BOARD MEETING DATE: March 4, 2005
AGENDA NO. 31
Adopt Proposed Rule 1469.1 – Spraying Operations Using Coatings Containing Chromium
SYNOPSIS:
Proposed Rule 1469.1 – Spraying Operations Using Coatings Containing Chromium will reduce chromium emissions from processes that spray primers or coatings containing hexavalent chromium. Reductions of hexavalent chromium and potentially other toxic emissions would occur through adding new or upgrading existing control equipment.
COMMITTEE:
Stationary Source, July 23, 2004 and January 28, 2005, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
- Certifying the Final Environmental Assessment (EA) for Proposed Rule 1469.1 – Spraying Operations Using Coatings Containing Chromium; and
- Adopting Rule 1469.1 – Spraying Operations Using Coatings Containing Chromium.
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Proposed Rule (PR) 1469.1 – Spraying Operations Using Coatings Containing Chromium is designed to reduce chromium emissions from spraying operations using coatings and primers containing hexavalent chromium. Coatings containing hexavalent chromium and chromate-based primers are used primarily as an anti-corrosion agent in the aerospace industry. Spraying operations involving hexavalent chromium are normally conducted inside of a spray booth, and are controlled by combinations of conventional spray booth filters, multi-stage filters or high efficiency particulate arrestor (HEPA) filters.
Hexavalent Chromium
In January 1986, the CARB identified hexavalent chromium as a toxic air contaminant in accordance with Health and Safety Code (H&SC) section 39650, et seq. Hexavalent chromium is used as a pigment in paints, inks and plastics; as an anti-corrosion agent in protective coatings, and in chrome plating. Processes emitting hexavalent chromium have become increasingly regulated in the recent past. Hexavalent chromium is a potent carcinogen which was identified as a key toxic air contaminant (TAC) in the AQMD’s second Multiple Air Toxics Exposure Study (MATES II), conducted in 1998-99.
Hexavalent Chromium Operations
There are three types of industrial operations that emit hexavalent chromium, including chrome plating and chromic acid anodizing, thermal spraying, and conventional spraying of primers and coatings containing chromates. PR 1469.1 addresses the third type of operation. During development of Rule 1469 - Hexavalent Chromium Emissions from Chrome Plating and Chromic Acid Anodizing Operations, ambient monitoring was conducted near several chrome plating facilities. The monitoring results showed elevated hexavalent chromium concentrations that could not be attributed to plating operations, and were presumed to come from chrome spraying operations. This rule development effort was undertaken to address chrome spraying operations where they are currently under-controlled, resulting in emissions of hexavalent chromium that may potentially create high risk levels.
An Air Toxics Control Measure (ATCM) has been developed by CARB to address emissions from thermal spraying operations. Thermal spraying is not addressed in PR 1469.1.
Industry Characterization
Based on the AQMD permit database, an estimated 70 facilities representing 93 spray booths use primers or coatings containing hexavalent chromium. The largest industry groups include Aircraft – 31%, Electroplating – 29%, and Coating & Engraving – 21%. These three industry groups comprise over 80% of the facilities subject to PR 1469.1. It is likely that many facilities with a primary standard industrial classification (SIC) code indicating electroplating or coating operations are job shops, manufacturing parts for the aerospace industry.
Of the 70 facilities that are affected by PR 1469.1, 20 facilities may also be currently subject to Rule 1469 - Hexavalent Chromium Emissions from Chrome Plating and Chromic Acid Anodizing Operations. In addition, there is one facility that both sprays chromated coatings, and uses chromium in a thermal spraying process. There are also seven facilities within the potential PR 1469.1 universe currently subject to the federal National Emission Standards for Hazardous Air Pollutants for Aerospace Manufacturing and Rework Facilities (Aerospace NESHAP).
Proposal
Proposed Rule 1469.1 applies to spraying operations that are using primers or coatings that contain hexavalent chromium. Operations using hand application methods of chromate based primers or coatings, and thermal spraying operations are not applicable to the proposed rule. Proposed Rule 1469.1 establishes enclosure requirements, requirements for transfer efficiency, and housekeeping requirements. The core requirements under PR 1469.1 are presented as three options. An owner or operator of a facility can select one of the following three options to demonstrate compliance: Option A: Annual Emission Limit; Option B: Installation of HEPA Filters or Better; or Option C: Facility-wide Risk Limit. Affected facilities must demonstrate compliance with either Option A, B, or C on or before July 1, 2007.
Option A is applicable to facilities that have no other hexavalent chrome operations, such as plating, thermal spraying, etc. Under this option, the facility must demonstrate that annual emissions are below a specific threshold depending on the distance to the receptor and the type of receptor. If the facility is greater than 25 meters (82 feet) from a residential or sensitive receptor, the owner or operator of the facility is required to not exceed an annual emission limit of 0.018 pounds of hexavalent chromium per year. This emission limit is adjusted upwards, depending on the distance to the nearest residential or sensitive receptor. If the facility is 25 meters (82 feet) or less from a residential or sensitive receptor or within 100 meters (328 feet) or less from an existing school, the annual emission limit is 0.007 pounds per year.
Under Option B, the owner or operator of a facility would be required to ventilate each source to an air pollution control equipment with a rated particulate filtration efficiency of 99.97% or higher, for particulate matter 0.3 microns or larger. This essentially would require the facility to install HEPA controls or better on all spray booths that are using chromate based primers or coatings.
Under Option C, a facility would need to demonstrate that they could achieve an overall facility-wide risk level depending on the distance to the receptor and the type of receptor. If the facility is greater than 25 meters (82 feet) from a residential or sensitive receptor, the owner or operator of the facility is required to achieve a facility-wide risk level less than 25-in-a-million. If the facility is 25 meters (82 feet) or less from a residential or sensitive receptor or within 100 meters (328 feet) or less from an existing school, a facility-wide cancer risk level of less than 10-in-a-million must be achieved.
PR 1469.1 also includes an exemption for touch up and repair operations provided emissions from these operations are accounted as part of the emission limit or facility-wide risk. In addition, PR 1469.1 also includes monitoring, recordkeeping, and reporting requirements.
Risk Reduction
Based on a Tier 2 screening analysis of cancer risk, 19 facilities have a cancer risk exceeding 25-in-a-million. 14 of these 19 facilities have estimated risks well over 100-in-a-million. Implementation of PR 1469.1 is expected to reduce the cancer risk for most affected facilities to below 25-in-a-million.
Public Input
A working group of representatives from industry, small business, the environmental community, and CARB met four times during development of PR 1469.1. A Public Workshop and CEQA Scoping Session was held on August 1, 2004. Additionally, a Public Consultation Meeting was held on January 20, 2005. Approximately 25 people attended each meeting. Public comments were received at both meetings, and all comments responded to in the Staff Report.
Key Issues
An industry representative has commented regarding the bioavailability of hexavalent chromium present in paint particles, and has stated that there is no evidence of harmful health effects from spraying of primers or coatings containing hexavalent chromium because the chromium is encapsulated within the paint particle. However, the Office of Health Hazard Assessment (OEHHA) has identified hexavalent chromium as a human carcinogen and has indicated that there is a potential for bioavailability of hexavalent chromium emitted in paint particles. In addition, source test data indicate hexavalent chromium emissions are present from coating operations using chromate primers.
California Environmental Quality Act (CEQA)
Pursuant to California Environmental Quality Act (CEQA) Guidelines §15252 and AQMD Rule 110, the AQMD has prepared a Draft Environmental Assessment (EA) for Proposed Rule 1469.1. The Draft EA concluded that implementation of the proposed project would not result in significant adverse environmental impacts. The Draft EA was circulated for a 30-day public review and comment period that closed on February 23, 2005. No comments were received on the Draft EA. The Final EA has been prepared and is included as an attachment to this Governing Board package.
Socioeconomic Assessment
A socioeconomic assessment is included as part of the Board package. Proposed Rule 1469.1 would affect approximately 70 facilities in the four-county area. The largest industry groups affected include aircraft (SIC 3721), aircraft engines and engine parts (SIC 3724), aircraft parts and auxiliary equipment (SIC 3728); coatings, engraving and allied services (SIC 3479), and electroplating, plating, polishing, anodizing and coloring (SIC 3471). Of the 70 affected facilities, 51 are located in Los Angeles, 13 in Orange County, three in Riverside County, and three in San Bernardino County.
The total annual cost of the proposed Rule 1469.1 is estimated at $0.54 million. The majority of the estimated annual cost will be borne by 17 facilities expected to add controls under the proposed rule requirements. Based on the compliance costs of the proposed rule and application of the AQMD’s regional economic model, it is estimated that an average of 15 jobs could be forgone annually. The job impact is within the noise of the REMI model.
AQMP and Legal Mandates
Proposed Rule 1469.1 is not an AQMP requirement or a legal mandate, nor is it a control strategy in the AQMD’s Air Toxics Control Plan.
Resource Impacts
Existing AQMD resources will be used to implement PR 1469.1. AQMD inspectors routinely inspect facilities conducting spray coating operations. AQMD resources will be used for evaluation of permits required for new control equipment, for review of Compliance Plans required by the proposed rule, and to provide technical assistance to facility operators in assessing risks and evaluating compliance options.
AQMD staff will make an effort to streamline internal procedures to accommodate the additional work within existing resources. Implementation of the proposed rules is not expected to have an impact on AQMD fiscal resources. No additional staff is requested.
Summary of Proposal
Key Issues and Responses
Rule Development Process
Key Contacts List
Resolution
Proposed Rule 1469.1
Staff Report (Includes Final Socioeconomic Report)
Final Environmental Assessment (EA) for Proposed Rule 1469.1 – Spraying Operations Using Coatings Containing Chromium
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