1. BAAQMD Rulemaking 2017-2019 Greg Nudd Acting Rules and
Strategic Policy Officer
September 21, 2017 1 1

2. Overview Upcoming Rules on Criteria Pollutants
Air Toxics Reductions at Existing Sources (Rule 11-18)
Climate Rules (Methane)
Impact of Assembly Bill 617 2 2

3. Reg 6 Rules: Coarse Particulate Matter
Criteria Pollutants
Reg 6 Rules: Coarse Particulate Matter
Rule 6-1 is currently a Total Suspended Particulates (TSP) rule
Tighten general particulate matter emissions limits
Specify test methods for determining compliance
Require periodic compliance testing
New Regulation 6, Rule 6: Prohibition of Trackout
No “significant” visible roadway material on adjacent paved roadway
Cleanup required at end of work day
New Regulation 6, Rule 8: Bulk Material Handling
No “significant” visible dust
No visible dust beyond the property line
Clean up spills 3 3

4. Refinery Fuel Gas Sulfur Limits
Criteria Pollutants
Refinery Fuel Gas Sulfur Limits
Regulation 9, Rule 1, Sulfur Dioxide
Limit total sulfur in refinery fuel gas to reduce SO2 emissions from RFG combustion
Sets a limit on the total sulfur content of RFG of 100 ppm (90-day average basis)
Requires monitoring and sampling of RFG for total sulfur
Expected to reduce SO2 emissions by ~250 tpy 4 4

5. Rule 9-9: Gas-Fired Turbines
Criteria Pollutants
Rule 9-9: Gas-Fired Turbines
Lower NOx limits on small (50 to 100 MMBtu/hr) and medium-sized (100 to 500 MMBtu/hr) turbines
Small turbines expected to comply by installing combustion-based controls (e.g., steam injection or Dry Low NOx)
Medium-sized turbines expected to comply by installing or modifying SCR systems 5 5

6. Regulation 1, Regulation 8, Manual of Procedures –
Criteria Pollutants
Regulation 1, Regulation 8, Manual of Procedures –
Update and Cleanup
Consolidate definitions of VOC in various Reg 8 Rules into one definition and place in Reg 1
Amend provisions in certain Reg 8 Rules that require updating and/or clarification
Amend the MOP to support Reg 1/Reg 8 project and to update/clarify certain volumes     6 6

7. Capping Risk from Toxic Air Contaminants
Bay Area risk levels decline since 1990
1990
2001
2014 7 7

8. Capping Risk from Toxic Air Contaminants
Rule 11-18
Reduces Risks from TACs to the lowest achievable levels
Particularly benefits CARE areas
Incorporates latest health risk methodologies
Promotes continuous improvement
Ensures public transparency
Provides greater flexibility 8 8

9. Capping Risk from Toxic Air Contaminants
Rule 11-18: Risk Action Thresholds
A. Benefit of Setting the Risk Action Level at 10 per Million
An Air District staff review of the toxic emissions from the potentially affected facilities indicates that these risk levels range from approximately 56/M to 10/M at the maximally exposed individual (MEI).
Approximately 450 facilities would be required to reduce their risk impacted under the proposed rule.
B. Ten per Million v. 25 per Million – What’s the Difference?
10/M is achievable and has been and continues to be demonstrated in practice in at least ten air pollution control districts, including Sacramento Metropolitan Air Quality Management District, Santa Barbara County and San Luis Obispo County Air Pollution Control Districts.
Air District staff estimated that numbers of residents that would be included under each risk action level scenario and determined that the 10/M action level would serve to reduce risk to about 10 to 15 times as many people as the 25/M action level. 9 9

10. Capping Risk from Toxic Air Contaminants
Air District staff will conduct health risk assessments
Facilities above Risk Action Levels must:
Develop a risk reduction plan for Air District approval
Plan must get down below 2020 Risk Action Levels (10/million)
Execute plan according to plan schedule
Risk reduction measures include:
Installation of Best Available Retrofit Control Technologies for Toxics (TBARCT)
Modification of operating hours and activity levels
Modification of emissions point characteristics 10 10

11. Capping Risk from Toxic Air Contaminants
Proposed Rule 11-18
Publish Final Hearing Package (September 2017)
Proposed Rule
Staff Report
Socioeconomic Analysis
Recirculated Draft Environmental Impact Report (CEQA)
TBARCT Workbook
Public Comments Due: October 16th
Board Hearing for Adoption (November 15, 2017)
Implementation
Phase 1: Facilities with PS > 250 (including multiple-source facilities)
Phase 2: PS >10 including MSF
Phase 3: Stationary Diesel Engines:
Phase 4: Retail Gasoline Stations: 11 11

12. Prohibit Significant Methane Leaks
Climate Rules
Prohibit Significant Methane Leaks
Establish a general/catch-all methane emissions limit (Draft Rule 13-2) applicable to all sources
Considering a methane emissions limit of 10,000 ppm and 10 lbs/hr. If a source can demonstrate a methane leak is  less than 10 lbs/hr, no need to repair.
If a repair is required, methane leak must be repaired and demonstrated to be less than 500 ppm
Rule will likely include a delay-of-repair provisions 12 12

13. Climate Rules Oil and Gas Rule
Air District Rule 8-37 limits organic compounds from natural gas and crude oil facilities but exempts methane
ARB’s Oil & Gas Rule (adopted in Mar 2017)
Covers < 25% of Bay Area GHG emissions due to exemptions
Allows air districts to implement firmer requirements
How will it work?
Consider a lower leak threshold to achieve cost-effective methane and VOC emissions reductions and protect public health
Remove methane exemption from rule 13 13

14. Climate Rules Composting
Registration for organic waste processing to better track material and characterize emissions
Best Management Practices (BMPs)
Storage Pile size and time limits at Transfer Stations and Chip and Grind facilities
Additional BMPs for Composting Facilities required subject to low- throughput or other exemption limits (community, park, on-site agricultural)
Control equipment for larger facilities
Biofilters
Alternative control methods 14 14

15. AB 617 Components
Require additional air monitoring in impacted communities
Develop methods to reduce air pollution in impacted communities
Develop clearinghouse for Best Available Retrofit Control Technology; air districts adopt additional BARCT rules
Require uniform reporting of emissions inventories
Increase allowable fines ($5,000 per day)
Slide 15 15

16. Air Monitoring in Impacted Communities
AB 617 Requirement – State/air districts to enhance air monitoring in impacted communities.
Air District efforts already under way
Identifying additional air monitoring locations in refinery communities.
Assembling available data to help identify additional locations for potential monitoring (health outcomes, modeling, short term studies, etc.).
Working with equipment manufacturers, Non-Governmental Organizations (NGOs), South Coast AQMD, universities and other groups to identify cutting edge equipment.
Slide 16 16

17. Emission Reduction Plans
AB 617 Requirement – Identify areas impacted by criteria pollutants and Toxic Air Contaminants (TACs) and develop Emission Reduction Plans to reduce those impacts.
Air District efforts already under way
Continued reduction of criteria pollutants
Regulation 11, Rule 18 will require existing stationary sources to reduce risk from TACs to the lowest levels in the State
Already adopted Regulation 2, Rule 5 to reduce TACs from new sources.
CARE Program/Community Risk Reduction plans
Planning Healthy Places Guidebook
Slide 17 17

18. BARCT Requirements Air District efforts already under way
AB 617 Requirement – State to develop a clearinghouse to define BARCT for stationary sources. Air districts to enact additional BARCT rules.
Air District efforts already under way
The 2017 Clean Air Plan evaluated all rules to determine which needed to be updated.
Staff currently reviewing and prioritizing rules to ensure that this requirement is met.
Slide 18 18

19. Emissions Inventory Reporting
AB 617 Requirement – State to develop uniform emissions inventory reporting requirements for criteria pollutants and TACs and require sources to submit this information to the State.
Air District efforts already under way
Regulation 12, Rule 15 requires the use of uniform reporting of emissions inventories based on guidance produced and updated to incorporate the latest emissions information available.
Regulation 11, Rule 18 will result in accurate, uniform emissions inventory for TACs to ensure health risk to the lowest levels achievable.
Slide 19 19

20. Working with Partners and Timelines in AB 617
Conference calls every week with CARB and South Coast AQMD to discuss issues and develop plans forward.
Working with other agencies, NGOs, universities and communities to hear ideas and receive feedback.
Timelines for implementation are extremely aggressive and will require a refocus of Air District resources
Air monitoring – deploy first stages by July 1, 2019 (Additions possible by Jan. 1, 2020 and annually thereafter).
Emission Reduction Plans - Once an area is identified as being impacted, a reduction plan must be in place within one year
BARCT Rules – Adoption of rules by Jan. 1, 2019 and implemented by Dec. 31, 2023
Slide 20 20

21. Questions? 21 21