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Control of Emissions from Metal Grinding Operations at Metal

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Control of Emissions from Metal Grinding Operations at Metal BOARD MEETING DATE: March 3, 2017 AGENDA NO. 36 PROPOSAL: Proposed Rule 1430 – Control of Emissions from Metal Grinding Operations at Metal Forging Facilities SYNOPSIS: Proposed Rule 1430 will reduce particulate matter and toxic emissions and help to reduce odors from metal grinding and cutting operations at forging facilities. Metal grinding and cutting operations are currently exempt from SCAQMD permits. Based on monitoring, sampling, and site visits, metal grinding at forging facilities can be a significant source of metal particulate emissions, some of which are also toxic air contaminants. The proposed rule will prohibit forging facilities from conducting grinding and cutting operations in the open air and includes requirements to vent metal grinding and cutting operations to emission control devices, to meet a specified emission standard for the emission control devices, conduct metal grinding and cutting operations in a building enclosure to reduce fugitive emissions, and implement a series of housekeeping measures to further minimize fugitive emissions. COMMITTEE: Stationary Source, January 20, 2017, Reviewed RECOMMENDED ACTIONS: Adopt the attached resolution: 1. Certifying the Final Environmental Assessment for Proposed Rule 1430 – Control of Emissions from Metal Grinding Operations at Metal Forging Facilities; and 2. Adopting Rule 1430 – Control of Emissions from Metal Grinding Operations at Metal Forging Facilities. Wayne Nastri Executive Officer PF: SN:EK:DG Background Metal grinding operations at metal forging facilities are unique, based on the magnitude and power of the grinding equipment, combined with the intensity of the grinding operations. Metal grinding and cutting operations are currently an unregulated source. As such, some metal forging facilities conduct metal grinding and cutting operations in the open air with no pollution controls, while other facilities have pollution controls, however, there are no requirements to ensure these controls are properly operated and maintained. Air monitoring and sampling has shown metal particulate, some of which are toxic air contaminants such as nickel and cadmium, are associated with metal grinding and cutting operations. Metal grinding operations at metal forging facilities was brought to SCAQMD’s attention by community representatives in the city of Paramount through a series of odor complaints that began in 2012. Through air quality analyses and investigation, the SCAQMD staff identified Carlton Forge Works’ metal grinding operation as the primary source of the odor complaints. Carlton Forge Works is a metal forging facility that manufactures large seamless rings for the aerospace industry. Based on air monitoring near Carlton Forge Works, nickel and hexavalent chromium were the metals of greatest concern based on the levels measured and their toxicity. Although Carlton Forge Works was conducting their metal grinding operation within a building and had pollution controls, point source controls were not operated properly and fugitive emissions were escaping from large vents and bay doors in the building. As a result, initial nickel levels averaged 90 ng/m3 with levels as high as 300 ng/m3. As Carlton Forge Works implemented a series of voluntary measures to their point source controls and building enclosure to reduce emissions from their grinding operations between 2013 through 2015, average nickel levels decreased to 16 ng/m3. During the rulemaking process, SCAQMD staff has found similar, and in most cases lesser, pollution controls for metal grinding operations at other forging facilities as compared to Carlton Forge Works prior to implementing voluntary measures. Given that all alloys contain some level of toxic metals, it is expected that similar and possibly higher PM and toxic metal levels are emitted from metal grinding operations at other forging facilities as compared to Carlton Forge Works. Hexavalent chromium levels near Carlton Forge Works were generally not affected by implementation of the voluntary measures, indicating that the source of hexavalent chromium is likely from a source other than metal grinding, and possibly from the hot forging process or a source unrelated to Carlton Forge Works. The levels of hexavalent chromium near Carlton Forge Works are on average approximately 0.4 ng/m3, with some days as high as 1 ng/m3, which is substantially lower than levels found in October 2016 in other industrial areas in the city of Paramount that were over 20 ng/m3. The SCAQMD staff is continuing to investigate the source(s) of hexavalent chromium in the -2- industrial areas in the City of Paramount and has taken, and will continue to take, the appropriate regulatory or other actions to reduce these emissions. Proposal The SCAQMD staff has identified 22 metal forging facilities that conduct metal grinding or cutting operations that are subject to Proposed Rule 1430. Proposed Rule 1430 will prohibit grinding in the open air beginning date of adoption. At full implementation, all facilities will be required to conduct their operations within a total enclosure, and those facilities that are within 500 feet of a sensitive receptor or 1,000 feet of a school or an early education center will be required to operate the total enclosure under negative air that is vented to air pollution controls. Proposed Rule 1430 establishes a point source emission standard of 0.002 grains per dry standard cubic feet, and requires facilities to install High Efficiency Particulate Arrestors (HEPA). Compliance with the point source emission standard is demonstrated through a PM source test. The proposed rule also requires a multi-metals and hexavalent chromium source test every four years, with specific exclusions for facilities with low total chromium levels. To ensure continuous compliance, the proposed rule requires installation of a bag leak detection system, a continuous data logger to measure the pressure across the HEPA filter, and smoke tests to verify air flow for the pollution controls. To further ensure compliance with point source requirements, the proposed rule requires additional source testing requirements if the pressure across the HEPA continuously falls out of range for prolonged periods of time. Proposed Rule 1430 establishes a series of housekeeping requirements and recordkeeping requirements. The proposed rule also includes odor contingency measures that a facility must implement if a facility receives four or more confirmed odor complaints that are related to metal grinding or metal cutting operations. The proposed rule will also require each facility to place signs that have a facility contact and the SCAQMD’s 1-800-CUT-SMOG to report air quality issues. Public Process Proposed Rule 1430 was developed with input from a stakeholder working group that included representatives from industry, consultants, environmental groups, community groups, and public agencies. Six working group meetings were held on October 7, 2015, September 14, 2016, October 26, 2016, December 1, 2016, January 11, 2017, and February 6, 2017. At the request of community representatives, the September and December working group meetings were held in evening in the city of Paramount. A Public Workshop was held on January 19, 2017 to present the proposed rule and receive public comment, and a Public Consultation meeting was held on January 25, 2017 in the city of Paramount. -3- Key Issue Through the rulemaking process, staff has been working with stakeholders and has resolved a number of issues. One remaining key issue is regarding the cost of air pollution controls. One metal forging facilities has commented that the cost to install air pollution controls necessary to comply with the proposed rule are burdensome and could potentially result in the facility closing. Based on a site visit to the facility during the rulemaking process, the facility conducts grinding outside of a building enclosure with no air pollution controls. The estimated capital cost for the facility to comply with PR 1430 is approximately $340,000. These costs are disproportionately higher than other facilities with similar grinding operations that are subject to PR 1430, because the facility currently lacks a building enclosure and air pollution controls for their metal grinding operations. As a result, the estimated compliance cost for the facility reflects the cost to construct a total enclosure, install new air pollution control equipment, and purchase proper housekeeping equipment. AQMP and Legal Mandates Pursuant to Health & Safety Code Section 40460 (a), the SCAQMD is required to adopt an Air Quality Management Plan (AQMP) demonstrating compliance with all federal regulations and standards. The SCAQMD is required to adopt rules and regulations that carry out the objectives of the AQMP. PR 1430 is not a control measure in the Draft 2016 AQMP, but is needed to reduce the generation of fugitive metal particulates from metal grinding or metal cutting emissions from metal forging facilities. California Environmental Quality Act Pursuant to California Environmental Quality Act (CEQA) Guidelines §15252 and §15070 and SCAQMD Rule 110, the SCAQMD has prepared an Environmental Assessment (EA) for PR 1430. The environmental analysis in the Draft EA concluded that PR 1430 would not generate any significant adverse environmental impacts and therefore, no alternatives or mitigation measures are required. The Draft EA was released for a 30-day public review and comment period from January 10, 2017 to February 10, 2017.
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