Rule 1146 and Rule 1146.1

The South Coast Air Quality Management District (SCAQMD) had a public workshop in late August proposing rule amendments to Rules 1146 and 1146.1. Rule 1146 and 1146.1 apply to boilers, steam generators, and process heaters of equal to greater than 5 million Btu per hour, and greater than 2 million Btu per hour and less than 5 million Btu per hour, respectively. The amendments to these rules are proposed to mainly address concerns raised by the United States Environmental Protection Agency (EPA) for a SIP approvability. The proposed amendments clarify that source test results showing emissions in excess of those rule limits would constitute a violation of these rules (as opposed to the existing rule languages implying that non-compliant source test is not considered a violation if corrected within 72 hours from the time of discovery). A summary of other proposed changes for clarification purpose is included below:

  • Exclude RECLAIM facilities (NOx emissions only) from 1146 and 1146.1 requirements.
  • Revised the definition of boiler or steam generator to not include any open heated tank, adsorption chiller unit, or waste heater recover boiler that is used to recover sensible heat from the exhaust of a combustion turbine or from the exhaust of any combustion equipment.
  • Equipment that use the low fuel usage option are required to perform periodic tune-ups.
  • Derating of equipment is not allowed at or below 2 million BTU/hr to be excluded from the applicable Rule, implying that the equipment would need to be retired, retrofitted to a low NOx burner(s), and/or low fuel option.

Written comments on these amendments were due on Friday, September 13, 2013. Currently, the district is reviewing the comments for consideration. If the SCAQMD receives no major comments, we expect the district to adopt these changes in the near future.

More information can be found at the following links:

Rule 1146 (Proposed)

Rule 1146.1 (Proposed)

Rule 1168 - Adhesive and Sealant Applications

As part of the 2012 Air Quality Management Plan (AQMP) to bring our Basin into attainment with federal health-based standards including, but not limited to unhealthful fine particulate (PM2.5) by 2014, the SCAQMD is looking for areas to reduce/limit emission.

The SCAQMD sent out a survey in an effort to evaluate volatile organic compounds (VOC) from adhesive and sealant applications. The current Rule 1168 (as amended in 2005), already establishes limits for, but not limited to indoor carpet, PVC glue, ceramic, wood adhesives, etc. Several working group meetings have already occurred with the latest one being on September 19, 2013. In conjunction with the survey and working group meetings, the district is trying to get a better understanding of the adhesives industry. The data gathered from these areas may eventually lead to more stringent VOC limits or refinements in adhesive categories.

It is not too late to submit your survey for SCAQMD's consideration as the deadline was extended to September 30th, 2013. Please feel free to contact Trinity Consultants at (949) 567-9880 if you need assistance in the survey. If we have prepared your annual emissions in the past, we can take a look at the regulatory impacts and provide additional suggestions to you before you pass it on to the district.

Please click here for information on the latest meeting.

Rule 1304.1 - Electrical Generating Facility Fee Use of Offset Exemption

Previously, the SCAQMD provided new source review (NSR) offsets to Electrical Generating Facilities (EGFs) which utilized the electric utility steam boiler replacement provision under Rule 1304(a)(2) at no cost. The proposed amended rule is establishing an annual offset fee to be paid by each pollution for each year of offsets. This rule generally affects all electricity generating facilities and directly affects peaker plants. The calculation is based on hours and megawatts generated, which means that EGFs will need to pay for offsets moving forward. Note that this fee only applies to permits issued on or after March 1, 2013. EGFs will now follow a different NSR offset compared to other permitted stationary combustion equipment. The fee proceeds will be invested in air pollution improvement strategies consistent with the 2012 AQMP.

The new spreadsheet broken down by pollution can be seen below. Please see the following links for more information:

Rule 1304.1