SCAQMD REGULATORY CHANGES -- RULES IN THE MAKING (PROPOSED RULE 1420.2)

AQMD Rules In the Making — PAR 1420.2 (proposed)

AQMD is currently working on developing new emission standards for operations with lead melting. Proposed Rule 1420.2 “Emissions Standards for Lead from Lead Melting Operations”. This is part of the 1420 lead emission rules regulating lead, and is currently being developed by the South Coast AQMD. Existing rule 1420.1 covers “Emission Standards for Lead and Other Toxic Air Contaminants from Large Lead-acid Battery Recycling Facilities”, and this new rule would extend to other types of operations with lead melting activities and could include less significant emissions of lead than Rule 1420.1.

Because of non-attainment of air quality for lead in parts of the Los Angeles Region, Rule 1420.1 was adopted on November 5, 2010 and applies to large lead-acid battery recycling facilities that have processed more than 50,000 tons of lead a year. The rule requires emission limits for lead as well as housekeeping, monitoring, and emission testing for the two applicable facilities that emit lead. As the AQMD continues to work toward attainment of air quality standards, they now focused additional industrial operations which have the potential for lead emissions. When anything containing lead is melted it can impact air quality. EPA has set December 31, 2015 as the deadline for Los Angeles to demonstrate attainment with the current lead air quality standard.

The new Proposed Rule 1420.2 is in the early phases. AQMD is in the process of assessing the types of facilities that will be covered under the rule. They have assembled a list of facilities including lead acid battery manufacturers, building material manufacturers, aerospace part manufacturers, steel pipe manufacturers, lead product manufacturers (solder, xray shields, fishing tackle), scrap metal recyclers, steel pipe manufacturers, steel mills, and alloying of aluminum and iron.

Alta’s Kevin Cosgrove is closely tracking the rule-development and participated in the first working group meeting in December 2014 where AQMD was seeking input.
The proposed new rule will be considerably more prescriptive than Rule 1420. It includes the following elements:

• Establish ambient lead concentration limits
• Establish requirements for lead point sources
• Total enclosures
• Fence line ambient air monitoring
• Housekeeping and maintenance requirements
• Testing of Point Sources
• Development of a Compliance Plan

Of these elements, ambient monitoring represents a new challenge for industries. Ambient monitoring will require high volume air monitors at the perimeter of the plant operations. A key to this will be how much monitoring is required, how often, and if a facility can “off-ramp”. The AQMD may also require additional elements for point sources such as enclosures, enhanced plans and increased monitoring.

Please give us a call if you would like more information. It will be important that businesses submit their comments on any policy changes during the comment periods. We are here to help keep you in compliance.