BOARD MEETING DATE: February 1, 2002
AGENDA NO. 20

Adopt Proposed Rule 1137 – PM10 Emissions from Woodworking Operations

SYNOPSIS: 

The objective of this new rule is to implement the 1997 AQMP control measure PRC-01 by reducing the amount of PM10 generated from woodworking operations. Facilities that may be affected include lumberyards, cabinet making facilities, furniture manufacturing and other product manufacturing operations. Many facilities currently have cyclones and/or baghouses that reduce PM10 emissions from their operations and will be required to maintain no visible emissions. Proposed rule requirements also include standards for control equipment (at new or expanded facilities), waste collection and disposal activities, enhanced control (i.e., baghouse systems) and facility reporting.

COMMITTEE: 

Stationary Source, December 7, 2001 and January 25, 2002, Reviewed.

RECOMMENDED ACTION:

Adopt the attached resolution:

1. Certifying the Final Environmental Assessment (EA) for Proposed Rule 1137 – PM10 Emissions from Woodworking Operations; and
   
   
2. Adopting Rule 1137 – PM10 Emissions from Woodworking Operations

Barry R. Wallerstein, D.Env.
Executive Officer

Background

The South Coast Air Quality Management District (AQMD) exceeds State and federal ambient air quality standards for PM10 (fine particulate matter less than 10 microns in diameter). Under this designation, the AQMD is required to implement all feasible measures to reduce PM10 emissions from man-made sources in order to attain the standards as expeditiously as practicable. In 1997, the AQMD prepared and adopted an AQMP that included a control measure to reduce PM10 emissions from woodworking operations. The purpose of proposed rule (PR) 1137 is to implement the 1997 AQMP control measure. Types of affected facilities include lumberyards, cabinet making facilities, furniture manufacturing and other product manufacturing operations that generate sawdust.

The 1997 AQMP baseline PM10 inventory for woodworking operations was approximately 7.4 tons per day in 1993 and 9.1 tons per day by the year 2006. A revised emissions inventory estimates that woodworking facilities generate approximately 1.4 tons per day of PM10 based on a revised universe of sources and accounting for in-place emission control devices. In order to claim State Implementation Plan (SIP) emission reduction credits associated with the revised emission estimates, a SIP-enforceable program is required by the U.S. EPA. PR 1137 represents a SIP-enforceable regulation that will control future emissions growth from this source category while taking credit for the PM10 reductions that have already occurred. In addition, because several other air districts, such as in Maricopa County and the San Joaquin Valley, currently have programs to reduce PM from woodworking operations, PR 1137 would also meet federal Clean Air Act expeditious progress requirements.

Public Process

In September 2000, staff distributed an industry survey to potentially affected woodworking facilities. The survey purpose was to gather information on the various kinds of woodworking facilities and types of control devices currently in use. With assistance from the AQMD’s Public Advisor, two focus group meetings were held in which affected industries were asked generalized questions regarding existing efforts to control fine particulate matter. Two presentations were made at Woodwork Institute of California member meetings: the first to provide background information and the second providing an early opportunity to comment on draft rule text. A public workshop was held on September 19, 2001 with approximately fifty attendees and a public consultation meeting was held on January 8, 2002. In addition to these outreach efforts, staff has also made numerous site visits and discussed PR 1137 with AQMD’s Local Government/Small Business and Ethnic Community Advisory Groups.

Proposal

PR 1137 is applicable to facilities that use a pneumatic conveyance system to remove sawdust from process areas and vent the material to the atmosphere. Woodworking facilities that do not use a pneumatic conveyance system are exempt from PR 1137 requirements due to a lower potential to affect PM10 ambient air quality when compared to ducted facilities. Under PR 1137 provisions, existing woodworking facilities will be required to use or continue to use an emissions control device so that there are no visible control device or external ductwork emissions beginning January 1, 2004. Control options include commercially available technologies including, baghouses, high-efficiency cyclones, and cyclones with after filters. PR 1137 will also require best available control technology (baghouse system) for new or expanded facilities on and after July 1, 2002. Best management practices for waste collection and disposal activities are also required on and after July 1, 2002.

In order to assist with compliance activities at existing facilities and to facilitate the evaluation of new or expanded facilities, PR 1137 requires applicable woodworking facilities to submit site information (i.e., operator’s name and contact information, fan [blower] diameter/horsepower, description of emission control device, estimate of sawdust production, and description of sawdust disposal procedures). This information must be submitted by July 1, 2002 for existing facilities and within 90 days of operation of a new or expanded facility. An expanded facility is based on either: 1) a separate pneumatic conveyance system installed subsequent to July 1, 2002 or 2) changes made to an existing pneumatic conveyance system that increase the cubic feet per minute by more than 20 percent over the design capacity that in existence as of July 1, 2002. There are no filing fees associated with the PR 1137 facility reporting requirements. (PR 1137 provisions are summarized in Attachment A.)

Emission Reductions

PR 1137 requirements are oriented towards accounting for emission reductions already achieved as reflected in the revised PM10 emissions inventory, ensuring these current reductions with an enforceable program, and controlling emissions growth. These reductions are estimated at approximately 6.1 tons per day from the previous AQMP baseline of 7.4 tons per day. Since PR 1137 ensures that current control devices are properly maintained and operated to achieve no visible emissions, it is estimated that PR 1137 would further result in emission reductions of an additional 0.09 ton per day by the year 2004. Cost-effectiveness of PR 1137 requirements (based on estimated rule-related reductions of 0.09 ton per day PM10) has been estimated at approximately $3,200 per ton of PM10 reduced.

Policy Issues

As mentioned, the AQMD is required to attain PM10 standards as expeditiously as practicable, which would require that all feasible measures be implemented to reduce PM10 emissions from man-made sources. PR 1137 is necessary as it represents compliance with these mandates and it would allow the region to claim the SIP credit for the reduced PM10 emissions estimates from the woodworking industry. Moreover, PR 1137 will ensure the continuing use of well functioning particulate matter controls (i.e., no visible emission limit); this is a cost-effective, technologically feasible alternative to requiring these facilities to be permitted as done by some other air districts.

In general, industry representatives noted that many of their facilities are already heavily regulated (i.e., AQMD VOC rules, fire department and OSHA regulations, worker compensation requirements, etc.) and expressed concern that new regulations, in addition to other competitive pressures, would affect the economic viability of woodworking operations in the region. Staff believes that since the majority of facilities are already in compliance, only a limited number of facilities are expected to incur increased costs. The Socioeconomic assessment also indicates that the potential impacts from PR 1137 are minimal. Concerning specific PR 1137 requirements, major industry comments pertained to the facility reporting requirements included in the original proposal and the time frame and ability of facilities to comply with a no visible emissions performance standard. In response to these comments, the PR 1137 facility reporting requirements have been streamlined to require basic information that is readily available to facility operators. Additionally, compliance with the visible emissions performance standard has been delayed until January 1, 2004 (previously July 1, 2002) to provide operators more time to evaluate potential facility/control device modifications. Limited exemptions from the no visible emissions performance standards have also been added to address specific situations identified by industry (i.e., emissions during equipment start-up and high-wind conditions).

California Environmental Quality Act (CEQA)

Pursuant to the California Environmental Quality Act (CEQA) and the AQMD’s Certified Regulatory Program (Rule 110), staff has prepared an Environmental Assessment (EA) for PR 1137 – PM10 Emission Reductions from Woodworking Operations. The Draft EA, which was made available for a 30-day public review period, concluded that PR 1137 would not have any significant adverse effects on the environment. No comments were received on the Draft EA. The Final EA is included as Attachment H.

Socioeconomic Assessment

Based on AQMD’s traditional socioeconomic assessment methodology, the total annualized cost of complying with PR 1137 is estimated to be $0.1 million. The impact on profitability will range from a 2 to 20 percent reduction. These changes appear to be well within the annual variation of profits. Due to the low capital costs of the proposed rule, most firms may opt to finance the costs out of internal cash flow rather than borrowing. It is estimated that an average of 1 job could be forgone annually from 2004 to 2015. Profits of the wood products (SIC 24) and furniture and fixtures (SIC 25) industries are expected to decline slightly.

In addition to the mandated socioeconomic assessment prepared for PR 1137, a trial, in-depth facility-based assessment was performed to provide additional information to industry and the decision-makers. Due to the lack of local facility-specific information, national cost data has been used in this analysis. The facility-based assessment examined profiles of affected facilities and firms, and impacts of the proposed rule on financial performance, affordability, and cash flow of representative firms. Facilities that could be potentially affected by PR 1137 belong to the industries of lumber and wood products (SIC 24) and furniture and fixtures (SIC 25). The analysis concluded that local wood product firms face competition from firms outside of the four-county area and would have to absorb the additional compliance costs without passing the costs onto customers.

Resource Impacts

It is anticipated that there will be a temporary workload increase due to AQMD staff processing and evaluating PR 1137 facility reporting information. However, as previously mentioned, the facility reporting information has been streamlined from the original proposal and PR 1137 does not require any continuing facility recordkeeping or submittals (new or expanded facilities would need a one-time submittal of updated facility information). These PR 1137 refinements were made to minimize industry and AQMD staff resources and in response to public comments. No additional AQMD resources are required to implement the PR 1137 requirements.

Attachments (4,862 KB)

1. Summary of PR 1137
2. Rule Development Process
3. Key Contacts
4. Resolution
5. Proposed Rule 1137 Language
6. PR 1137 Final Staff Report
7. Final Socioeconomic Report
8. Final Environmental Assessment

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