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BOARD MEETING DATE: March 12, 1999 AGENDA NO. 2

PROPOSAL:

Set Public Hearing April 9, 1999 to Amend Rule 1158 – Storage, Handling, and Transport of Coke, Coal and Sulfur

SYNOPSIS:

Ambient monitoring, on-going public nuisance complaints, and AQMD staff observations and inspections have shown that the current Rule 1158 is not sufficient in reducing PM10 emissions. To address these deficiencies PAR 1158 will: expand the scope of this rule by including coal and sulfur; establish a No. ½ Ringlemann visible emissions limitation; reaffirm the requirement that all coke piles be enclosed; allow optional open storage of prilled sulfur and coal, under an Executive Officer approved plan; set standards for silt loading on roads and truck exteriors; require paving and maintenance of surfaces and roads where material accumulates; and require covers or slot-tops for material transport trucks.

COMMITTEE:

Stationary Source Committee, February 19, 1999, Reviewed

RECOMMENDED ACTION:

Set the Public Hearing on Proposed Amended Rule 1158 – Storage, Handling, and Transport of Coke, Coal and Sulfur

Barry R. Wallerstein, D.Env.
Executive Officer

Background

Rule 1158 was originally adopted on December 2, 1983. The rule addressed the open storage of coke in order to reduce public nuisances from particulate emissions. The rule required enclosure of coke piles, required an interim open storage plan until a pile was enclosed and allowed the Executive Officer to make an interim plan permanent, subject to annual review, if the facility demonstrated that it would not violate AQMD rules.

Since the original rule was adopted citizen complaints have continued about coke, coal, and sulfur emissions and fallout from the storage, handling and transport activities. Various monitoring studies and inspections have documented problems and violations resulting from these operations. The particulate emissions from these sources contribute to poor ambient air quality and visibility which are in violation of applicable standards. Health studies related to ambient air quality standards have linked particulate emissions to adverse health effects.

As such, the current Rule 1158 is proposed to be amended for a number of reasons:

• Monitoring studies, site observations by AQMD staff, continued violations of AQMD rules, and continued public nuisance complaints indicate the current Rule is not sufficient to address the problems it was designed to deal with.
• The facilities covered by this Rule contribute to the Basin’s continued exceedances of the federal and state ambient air quality standards and localized PM₁₀ concentrations.
• There is documented evidence that PM₁₀ causes serious adverse health affects.
• Sixteen facilities have enclosed their coke piles in compliance with the current Rule 1158. However, an exemption in the Rule allowed seven facilities to conduct outdoor coke storage for a significant period of time. The outdoor storage piles need to be enclosed because of emissions associated with wind erosion and handling, housekeeping, and reentrainment.
• The current Rule 1158 does not include coal and sulfur (which have had problems similar to coke in some instances).
• The current Rule 1158 does not adequately address housekeeping, transport, and handling, all of which can significantly contribute to the emissions problem, which PAR 1158 will address.
• Existing AQMD Rules 401- Visible Emissions, 402- Public Nuisance, and 403- Fugitive Dust are not sufficient to address the unique problems posed by coke, coal and sulfur storage, handling and transport.
• The technology for controlling emissions from these sources is readily available and has been employed by several facilities.
• The current Rule 1158 is difficult to enforce because it is very staff resource intensive, requiring the evaluation of numerous different facility plans, ambient monitoring, interviews with numerous complainants, and requires repeat on-site inspection visits by AQMD staff to evaluate visible emissions.

Proposal

PAR 1158 will reduce emissions of airborne particulate matter from the storage, handling and transport of coke, coal and sulfur between and including the points of origin and final transport; and will reduce the potential for a violation of AQMD Rules 401, 402 and 403.

To address the current deficiencies, proposed amendments to Rule 1158 will (a) expand the scope of this rule by including coal and sulfur; (b) establish clear and specific requirements including a No. ½ Ringlemann opacity limitation during storage, handling and transport operations; (c) reaffirm the requirement that all coke piles be enclosed, and allow optional open storage of prilled sulfur and coal, under an Executive Officer approved plan; (d) set standards for silt loading on roads and truck exteriors; (e) require paving and maintenance of surfaces and roads where material accumulates; (f) require covers or slot-tops for material transport trucks; (g) include end user facilities; (h) require quarterly testing for large facilities; and, (i) set a compliance schedule for facilities that need to construct or modify their facilities.

PAR 1158 will rely on existing technology that is currently employed by some of the facilities. No new technologies will need to be developed.

Facilities subject to PAR 1158 will include oil refineries, transporting operations, facilities involved in the storage and ship loading of these materials at the Los Angeles and Long Beach Harbors, and facilities that use any of these materials as a fuel source in their production operations. There are about 30 such facilities that would be subject to PAR 1158.

Emissions and Cost Effectiveness

Implementation of PAR 1158 will reduce PM₁₀ by 228 tons per year, which is expected to significantly reduce coke/coal related nuisances and complaints, reduce the potential for violating Rules 401, 402 and 403, and reduce incidences of visible fugitive dust fall-out and track-out from truck loads during transport.

Cost effectiveness analysis includes enclosure of piles, even though enclosures can be required under the current Rule 1158. The cost effectiveness calculations also include the costs of enclosing transfer points, conveyor upgrades, achieving silt loading standards (road cleanliness) by use of truck washes and street sweepers, and truck covers. The total cost effectiveness is $11,500 per ton of PM₁₀ reduced. The cost ranges from $30,000 per ton of PM₁₀ reduced for a facility that needs to construct an enclosure to $3,000 for a facility that needs to improve housekeeping.

Public Outreach

Over the last year, the AQMD staff has made about 25 visits to affected facilities, and held about ten meetings with industry, three public meetings in the harbor area, and one public workshop on the rule amendments. AQMD staff also visited a state-of-art facility, Koch Carbon, in Pittsburg, California. In addition, AQMD staff has received numerous letters about the proposed amendments. As a result of this public input, AQMD staff has revised the proposed rule language including developing specialized standards for end users, removing prescriptive requirements in favor of setting standards which give facilities the flexibility of determining the best compliance methods, removing unnecessary inspection and recordkeeping requirements, and allowing open storage of existing coal and sulfur piles under certain circumstances.

CEQA & Socioeconomic Analysis

The AQMD has reviewed PAR 1158 pursuant to CEQA and California Health and Safety Code requirements for Socioeconomic Impact Assessments. An Environmental Assessment was prepared and released for public comment on February 3, 1999. Staff is preparing the socioeconomic assessment which will be made available to the public prior to the AQMD Governing Board’s adoption hearing.

Resource Impacts

PAR 1158 will reduce the administrative burden associated with the current Rule. Thus, it will be easier to implement and no additional staff will be needed.

Attachments

Attachment A: Rule Development Process
Attachment B: Key Contacts
PAR 1158
Draft Staff Report
Socioeconomic Impact Assessment

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