AIR QUALITY

Air District, Materials Producers Work Together for Air Quality

By Suzanne Seivright, Director of Regional Government Affairs and Grassroots Operations, CalCIMA

CalCIMA members and South Coast AQMD staff had the necessary information to create a rule that minimized operational disruptions at industry facilities while allowing the agency to account for surplus emissions reductions from industry. This included several industry-led virtual facility tours.

South Coast Air Quality Management District’s (AQMD) Governing Board approved Rule 1147.1 ‘Aggregate Dryers’ that aims to reduce nitrogen oxide (NOx) and carbon monoxide (CO) pollutants from industrial drying equipment. The rule was developed in response to the phase-out of South Coast AQMD’s ‘Regional Clean Air Incentives Market (RECLAIM)’ program and to meet BARCT development deadlines under AB 617.

CalCIMA members operate local plants and facilities throughout the region, producing aggregate, concrete, asphalt, and industrial minerals. These materials are all necessary to California’s infrastructure, among other essential uses. Over the course of years, CalCIMA members engaged with South Coast AQMD staff to help develop this new rule to regulate burners used to dry aggregate. CalCIMA member participation and education of South Coast AQMD staff was vital to the rulemaking process. CalCIMA members helped ensure that South Coast AQMD had the necessary information to create a rule that minimized operational disruptions at industry facilities while allowing the agency to account for surplus emissions reductions from industry. This included several industry-led virtual facility tours.

Rule 1147.1 can be a costly rule to comply with since it can trigger significant upgrades at facilities. The rule is not only limited to the combustion equipment that will need to be replaced but also inclusive of the overall facility designs that will need to be overhauled to accommodate the new combustion equipment. As a result, land entitlements may need to be addressed, and CEQA may be triggered in relation to these entitlements. Additionally, AB 617 speeds up the compliance process adding another costly layer of complexity.

South Coast AQMD and the construction materials industry efforts to address critical rulemaking issues was vital to maintaining operations and maximizing the reduction of emissions in communities. These efforts led to the development of a

rule that maximized the continuity of most facilities while achieving environmental and health improvements as required by law. Significant knowledge sharing between industry and South Coast AQMD staff occurred during the frequent and intense rulemaking discussions. As a result of the collaboration, Rule 1147.1 meets most stakeholders’ interests.

Rule 1147.1 impacts around 33 aggregate facilities representing around 92 pieces of equipment. Of this population, approximately 21 different asphalt companies have units impacted, equating to about 48 dryers.

The table below highlights key components of the new rule.

For additional information please visit South Coast AQMD’s website at http://www.aqmd.gov/ home/rules-compliance/rules/ scaqmd-rule-book/proposedrules/rule-1147-1. n

Topic

Definition – Aggregate Material

Definition – Aggregate Dryer

BARCT limits - NOx

Rule Language

“Particulate materials used in construction and industrial manufacturing, including recycled concrete, recycled asphalt, and quarried materials such as sand, gravel, and crushed stone.”

“Any combustion equipment fired with gaseous fuel used to reduce or minimize the moisture content of aggregate material, including dryers, rotary dryers, fluidized bed dryers and rotary kilns.”

30PPM NOx.

BARCT limit – CO

Trigger for compliance

1000PPM CO.

Units with existing permit limit ≤40PPM – By July 1 after the year burner is 32 years old.

All other units with burners installed prior to 2009 – By July 1, 2022.

All other units with burners installed on or after 2009 – By July 1 after the year burner is 12 years old. Implementation schedule for operators of multiple facilities 18 months after the permit to construct is issued.

Implementation schedule for new replacements instead of retrofits

Units to be replaced would be given 36 months to permanently shut down to provide operators additional time to manage installation of the new unit.

≥40MBtu/hr – conduct source testing every year but no earlier than 6 months after the previous source test.

≥10MBTU/hr and less than 40MBTU/hr – conduct source test every 3 calendar years.

<10MBtu/hr – conduct a source test every 5 years but no earlier than 54 calendar months after the previous source test.

Monitoring – Source testing

Shut Down Provision

On or before 36 months after the date a permit application is due pursuant to the date compliance is triggered.

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