South Coast Air Quality Management District

Adopt Rule 1425 – Film Cleaning and Printing Operations

SYNOPSIS: 

Proposed Rule 1425 will reduce air toxic emissions from motion picture film cleaning and printing operations. This proposed rule was developed to implement part of the Air Toxics Control Plan and the source specific measures as part of the adoption of Rule 1402. The proposed rule will also include federal NESHAP requirements.

COMMITTEE: 

Stationary Source, January 26, 2001, Reviewed

RECOMMENDED ACTION:

Adopt the attached resolution:

1. Certifying the CEQA Final Environmental Assessment for Proposed Rule 1425 – Film Cleaning and Printing Operations; and
   
   
2. Adopting Proposed Rule 1425 – Film Cleaning and Printing Operations.

Barry R. Wallerstein, D.Env.
Executive Officer

Background

Proposed Rule (PR) 1425 – Film Cleaning and Printing Operations would implement a control strategy in the Air Toxics Control Plan approved by the AQMD Governing Board in March 2000. It would also implement a directive by the Governing Board in conjunction with amendments to Rule 1402 - Control of Toxic Air Contaminant Emissions from Existing Sources (March 2000). This directive called for the investigation of source-specific rules by March 2003 to regulate eight industries, including motion picture film processing. The Air Toxics Control Plan calls for source-specific rules that are to be based on technically and economically feasible measures in lieu of submitting individual risk reductions plans under Rule 1402.

The motion picture film processing industry uses perchloroethylene (perc) as the primary and most widely used solvent for cleaning and the only solvent used for printing film. The industry is geographically concentrated in the Burbank/Hollywood areas of Los Angeles County. The industry includes approximately 55 facilities with more than 115 film cleaners and 100 film printers. These equipment currently emit about 47,000 pounds of perc per year from film cleaning and 64,000 pounds of perc per year from film printing. Of the total 111,000 pounds of perc emitted per year, 93,000 pounds are emitted into the atmosphere uncontrolled (59,000 pounds from film printing and 34,000 pounds from film cleaning operations). The 34,000 pounds per year of perc from film cleaning are already subject to reductions under applicable federal requirements. However, PR 1425 requires more emission reductions from film cleaning and also applies to film printing. Federal requirements will reduce perc emissions by approximately 12 tons per year and PR 1425 will result in an additional 27.5 ton per year perc emission reduction, for a total of 39.5 tons per year. This is equivalent to an 85 percent overall emission reduction of uncontrolled perc emissions.

Perc has cancer causing health effects, as well as acute and chronic non-cancer health impacts. The non-cancer impacts affect the respiratory and central nervous systems, gastro-intestinal/liver, kidneys, and can cause eye irritation. About 20 facilities may currently exceed the 25 in one million action risk level of Rule 1402.

Proposal

The purpose of PR 1425 is to reduce perc emissions from these operations. The reductions would be achieved with emission controls or use of alternative solvents. The rule requires all film cleaning and printing equipment that emits perc to reduce uncontrolled emissions via add-on air pollution control equipment. Add-on air pollution control equipment would consist of capture and removal devices that reduce the uncontrolled perc emissions by 85 percent.

Facilities may also comply by one of the alternative compliance methods either demonstrating equivalent emission reductions on a facility-wide basis or by taking a facility-wide cap on total perc emissions. This first option would allow facilities to demonstrate an overall level of compliance equivalent to 85 percent overall control efficiency. The second alternative compliance method is a facility-wide emissions cap based on conservative assumptions of potential exposure to the nearest receptor to allow small usage, while protecting public health.

PR 1425 requires compliance with federal requirements under the National Emission Standards for Hazardous Air Pollutants (NESHAP) for halogenated solvent cleaning, which is applicable to film cleaning using perc. There are no federal requirements for controlling emissions from film printing.

Compliance with PR 1425 is expected to reduce cancer risk below 25 in one million for most, if not all, facilities. The rule includes a technical assessment to be conducted within 5 years of rule adoption to investigate further risk reduction measures. This investigation would focus on any facilities, after control, having residual risks greater than 25 in one million.

Public Input

During the development of PR 1425, staff worked with a Technical Subcommittee for Motion Picture Film Processing. This Technical Subcommittee was comprised of representatives from potentially affected facilities, equipment manufacturers, chemical manufacturers, and consultants. All potentially affected facilities were invited to participate in the rule development process. Six Technical Subcommittee meetings were held. A Public Workshop was held on November 15, 2000 with approximately 30 persons attending.

Key Issues

Several issues were raised and addressed during the rule development process. These include technical feasibility for emission reductions, collection efficiency for optical wet-gate printers and providing flexible compliance options. Each of these issues has been resolved satisfactorily. Attachment B provides additional information on these issues.

California Environmental Quality Act (CEQA) and Socioeconomic Analysis

Pursuant to the California Environmental Quality Act (CEQA) and AQMD Rule 110, the AQMD has prepared a Draft Environmental Assessment (EA) for the proposed adoption of Rule 1425. The Draft EA concludes that implementation of the proposed project would not result in significant adverse environmental impacts. The Draft EA was released for a 30-day public review and comment period. Comments were received on the Draft EA and the responses are included in the Final EA. The Final EA has been prepared and is included as part of this board package.

Proposed Rule 1425 would affect 40 film cleaning and printing facilities. Of these 40 facilities, 10 facilities have existing add-on controls and thus meet the requirements of the proposed rule. Nine out of the remaining 30 affected facilities conduct both film cleaning and printing operations and the remaining 21 facilities conduct film cleaning only.

All the affected facilities are also subject to the NESHAP requirements. The proposed rule’s more stringent requirements for film cleaning operations and the proposed rule’s requirements for film printing will increase the needed capacity of control devices beyond what is called for in the NESHAP for the 21 film cleaning and nine film cleaning and printing operations. The total annualized costs of the proposed rule range from $166,600 to $392,600.

AQMP and Legal Mandates

Proposed Rule 1425 is an air toxic rule that would implement part of the Air Toxics Control Plan and the source specific measures the Board directed staff to evaluate as part of the adoption of Rule 1402. The proposed rule also includes requirements to ensure compliance with the federal NESHAP applicable to halogenated solvent cleaning.

Implementation Plan

Existing AQMD resources will be used to implement the new rule. AQMD permit processing engineers and compliance personnel are already permitting and enforcing current applicable requirements for the motion picture film industry. These staff will be trained on the new requirements established under PR 1425.

Attachments (5,868 KB)

Summary of Proposal
Key Issues and Responses
Rule Development Process
Key Contacts List
Resolution
Proposed Rule 1425
Staff Report

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