission to strengthen tools    
  10. 10. 2015  Risk   Guideline   Changes   Increased   Monitoring   &  Tes<ng   EJ   Community   Ac<va<on   CrVI   Emissions   Increased   Public   Nuisance   Enforcement   Odors  
  11. 11. Paramount Enforcement – Anaplex •  Metal finishing facility •  AQMD fenceline & community monitoring •  1 ng/m3 CrVI ambient threshold, 3 samples –  0.2 ng/m3 = 100 in one million resident cancer risk •  Anaplex Order for Abatement in Jan 2017 for emissions exceeding 1 ng/m3 –  Ordered to temporarily shut down all equipment w/PTE CrVI on June 27th, 2017 •  Required controls include: –  Close access doors, reduce tank emissions, housekeeping •  Precursor to rulemaking, amended Rule 1469/1426
  12. 12. Paramount Enforcement - Carlton Forge •  Metal forging facility •  Public odor complaints starting in 2012-2013 –  190 odor complaints since Dec 9, 2016 à 17 NOVs •  Voluntary controls installed for grinding •  Nickel emissions went down, but CrVI constant •  Precursor to rulemaking, Rule 1430 –  Related to grinding specifically •  Additional review of odor controls in process  
  13. 13. Compton & Long Beach Enforcement •  SCAQMD putting the Air Toxics Initiative in play …. •  Multiple facilities in Compton –  Ambient CrVI monitoring began June 2017 –  99 inspections conducted in July 2017 •  5 NOVs and 16 NTCs issued –  Expecting Orders for Abatement •  Lubeco in North Long Beach
  14. 14. South Coast AQMD Rulemaking •  Exide – Rules 1420.1 and 1420.2 for lead •  Carlton Forge – Rule 1430 for CrVI and odors •  Hixson, Paramount, Compton, etc. – Proposed Amended Rules 1426 / 1469 for CrVI •  Other Proposed Amended rules, capture more sites and consistency: –  Rule 1420 for small lead melters –  Rule 1407 for ferrous and non-ferrous facilities •  New Rules Coming - other units and operations – heat treating, laser cutting, grinding; larger facilities  
  15. 15. New State Air Toxics Legislation •  Assembly Bill 617 (passed 7/26/17): –  ARB to expand community toxics monitoring for high priority facilities –  Authorize air districts to require facility fenceline monitoring •  Facility with elevated cancer or noncancer prioritization score –  Districts can require “best controls” to reduce toxics •  Assembly Bill 1132 (passed 8/7/17) –  Air districts can issue an “interim” Order for Abatement •  Currently must be noticed and hearing occur, with approval before Order can be issued –  Finding of “imminent and substantial endangerment to the public health or welfare” –  Air district must meet facility, work on a “stipulated” interim Order –  The interim orders are temporary.  
  16. 16. LA City Council Motion and beyond … •  Motion passed by LA City Council on 8/30/17 •  Identified 21,000 metal processing sites with CrVI •  Bureau of Sanitation to work with SCAQMD and LA Co Health Dept w/in 30 days –  Update priority ranking of sites with excessive CrVI –  Plan for joint inspections –  Analyze environmental justice impacts –  Update on ways to reduce health effects to LA residents •  What other cities, counties, agencies, initiatives, areas in California? –  When will the air toxics snowball slow down??
  17. 17. SCAQMD Rule Developments in Response to Air Toxics Initiative
  18. 18. SCAQMD Metals Rule Applicability by Operation Type Activity 1420 1420.1 / 1420.2 1430 1469 / 1426 1407 1435 1445 Amendment Review Adopted Adopted Amendment Review Amendment Review Pending Pending Foundry ✔ ✔ ✔ Machine Shop ✔ Stamping Metal Finisher ✔ ✔ Forger ✔ Smelter ✔ ✔ Grinding ✔ ✔ ✔ Saw Cutting ✔ ✔ Welding ✔ Dust / Fugitives ✔ ✔ ✔ ✔ ✔ ✔ Odors ✔ ✔ Finishing ✔ Melting ✔ ✔ ✔ Heat Treating ✔ ✔ Laser Cutting ✔
  19. 19. Proposed Amended Rules •  Rule 1420 – Emissions Standards for Lead –  SCAQMD proposed amendments to the rule –  Applies to metal melting or lead processing facilitates •  Exempt if process < 2 TPY lead –  Ambient lead concentration requirements: •  0.150 µg/m3 through 2020, 0.100 µg/m3 2021 and beyond –  Emissions to be vented to HEPA filter controls (alternative compliance option available) –  Source testing demonstrations –  Fenceline ambient lead monitoring •  If process more > 10 TPY lead •  If > 2 TPY, but < 10 10 TPY, can avoid with modeling studies –  Total Enclosures –  Housekeeping Requirements
  20. 20. Approved SCAQMD Metals Rules •  Rule 1420.2 – Emission Standards for Lead from Metal Melting Facilities –  If facility melts > 100 TPY lead –  Would require total enclosure for all lead processing operations –  Ambient air monitoring requirements –  Lead point source emission controls –  Source testing –  Total enclosures
  21. 21. Recently Adopted Rule •  Rule 1430 - Control of Emissions From Metal Grinding Operations at Metal Forging Facilities –  Requires total enclosure for all metal grinding and cutting operations –  Emissions requirements: •  0.002 grains PM per dscf •  Vented to HEPA filter & continuous data logger –  Odor reduction –  Source testing –  Housekeeping requirements –  Compliance dates for total enclosures around metal grinding or cutting operations started 9/3/17
  22. 22. Proposed Amended Rules •  Rule 1469 – CrVI Emissions from Chromium Electroplating and Chromic Acid Anodizing Operations –  Would require enclosure for all tank operations with CrVI –  Point source controls Tier II tanks (high conc. or temp., or rectified) –  Periodic source testing –  Potential regulations on tanks currently not subject to Rule 1469 (Rinse, passivate, dichromate seal, etc.) –  Getting help from other City of LA agencies to find CrVI emitters •  Rule 1426 - Emissions from Metal Finishing Operations –  Facilities performing Cr, Ni, Cd, Pb or Cu operations, or chromic acid anodizing (See Rule 1469) –  Compliance reports & housekeeping requirements –  No control requirements –  AQMD is using facilities under this Rule as a vehicle to capture facilities under Rule 1469
  23. 23. Proposed Amended Rules •  Rule 1407 – Control of Emissions of Arsenic, Cadmium, and Nickel from Non-Ferrous Metal Melting Operations –  Proposed amendments –  Includes smelting, die casting, galvanizing & more –  Control fugitive emissions by building enclosures –  Point source controls –  More housekeeping –  Source Testing to measure control efficiency –  Exempt if < 1 TPY metal melting –  Next workshop in December 2017
  24. 24. SCAQMD Metals Rules In the Pipeline •  Rule 1435 Control of Emissions from Metal Heat Treating Processes –  A proposed rule –  Being moved from Nov to 2nd quarter 2018 •  Rule 1445 Control of Toxic Emissions from Laser Arc Cutting –  Will establish requirements to reduce toxic metal particulate emissions from laser arc cutting
  25. 25. Loss of Permitting Exemption •  Loss of exemption language clearly stated in rules. •  Can lose exemption if the AQMD see your process as a health risk concern. •  Rule 219/222 –  Equipment losing exemptions and will require permits •  Example: No exemptions for plating, stripping or anodizing if tank contains Cr, Ni, Pb, or Cd and is rectified, sparged, or heated
  26. 26. Key Common Downstream Impacts of Rulemaking •  Loss of permit exemption •  Increased source testing requirements •  Increased ambient monitoring •  Increased emission controls of point sources –  HEPA filters, baghouse, etc. •  Increased emission controls of fugitive sources –  Enclosures •  Increased housekeeping requirements
  27. 27. Impacts on Metal Processing Facilities
  28. 28. How to Know if You Could be a High Priority? •  Do you emit CrVI, cadmium, nickel, lead, or arsenic? •  Is the facility located near residences or schools? •  Is the facility located in an Environmental Justice (EJ) area? •  Potential for fugitive toxic emissions or odors? •  Any previous issues related to metal emissions: NOVs, NTCs, etc? •  On other lists, like for Rule 1402?
  29. 29. Carlton Forge is a High Priority
  30. 30. How to Know if You Could be a “Bad Player?” •  Know your emissions •  Are these sources controlled? •  Are all emission sources permitted? •  Metals-related NTCs/NOVs? •  Any odor complaints? •  Is your facility clean and is proper housekeeping performed? •  Where are the prevailing winds coming from?
  31. 31. What Can Happen if the Emissions & Monitoring Results are Too High? •  Installation of emission controls may be required: –  Baghouses/HEPA filters –  Enclosures •  Required to source test or monitor •  Emissions, source test or monitoring results may need to be modeled: –  To assess health risk impacts –  HRA methodologies were updated in 2015 à 3x higher impacts •  Any of these activities are expected to yield high costs to the facility •  If seen as “imminent danger” to public, potential process limits or operation curtailment
  32. 32. What Can Happen if the Emissions & Monitoring Results are Bad?
  33. 33. Potential Costs to Your Facility
  34. 34. Potential Costs to Your Facility
  35. 35. Lubeco Example – Formula for an Order of Abatement •  July 2017, AQMD petitioned for Stipulated Order of Abatement & was granted by Hearing Board on August 23 •  Result of “intensive investigation” à high levels of CrVI •  Short & long-term measures to reduce CrVI •  Shut down equipment if > 1 ng/m3 •  Removal of certain tanks w/CrVI •  Modification of certain practices •  Risk reduction plan •  Installation of control equipment •  Periodic AQMD inspections to ensure compliance with the Order
  36. 36. Recommended Evaluations
  37. 37. Prepare Yourself With All of the Information •  Know the rules and those that apply to you. •  Make sure the emission inventory reports are accurate –  Review emission factors, process throughput and other assumptions •  Which is the highest source of CrVI emissions? –  Furnace? –  Welding? –  Cutting? •  Do you think your equipment could be a problem? Perform a fact-finding source test or ambient monitoring •  Has an HRA been previously performed? •  Know how this could affect your suppliers and purchasers.
  38. 38. Proactive Actions to Avoid SCAQMD Enforcement •  Be prepared before SCAQMD arrives – know what the potential problems are/will be. •  Be prepared to update emissions with better information. •  Begin getting cost estimates on expected control equipment. –  Plan for enclosures, scrubbers, dust collectors, HEPA filters, housekeeping and other measures •  Attack the low hanging fruit first. •  Be prepared to communicate with the SCAQMD.
  39. 39. Conclusions
  40. 40. Develop a Plan •  Do your homework –  Collect all information –  Review compliance history –  Visit all the equipment –  Compare permits to equipment operation – is everything accurate? –  Know your neighbors •  What is the “high risk” equipment? –  Know the emissions and health risk impacts, evaluate need for controls, prepare for source tests and monitoring •  Get help!
  41. 41. Get Involved •  Keep up to date with rule development •  Know where you fit into these rule developments •  Attend workshops and public hearings •  Attend town hall meetings •  Submit comments for rule development •  Be active in local environmental organizations
  42. 42. A Consultant Can Help You There are experts who can: •  Review rule applicability •  Help you know if you are a “target” or a “bad player” •  Ensure your emission reports are accurate •  Support source testing or ambient monitoring •  Perform health risk calculations & modeling •  Communicate with the air districts and other agencies
  43. 43. Ques:ons?   Contact  Informa:on   James A. Westbrook, CPP | President jwestbrook@bluescapeinc.com Michael Stewart, PE | Project Manager mstewart@bluescapeinc.com (877) 486 – 9257 www.bluescapeinc.com Connect with us on Linkedin! The webinar presentation will be posted on Slideshare and YouTube

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