South Coast Air Quality Management District
South Coast Air Quality Management District
BOARD MEETING DATE: September 15, 2000 AGENDA NO. 34
Proposed Rule 1131 – Food Product Manufacturing and Processing Operations
SYNOPSIS:
Proposed Rule 1131 will reduce VOC emissions from food manufacturing and processing operations by limiting the VOC content of process solvents and solvents used for sterilization of equipment; or requiring control equipment; or requiring equivalent reductions through reformulation or process modifications. Affected operations include distillation, extraction, reacting, blending, drying, crystallizing, granulation, separation, sterilization, and filtering.
COMMITTEE:
Stationary Source Committee, July 28, 2000, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Volatile organic compound (VOC) emissions from stationary and mobile sources significantly contribute to the formation of smog in the South Coast Air Basin. The VOCs react with oxides of nitrogen and other compounds to form ozone in the atmosphere. Ozone, a criteria pollutant, has been shown to cause adverse health. Ozone also contributes to the formation of another criteria pollutant, PM10.
Past emission inventory work on several District projects has led to the discovery of large amounts of solvent usage (primarily isopropyl alcohol) at several food manufacturing facilities. The solvents are in extraction, blending, crystallization, and drying processes as well as the sterilization of food manufacturing equipment. In past years, many operations and equipment used in the food manufacturing industry were exempt from requiring a permit from the District. Though permit exempt, emissions from such equipment and operations can be significant and as high as 300 tons per year at a single facility. The District has had no source specific Regulation XI rule to control VOCs in the food manufacturing industry and the use of organic solvents at these facilities have been subject to Rule 442.
The discovery of these emission sources and the establishment of AQMP control measure #99PRC-06 – Further Reductions From Industrial Processes, has prompted the need to develop a source specific regulation for this industry. The proposed regulation is Rule 1131- Food Product Manufacturing and Processing Operations. Additionally, in May 2000, the District amended Rule 219 – Equipment Not Requiring a Written Permit Pursuant to Regulation II. This amendment requires food manufacturing and processing operations to have written permits if organic solvents are used. Thus, equipment subject to the new regulation will be evaluated for compliance through the permit system and will ensure the emission reduction goals of the rule are achieved.
A Rule 1131 Advisory Panel was formed at the start of this rulemaking effort in February 2000 with experts from the food manufacturing sector, consultants, and the public. AQMD staff met with the panel on several occasions to obtain and discuss relevant information and technologies involving food manufacturing operations prior to drafting a rule proposal. Staff also visited several facilities to observe various food manufacturing processes including operations at a facility that already had plans for installing control equipment.
Proposal
The purpose of Rule 1131 is to reduce emissions of Volatile Organic Compounds (VOCs) from the use of solvents in food product manufacturing and processing operations. Food products are considered to be any combination of carbohydrates, proteins, or fats intended for human consumption. Colorings, flavorings, spices and extracts that are manufactured and subsequently used in the preparation of human consumable foods are considered to be food products.
Food processing and manufacturing operations include:
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The VOC content requirements for Proposed Rule 1131 are:
The requirements are effective October 1, 2002 (except for the 200 g/l sterilization requirement) and will provide sufficient lead time for implementation and optimization.
In lieu of complying with the VOC limits for process and sterilization solvents, VOC air pollution control equipment may be used provided that the collection efficiency is at least 90% and the destruction efficiency is at least 95 percent (85.5 % overall). Additionally, facilities may achieve compliance by demonstrating an 85.5% reduction from product reformulation and/or process changes, or the development of innovative technologies.
Staff estimates that these requirements will achieve VOC emission reductions of over 2 tons per day in 2002 from a total inventory of 617 tons/year, assuming 250 operating days per year.
Rule 1131 also includes several general housekeeping and recordkeeping requirements. Equipment with leaks, visible tears, or cracks that result in VOC emissions to the atmosphere must be repaired within 48 hours or the equipment shall be drained of all solvent and shut down until replace or repaired. Records must be maintained for any equipment with a leak, visible tear, or crack. The record shall contain the date and time the leak, crack or tear was detected, as well as the time and date the equipment was repaired. Additionally, records for solvents used in operations subject to the rule must be kept pursuant to District Rule 109.
Several food product manufacturing and processing industries that are regulated under other District rules and regulations will be exempt from the requirements of Proposed Rule 1131. These include:
Additionally, Proposed Rule 1131 does not apply to:
A monthly exemption threshold is proposed in order that facilities meeting the exemption could exercise the monthly recordkeeping option in Rule 109. VOC emissions from breweries, wineries, and distilleries are from fermentation processes and not from direct solvent use and require separate analysis. VOC emissions from deep-fat frying operations are negligible but particulates from such operations are significant and are controlled by other District rules.
California Environmental Quality Act (CEQA) Analysis
Pursuant to California Environmental Quality Act (CEQA) and the AQMD’s Certified Regulatory Program (Rule110), staff has prepared an Environmental Assessment (EA) for Proposed Rule 1131 – Food Product Manufacturing and Processing Operations. The Draft EA, which was made available for a 30-day review period, concluded that the adoption of Proposed Rule 1131 would not have any significant adverse effect on the environment. No comments were received on the Draft EA. The Final EA is included as part of the attached package for the public hearing on the proposed rule.
Socioeconomic Analysis
Proposed Rule 1131 affects large and small manufacturers of food products. The larger sources primarily manufacture flavorings, spices, or other food additive products. These few large sources constitute a large fraction of the total emission inventory. The smaller facilities include a wider scope of industries in the local economy. The total cost impact from the requirements of Proposed Rule 1131 is estimated at $2.38 million annually. This cost represents less than 0.0001 percent of the average projected value of output in the four-county area for the period of 2002 – 2015. The cost-effectiveness of the proposed amendments is estimated to be $4,732 per ton. This cost-effectiveness value is within the range of recently adopted VOC rules.
It is further estimated that approximately 7 jobs will be foregone annually, which is less than 0.001 percent of the total jobs in the four-county area for the period of 2002 – 2015. The food manufacturing sector (SICs 20) is projected to experience approximately 10 jobs foregone annually.
AQMP and Legal Mandates
The California Health and Safety Code requires the AQMD to adopt an Air Quality Management Plan to meet state and federal ambient air quality standards in the South Coast Air Basin. In addition the California Health & Safety Code requires that the AQMD adopt rules and regulations that carry out objectives of the AQMP. The requirements of Proposed Rule 1131 are consistent with the guidelines set forth in the AQMD control measure #99PRC-06- Further Reductions From Industrial Processes.
Implementation Plan
All potential sources have been noticed of the proposed requirements. Should Rule 1131 be adopted, all sources that must comply will be notified through the AQMD’s outreach effort. The smaller facilities will most likely meet the exemption threshold provided in the rule. Therefore, no additional implementation actions are expected to be necessary.
Resource Impacts
Implementation of Proposed Rule 1131 can be accomplished with no adverse impact on AQMD resources or budgets.
Summary of Proposal
Key Issues and Responses
Rule Development Process
Key Contacts List
Resolution
Proposed Rule Language
Staff Report
Final Environmental Assessment
Socioeconomic Assessment
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