One Size Does Not Fit All
By Chris Morse & RJ Simmons
The South Coast Air Quality Management District (AQMD) is introducing an amendment to Rule 1407 with the purpose of further reducing fugitive emissions. Fugitive emissions are emissions of gases and vapors from recycling equipment that contribute to air pollution, climate changes, and serious health concerns.
The current purpose of Rule 1407 is to reduce emissions of arsenic, cadmium, and nickel from non-ferrous metal melting operations. This new amendment specifically targets hexavalent chromium and ferrous metal melting operations.
As discussions of this amendment take place, AQMD’s stand is to create an overarching guideline for recyclers to help reduce these emissions. However, every recycling plant is different and one size does not fit all.
Key changes with the new Prop 1407 requirements are that any melting operations must have a total enclosure, point source controls, and housekeeping around melting operations to control fugitive emissions entering the air.
One point of contention is the total enclosure regulation. Total enclosures of melting operations means that this process must be done indoors to minimize cross drafts and limit access to people and vehicles. For some recyclers, building an entirely new building around melting operations could be costly, not to mention some businesses may be constricted by location and space.
Under the Rule 1407 amendment, several new controls will be required and existing ones amended, in addition to the new total enclosure regulation:
- Point Source Controls: in place to control fugitive emissions and base emissions of a specific toxin or emissions particulates, depending on what specific metal is being melted with periodic source testing to measure emissions, find the level of emissions and identify the toxin.
- Parametric Device Monitoring: implemented around the parameters of buildings and yards to alert when emissions are not being controlled properly.
- Installations of flow meters: required smoke tests once every 3 months to measure how many fugitive emissions are in the air.
- Ambient Air Monitoring: to measure toxins amounts in the air and what kind.
- Pressure Gauge System: to require a certain amount of pressure always be implemented during the melting process.
- Broken Bag Detectors: alarm to notify if there is a leak of fugitive emissions and failures.
- Housekeeping: requirements to minimize fugitive emissions around buildings and enclosures where metal is being melted and other processes, for example, the use of street sweepers to collect dust that can contain fugitive emissions.
The AQMD’s push to implement these potentially costly regulations affect all businesses involved with melting operations and recycling. Heavy fines could potentially be given to any business not following the new controls.
Since proposing this amendment, the AQMD’s seen pushback from recyclers and smelters asking them to consider plans that offer varied categories and options for recyclers with different operations, as every recycling plant is different.
The Prop 1407 amendment is still in discussion, a private hearing is set for April 6, 2018, and a public hearing for May 4th, 2018.
Our Recycling professionals are monitoring the Rule 1407 proposed amendment closely and are available to answer questions. Contact us for more information.