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California Environmental News

MDAQMD Proposed Adoption of the 2015 8-Hour RACT SIP Analysis

Wednesday, February 25, 2015

The Mojave Desert Air Quality Management District (MDAQMD) is proposing the adoption of an updated 2015 8-Hour Reasonably Available Control Technology - State Implementation Plan Analysis (RACT SIP Analysis). Effective May 27, 2008, the United States Environmental Protection Agency's (USEPA) lowered the primary ozone National Ambient Air Quality Standard (NAAQS) from 0.084 parts per million (ppm) to 0.075 ppm. As a result, portions of the MDAQMD have been designated non-attainment for ozone and classified as Severe-15 for the new 8-hour ozone standard.

The shift to the lower NAAQS standard prompted the USEPA to require all non-attainment areas to submit an updated RACT SIP Analysis. The purpose of the updated RACT SIP Analysis is to ensure that the district rules adequately comprehend and detail the current effective RACT requirements. Therefore, the MDAQMD has assessed the district rules and all of its major sources of ozone precursors to ensure that the current rules satisfy RACT, as defined by USEPA.

It is important to note that this RACT SIP Analysis draws upon the 2006 RACT SIP Analysis, and the 2014 Supplement which were previously submitted to the USEPA for review. The current RACT SIP Analysis, therefore, provides a complete determination of the MDAQMD’s obligations. The MDAQMD has determined that the following rules will require amendments under this latest RACT SIP analysis: Rule 461, 462, 463, 464, 1104, 1106, 1114, 1115, 1118, 1157, 1158, 1160, 1161, and 1162.

For more information regarding the updates, click here.

SJVAPCD Proposes Increases to District Fees

Wednesday, February 25, 2015

San Joaquin Valley Air Pollution Control District (SJVAPCD) is proposing to amend rules under Regulation III to increase fee rates and schedules associated with regulatory obligations of the District. The proposed fee increases are designed to remedy the District’s ongoing shortfall in revenue. Specifically, the District is proposing to amend the following rules with associated fees: Rule 3010 Permit Fee, Rule 3020 Permit Fee Schedules, Rule 3030 Hearing Board Fees, Rule 3040 Open Burning Fees, Rule 3050 Asbestos Removal Fees, Rule 3060 Emission Reduction Credit Banking Fee, Rule 3070 Other Charges, Rule 3110 Air Toxics Fees, Rule 3120 Regulation VIII Alternative Compliance Plan Review Fee, Rule 3135 Dust Control Plan Fee, Rule 3140 Fees for Certification of Air Permitting Professionals, Rule 3147 Fees for Certification of Gasoline Dispensing Facility Testers, Rule 3150 Fees for Portable Equipment Registration, Rule 3155 Permit-Exempt Equipment Registration Fees, Rule 3160 Prescribed Burning Fee, Rule 3180 Administrative Feesfor Indirect Source Review, and Rule 3190 Conservation Management Practices Plan Fee.

In general, the proposed amendments will increase fees in two stages: first, a 4.8% increase effective on July 1, 2015; and, second, a 4.4% increase effective on July 1, 2016. These increases will not affect hourly fees associated with compensating the District for time spent on various activities (e.g., processing a permit application). Hearing Board fees will be increased in the same manner prescribed above, plus proposed amendments to Rule 3030 would also impose an excess emission fee of $2.50 per pound to each variance with excess emissions. The proposed amendments to Rule 3040 would increase the annual agricultural/open burning fee from $26 to $36 per location, and increase the burn day exemption fee from $36 to $50. Finally, the proposed amendments to Rule 3050 would increase the asbestos removal fees by 37%.

Written comments regarding these proposed amendments are due by March 3, 2015. More information can be found here.

ARB’s Consumer and Commercial Products Survey Deadlines and Extensions

Wednesday, February 25, 2015

The California Air Resources Board (ARB) is conducting a mandatory Consumer and Commercial Products Survey to gather data regarding consumer and commercial products that were supplied or sold for use in California during calendar years 2013 through 2015.

The deadlines for the surveys are as follows:

  • 2013 Survey:
    • Responsible Party – March 2, 2015
      • Small Businesses – July 1, 2015
    • Formulators – April 1, 2015
  • 2014 Survey:
    • Responsible Party and Formulators – November 1, 2015

Small businesses and formulators have been granted an extension for the 2013 survey due to insufficient time to collect data and do not need to submit any extension requests. A small business is defined as a company with 25 or fewer full-time, part-time, and contract employees combined. All responsible parties have the option to request an extension of the original due date for the 2013 survey. These requests must be emailed to by February 27, 2015. More information on extension requests can be found here.

For more information or assistance regarding this survey, contact Trinity at (949) 567-9880.

SCAQMD Proposed Amended Rule 1148.1 - Oil and Gas Production Wells

Wednesday, February 25, 2015

The South Coast Air Quality Management District (SCAQMD) is proposing to amend Rule 1148.1 - Oil and Gas Production Wells, in order to reduce nuisance and potential exposure near sensitive receptors. Rule 1148.1 applies to onshore oil producing wells, well cellars, and produced gas handling operation and maintenance activities. The amended rule would strengthen the regulatory language, add odor prevention measures and monitoring, and set-up a tiered requirement system based on sensitive receptor proximity and how many odor complaints a facility has received in the past 12 months. The highest tier would require an Odor Mitigation Plan for sources within 1,500 feet of a sensitive receptor who have experienced five (5) confirmed odor complaints within prior 12 month, or received a Notice of Violation (NOV) for odor. The proposed amendment would also expand the definition of Sensitive Receptor by including residential homes along with K-12 schools, hospitals, daycare centers, and convalescent homes. By including residences as sensitive receptors plus adding new odor mitigation and other requirements, SCAQMD hopes to lessen the amount of odor complaints it receives from the operation of oil and gas production wells.

The SCAQMD has held two working group meetings regarding this amendment, and a public hearing will be held in quarter two of 2015.

For more information regarding this amendment and future compliance, please click here for more information.

VCAPCD Adopted Rule 74.33- Liquefied Petroleum Gas Transfer or Dispensing

Wednesday, February 25, 2015

On January 13, 2015, the Ventura County Air Pollution Control District (VCAPCD) adopted new Rule 74.33, Liquefied Petroleum Gas (LPG) Transfer or Dispensing. The new rule will help to reduce emissions of reactive organic compounds (ROC) from the transfer, dispensing, mobile fueling, and bulk loading of LPG. Expected to achieve ROC reductions of 104 tons per year, this new rule applies to any transfer of LPG to or from cargo tanks, stationary and portable storage tanks, and cylinders, excluding those on recreational vehicles. Operations affected by Rule 74.33 include forklift filling, retail sales, residential heating, vehicle filling, commercial operations, industrial operations, tank degassing operations, portable asphalt plants, LPG bulk plants and LPG storage, and dispensing facilities. However, LPG truck loading facilities subject to Rule 71.3 (Transfer of ROC Liquids) and Rule 74.10 (Components at Crude Oil and Natural Gas Production and Processing Facilities) are exempt from this rule. In addition, the proposed rule would not apply to the transfer of LPG into any container having a water capacity of less than four (4) gallons.

Effective July 1, 2015, ROC emissions from fugitive sources will be reduced through the requirement of Low-Emission Fixed Liquid Level Gauges (FLLG), also known as bleeder valves, and Low Emission Connectors. For LPG Bulk Loading Facilities, a vapor recovery or equalization system will be required to recover LPG vapors. This rule also establishes a Leak, Detection, and Repair (LDAR) program for LPG Bulk Plants and Storage and Transfer Facilities, which involves daily and monthly inspections using approved methods.

The new rule also establishes a series of record keeping and reporting requirements. Records of FLLGs and Low Emission Connectors installed must be kept for five years, along with the equipment specifications to show compliance with this rule. By July 1, 2017, all LPG bulk facilities must perform an inventory for 2016 of all Low Emission Connectors and mobile fuelers on site. This inventory will continue annually until 2020 and each inventory report is due on July 1 of the following year.

For more information regarding compliance with this rule, please contact Trinity at (949) 567-9880 or click here for more information.

Ventura County APCD Proposed Revisions to Rule 74.15.1- Boilers, Steam Generators, and Process Heaters

Friday, January 23, 2015

The Ventura County Air Pollution Control District (VCAPCD) is proposing revisions to Rule 74.15.1 Boilers, Steam Generators, and Process Heaters, in order to reduce Oxides of Nitrogen (NOx) emissions to help attain the state ambient ozone air quality standards. This rule applies to boilers, steam generators, and process heaters with a rated heat input capacity below 5 million BTUs per hour and greater than or equal to 1 million BTUs per hour.

The proposed changes to this rule include more strict NOx emission limits of 12 ppm for natural gas fired units using atmospheric combustion and 9 ppm for all other natural gas fired units. Atmospheric combustion includes units using a non-sealed combustion chamber where natural draft is used to exhaust gases. These lower limits will only apply to new or replaced boilers, steam generators and process heaters with ratings between 2 and 5 million BTUs per hour and the limitations will become effective January 1, 2016. The lower NOx limit has the potential to affect approximately 44 existing emission units within VCAPCD jurisdiction upon replacement.

The rule revision includes new emission screening deadlines and additional methods for submitting notifications to VCAPCD. An alternative test method has also been added, which allows the use of South Coast Air Quality Management District’s Compliance Protocol, found here. Additional exemptions have been updated to include units fired by landfill gas, biogas, or liquefied petroleum gas, and certain portable combustion equipment. Staff is also proposing to update the definition of process heater to exclude certain combustion equipment. Click here to see the list of potential exempt equipment.

VCAPCD will be holding a public consultation meeting regarding the proposed revisions to this rule on February 12, 2015 at 10 am. For more information regarding future compliance with this rule and the public consultation meeting, please contact our office at (949) 567-9880 or click here for more information.