BOARD MEETING DATE: December 5, 2008
AGENDA NO. 27

PROPOSAL:

Amend Rule 1469 – Hexavalent Chromium Emissions from Chrome Plating and Chromic Acid Anodizing Operations

SYNOPSIS:

On October 24, 2007 amendments to the state Airborne Toxic Control Measure (ATCM) for Chromium Plating and Chromic Acid Anodizing Facilities became effective, establishing more stringent requirements to Rule 1469. Rule 1469 is being amended to incorporate the more stringent requirements of the ATCM along with additional housekeeping, monitoring, and testing requirements. Proposed Amended Rule 1469 establishes more stringent requirements for new, modified, and existing facilities, further reducing hexavalent chromium emissions from metal finishing operations.

COMMITTEE:

Stationary Source, October 17, 2008, Reviewed

RECOMMENDED ACTIONS:

Adopt the attached resolution:

1. Certifying the Final Environmental Assessment (EA) for Proposed Amended Rule 1469 – Hexavalent Chromium Emissions from Chromium Electroplating and Chromic Acid Anodizing Operations;
2. Amending Rule 1469 – Hexavalent Chromium Emissions from Chromium Electroplating and Chromic Acid Anodizing Facilities.
    

Barry R. Wallerstein, D.Env.
Executive Officer

Background

In 1986, the California Air Resources Board (CARB) identified hexavalent chromium as a carcinogenic toxic air contaminant. Rule 1469 addresses hexavalent chromium emissions from chromium electroplating and chromic acid anodizing operations. The rule was adopted in 1998 and was last amended in February 2003 through a negotiated rulemaking pilot program. The current rule primarily requires two control efficiencies: an emission rate limit of 0.01 milligrams/ampere-hour, typically achieved by use of in-tank controls, and an emission rate of 0.0015 milligrams/ampere-hour, typically achieved by use of an add-on air pollution control device. The emission rate to be complied with is determined by the facility-wide annual ampere-hour usage in combination with proximities to schools, sensitive receptors and residences.

On October 24, 2007, the California Air Resources Board amended the Airborne Toxic Control Measure (ATCM) for Chromium Plating and Chromic Acid Anodizing Operations. The amended ATCM provides further hexavalent chromium emission reductions by requiring more stringent emission limits for some facilities, and ensures that construction of new facilities are not sited near sensitive receptors. In addition to emission limit changes, the ATCM has also added housekeeping measures. California Health and Safety Code (H&SC) section 39666(d) mandates the South Coast Air Quality Management District (AQMD) to implement and enforce state ATCMs or enforce equally effective or more stringent rules than ATCMs adopted by CARB.
 

Proposal

PAR 1469 is being amended to be consistent with the recently amended ATCM. The amendment will further reduce hexavalent chromium emissions by requiring lower emission limits for some operators and establishing more stringent housekeeping requirements. Additional provisions beyond the ATCM are also being proposed which include more detailed housekeeping requirements and enhanced monitoring, recordkeeping and testing of add-on air pollution control devices. These requirements are intended to ensure compliance and minimize dragout emissions during chromium electroplating and chromic acid anodizing operations.
 

Public Process

During the rule development process, a meeting was held with the Metal Finishing Association of Southern California on September 9, 2008. Additionally, a public workshop discussing Proposed Amended Rule 1469 was held on October 2, 2008. Comments made at the public workshop and written comments received with responses are included in the Staff Report for Proposed Amended Rule 1469.
 

AQMP and Legal Mandates

Proposed Amended Rule 1469 is an air toxic rule that is not an AQMP requirement.
 

Emission Reductions

Implementation of PAR 1469 would result in an environmental benefit due to the further reduction of hexavalent chromium emissions and associated health risk. It is estimated that hexavalent chromium emissions from the affected industry would be reduced by 40 percent through requiring the more stringent emission rate limits of the ATCM. After full implementation of PAR 1469, all facilities are expected to be below the Rule 1402 action risk level of 25 in a million except for a few facilities where further risk reductions will be implemented through Rule 1402.
 

California Environmental Quality Act (CEQA)

Pursuant to California Environmental Quality Act (CEQA) Guidelines §15252 and AQMD Rule 110, the AQMD prepared a Final Environmental Assessment (EA) for the proposed amendments to Rule 1469. The Draft EA concluded 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 from October 9, 2008 and ending on November 7, 2008.  One comment letter was received and responses to all comments were prepared and are included in Appendix C of the Final EA.  Minor modifications were made to PAR 1469 subsequent to the release of the Draft EA. Staff has reviewed the minor modifications to PAR 1469 and concluded that they would not change any conclusions made in the Draft EA or worsen environmental impacts analyzed in the Draft EA.  Therefore, pursuant to CEQA Guidelines §15073.5, recirculation is not required since the information provided does not result in new avoidable significant effects.
 

Socioeconomic Assessment

PAR 1469 incorporates the ATCM requirements and does not further lower emission rate thresholds, and therefore no additional add-on air pollution control devices will be required beyond the ATCM.
 

Based on staff estimates, the additional housekeeping practices and increased monitoring requirements beyond the ATCM would not cause significant costs to the affected facilities. Under PAR 1469, to comply with the capture efficiency testing requirements, the affected facilities are required to conduct periodic smoke tests of their add-on air pollution control devices two times per year. The cost of two smoke tests is estimated to be $65 per facility.
 

Implementation and Resources

Existing AQMD resources will be used to implement Proposed Amended Rule 1469.
 

Attachments (ZIP, 1.68M)

1. Summary of Proposal
2. Key Issues and Responses
3. Rule Development Process
4. Key Contacts List
5. Resolution
6. Proposed Amended Rule 1469 Rule Language
7. Proposed Amended Rule 1469 Staff Report
8. Final Environmental Assessment