Draft EA - PR1634



south coast air quality management district

Final Environmental Assessment:

Proposed Rule 1137- PM10 Emission Reductions from Woodworking Operations

January 22, 2002

SCAQMD No. 011009MK

Executive Officer

Barry R. Wallerstein, D.Env.

Deputy Executive Officer

Planning, Rule Development and Area Sources

Elaine Chang, DrPH

Assistant Deputy Executive Officer

Planning, Rule Development and Area Sources

Laki Tisopulos, Ph.D.

Planning and Rules Manager

CEQA, Socioeconomic Analysis and PM/AQMP Control Strategies

Alene Taber, AICP

Author: Michael A. Krause Air Quality Specialist

Technical Michael Laybourn Air Quality Specialist

Assistance:

Reviewed By: William Wong Senior Deputy District Counsel

Steve Smith, Ph.D. Program Supervisor

South coast air quality management district

governing board

Chairman: WILLIAM A. BURKE, Ed.D.

Speaker of the Assembly Appointee

Vice Chairman: NORMA J. GLOVER

Councilmember, City of Newport Beach

Cities Representative, Orange County

MEMBERS:

MICHAEL D. ANTONOVICH

Supervisor, Fifth District

Los Angeles County Representative

HAL BERNSON

Councilmember, City of Los Angeles

Cities Representative, Los Angeles County, Western Region

JANE W. CARNEY

Senate Rules Committee Appointee

BEATRICE J.S. LAPISTO-KIRTLEY

Mayor, City of Bradbury

Cities Representative, Los Angeles County, Eastern Region

Ronald O. Loveridge

Mayor, City of Riverside

Cities Representative, Riverside County

JON D. MIKELS

Supervisor, Second District

San Bernardino County Representative

LEONARD PAULITZ

Councilmember, City of Montclair

Cities Representative, San Bernardino County

JAMES SILVA

Supervisor, Second District

Orange County Representative

CYNTHIA VERDUGO-PERALTA

Governor's Appointee

S. ROY WILSON, Ed.D.

Supervisor, Fourth District

Riverside County Representative

EXECUTIVE OFFICER:

BARRY R. WALLERSTEIN, D.Env.

Preface

This document constitutes the Final Environmental Assessment (EA) for the proposed Rule 1137 – PM10 Emission Reductions from Woodworking Operations. The Draft EA with no significant environmental impacts was released for a 30-day public review and comment period from October 9, 2001 to November 7, 2001. No comment letters were received from the public. Minor modifications have been made to the proposed rule since the release of the Draft EA. These modifications include extending the compliance date for existing facilities and altering the requirements for waste disposal activities. Also, staff updated the impact analysis, reducing the number of facilities that would need to make modifications compared to the number analyzed in the Draft EA. No changes have been made that alter the conclusions made in the Draft EA and the new changes in the project do not deprive the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project. No changes have been made to the Draft EA analysis. Thus, recirculation is not required because the new information added makes insignificant modification in an adequate EA. Therefore, this document is now a Final EA.

Table of contents

CHAPTER 1 - PROJECT DESCRIPTION

Introduction 1-1

California Environmental Quality Act 1-2

Project Location 1-3

Project Background 1-4

Project Objectives 1-7

Project Description 1-8

Dust Collection Technology 1-9

CHAPTER 2 - ENVIRONMENTAL CHECKLIST

Introduction 2-1

General Information 2-1

Environmental Factors Potentially Affected 2-2

Determination 2-2

Environmental Checklist and Discussion 2-4

APPENDIX A - Proposed Rule 1137

APPENDIX B - Construction Emission Calculations

List of Figures

Figure 1-1: South Coast Air Quality Management District 1-3

List of Tables

Table 1-1: Estimated Woodworking Facilities with Pneumatic

Conveyance Systems 1-7

Table 2-1: Estimated Upgrades at Affected Woodworking Facilities 2-7

Table 2-2: Daily Construction Emissions from Seven Upgraded

Woodworking Facilities 2-8

Table 2-3: Estimated Woodworking Facilities Upgrading Their Fan Size 2-13

Table 2-4: Energy Consumption and Supply 2-14

Table 2-5: Estimated Increase in Electrical Consumption 2-14

Table 2-6: Noise Levels Associated with Upgraded Fan Size 2-23

C H A P T E R 1 - P R O J E C T D E S C R I P T I O N

Introduction

California Environmental Quality Act

Project Location

Project Background

Project Objectives

Project Description

Dust Collection Technology

introduction

Proposed Rule (PR) 1137 – PM10 Emission Reductions from Woodworking Operations, implements the 1997 AQMP as amended in 1999 control measure PRC-01 by reducing the amount of particulate matter less than 10 microns (PM10) generated from woodworking operations. Typical facilities that may be affected include lumberyards, cabinet making facilities, furniture manufacturing and other product manufacturing operations that generate sawdust. Targeted facilities are those that utilize a centralized pneumatic conveyance system to remove sawdust from process areas and direct the material to a collection device. Based on recent site visits by the South Coast Air Quality Management District (SCAQMD) staff and survey results provided by affected facilities, many whom currently have cyclone collectors and/or baghouses that reduce PM10 emissions from their operations. Proposed Rule 1137 would require facility reporting and enhanced control (i.e., baghouses) for certain facilities, and establish standards for control equipment, waste collection and disposal activities. The analysis of the four environmental areas identified that could potentially be adversely affected by the proposed project, energy, noise, hazards and solid waste, concluded that impacts would not exceed the SCAQMD's significance thresholds and therefore are considered not significant. No other environmental topic areas were identified that could be significantly adversely affected by the proposed rule.

PR 1137 would be expected to provide local air quality benefits to community members who live in and around areas where woodworking facilities operate. These benefits include a reduction in particulate matter and toxic air contaminant emissions associated with the sawdust produced from the process of cutting, carving and/or sanding wood.

The California Legislature created the SCAQMD in 1977[1] as the agency responsible for developing and enforcing air pollution control rules and regulations in the South Coast Air Basin (Basin). By statute, the SCAQMD is required to adopt an air quality management plan (AQMP) demonstrating compliance with all federal and state ambient air quality standards for the all areas of the SCAQMD’s jurisdiction[2]. Furthermore, the SCAQMD must adopt rules and regulations that carry out the AQMP[3].

In 2000, the Basin exceeded both the federal (annual arithmetic mean) and state (annual geometric mean) ambient air quality standards, as well as the state 24-hour standard. To address these state and federal mandates, the 1997 AQMP as amended in 1999 (hereafter referred to as the 1999 AQMP) included a control measure (PRC-01) for the control of fine particulate matter from woodworking operations. The 1999 AQMP control measure called for upgrading control equipment at woodworking facilities to baghouse control systems and improved housekeeping to reduce PM10 emissions. PR 1137 implements the 1999 AQMP control measure PRC-01.

california environmental quality act

Proposed Rule 1137 is a "project" as defined by CEQA (Cal. Public Resources Code §21065). SCAQMD is the lead agency for the proposed project and has prepared appropriate environmental analysis pursuant to its certified regulatory program (SCAQMD Rule 110). California Public Resources Code §21080.5 allows public agencies with regulatory programs to prepare a plan or other written document in lieu of an environmental impact report once the Secretary of the Resources Agency has certified the regulatory program. The SCAQMD’s regulatory program was certified by the Secretary of the Resources Agency on March 1, 1989, and is codified as SCAQMD Rule 110.

CEQA requires that potential adverse environmental impacts of proposed projects be evaluated and that feasible methods to reduce or avoid significant adverse environmental impacts of these projects be identified, if available. To fulfill the purpose and intent of CEQA, the SCAQMD has prepared this environmental assessment (EA) to address the potential adverse environmental impacts associated with proposed Rule 1137. This Draft EA is intended to: (a) provide the lead agency, responsible agencies, decision makers and the general public with detailed information on the environmental effects of the proposed project; and, (b) to be used as a tool by decision makers to facilitate decision making on the proposed project.

All comments received during the public comment period on the analysis presented in the Draft EA will be responded to and included in the Final EA. Prior to making a decision on the proposed rule, the SCAQMD Governing Board must review and certify the EA as providing adequate information on the potential adverse environmental impacts of the proposed rule.

SCAQMD’s review of the proposed project shows that the project would not have significant adverse effects on the environment. Therefore, pursuant to CEQA Guidelines §15252, no alternatives or mitigation measures are included in this Draft EA. The analysis in Chapter 2 supports the conclusion of no significant adverse environmental impacts.

project location

Proposed Rule 1137 would apply to the SCAQMD’s entire jurisdiction. The SCAQMD has jurisdiction over an area of 10,473 square miles (referred to hereafter as the district), consisting of the four-county South Coast Air Basin (Basin) and the Riverside County portions of the Salton Sea Air Basin (SSAB) and the Mojave Desert Air Basin (MDAB). The Basin, which is a subarea of the SCAQMD’s jurisdiction, is bounded by the Pacific Ocean to the west and the San Gabriel, San Bernardino, and San Jacinto Mountains to the north and east. The 6,745 square-mile Basin includes all of Orange County and the nondesert portions of Los Angeles, Riverside, and San Bernardino counties. The Riverside County portion of the SSAB and MDAB is bounded by the San Jacinto Mountains in the west and spans eastward up to the Palo Verde Valley. The federal nonattainment area (known as the Coachella Valley Planning Area) is a subregion of both Riverside County and the SSAB and is bounded by the San Jacinto Mountains to the west and the eastern boundary of the Coachella Valley to the east (Figure 1-1).

[pic]

Figure 1-1

SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

PROJECT BACKGROUND

1 Affected Universe

There are approximately 750 facilities located in the district where woodworking activities are performed (e.g., lumber yards, wood turning and carving shops, and furniture and other product manufacturing facilities). Common woodworking operations include sawing, planing, chipping, lathing, and sanding. Each of these operations generates small wood waste particles in the form of shavings, sawdust, and fine wood dust.

Most larger woodworking plants employ pneumatic conveying systems that remove the wood waste from the immediate area of each operation and transport this waste to a collection device. These systems are necessary for housekeeping and convenience in collecting the waste material for ultimate disposal. Historically, cyclone collectors have been the primary means of separating the waste material from the air stream in these pneumatic transfer systems. Although suitable for medium-sized particulate (15 to 40 microns), wood dust particles within the 0 to 10 micron size range (PM10) are too fine to be effectively collected by the cyclone collectors.

The quantity of fine particulates escaping from a given cyclone depends on the dimension of the cyclone, the velocity of the air stream, and the type of woodworking operation. Typical cyclone collectors found in the woodworking industry are about 80 percent efficient in removing particles in the 20 to 44 micron-size range (U.S. EPA, 1980).

In addition to the health effects of fine particulates, deposits of fine wood dust particles on the roof and in the surrounding area of woodworking operations are a common source of public nuisance complaints in the district. Baghouses have recently been installed as a control device in some large woodworking plants in the district. Baghouses collect essentially all sizes of wood dust particles in the air stream and can significantly improve the emissions reduction of PM10 from this source category.

2 Regulatory History

At present, the SCAQMD does not have a source-specific rule directed at woodworking operations. Dust collectors at woodworking facilities are exempt from the SCAQMD’s permitting requirements. Rules 404 and 405 regulate particulate emissions from control exhausts based on concentrations (volume discharged) and weight criteria, respectively. Rule 401 controls visible emissions of any air contaminant discharged into the atmosphere from any single source. Rule 402 limits the discharge from any source causing a public nuisance. Rule 403 prohibits all forms of visible fugitive particulate matter from crossing the property line.

3 Source Testing, Survey and Site Visits

The SCAQMD conducted source testing at five commercial woodworking facilities in 1997 (SCAQMD, 1998) to update the emission inventory for this source category. The source testing identified uncontrolled PM10 emission factors ranging from 0.25 to 2.81 pounds of PM10 per hour. These factors are generally consistent with the AP-42 woodworking emission factors that range from two to five pounds of PM per hour (U.S. EPA, 1980). This testing also documented cyclone control efficiencies ranging from 24 to 84 percent with a combination cyclone/baghouse control system exhibiting a control efficiency of 99 percent.

The SCAQMD subsequently prepared and distributed a comprehensive survey to potentially affected facilities. The survey’s purpose was to refine the list of potentially affected facilities, determine the amount of production at typical facilities, and determine the extent of existing controls (cyclones, baghouses, etc.) presently in use. Surveys were distributed to all potentially affected facilities of which approximately 100 were completed and returned by industry. Valuable information obtained from the survey included refinement of the list of potentially affected facilities, typical amounts of sawdust generated on a weekly/monthly basis, and a brief description of existing control technologies.

In addition to the source testing and the survey work, the SCAQMD conducted site visits to seven sites ranging from small custom shops to large-scale manufacturing operations. Each of the facilities visited already employed dust collection and containment system(s). During the site visits, small facilities typically had a dedicated dust collection system for individual pieces of equipment. These "stand-alone" systems are necessary to meet Occupational Safety and Health Administration (OSHA) regulations and to reduce housekeeping requirements. Conversely, larger woodworking facilities employed centralized pneumatic conveying systems that remove the wood waste from the immediate area of each individual operation and transport this waste to a collection device. These systems are also necessary to meet OSHA standards and for convenience in collecting the waste material for ultimate disposal. Facilities with a centralized collection systems employed cyclone collectors to remove larger particles from the air stream prior to disposal. Control systems with cyclone collectors to remove larger particles followed by a baghouse to capture smaller particles were also observed at the largest woodworking facilities.

After conducting site visits and reviewing SCAQMD complaint data, it was determined that one of the primary sources of PM emissions from woodworking facilities was from the removal of waste material. Specifically, the waste storage bins are typically enclosed during normal operations; however, large amounts of particulate matter can become airborne when material is removed from the bin by a trash truck or other haul vehicle. To help quantify PM10 emissions from this activity, the revised emissions inventory included AP-42 emission factors for wood waste storage bin venting and wood waste storage bin loadout (U.S. EPA, 1979). These emission factors are based on total waste material generated at a facility and the analysis presumes an average density of wood waste/sawdust of 10 pounds per cubic foot of material (U.S. EPA, 1973). The amount of waste material generated from typical facilities was obtained from the year 2000 SCAQMD survey of woodworking operations.

4 Revised Emissions Inventory

Based on the survey data, site visits, and a review of complaint information, the number of facilities with existing controls is much higher than was originally used to generate previous emissions inventories. Accordingly, the updated emissions inventory for woodworking facilities includes an estimate that one-third of existing facilities utilize large-diameter (low-efficiency) cyclone collectors, one-third utilize small diameter (high-efficiency) cyclone collectors, and one third utilize a system comprised of a cyclone and baghouse. The resulting PM10 control efficiencies for each of these scenarios are 24 percent, 84 percent, and 99 percent, respectively. Using these assumptions (including assumptions regarding wood waste storage bin venting/loadout and the extent of existing control technology), woodworking facilities are estimated to generate approximately 1.2 tons of PM10 per day.

5 Size of Universe

Of the estimated approximate 724 woodworking facilities, 200 of these facilities are estimated to employ less than 10 workers to perform the woodworking operation. Such a small operation is not likely to use pneumatic conveyance (duct) system and, therefore, would not be subject to PR 1137. Approximately 78 facilities are estimated to employ over 100 workers because the woodworking operation is large. As such, a pneumatic conveyance system is likely to be in place, as well as a baghouse to collect the high amount of wood particles. The remaining facilities are estimated to either comply with the proposed “no visible emissions” requirement or will be required to upgrade their estimated current control equipment to comply with the proposed rule. Table 1-1 outlines all the affected facilities and their current control device.

Table 1-1

ESTIMATED WOODWORKING FACILITIES WITH PNEUMATIC CONVEYANCE SYSTEMS

|# of Employees |# of Facilities |Current Control Device |Typical Air Flow |Typical Fan Size |

| | | |(cubic feet per minute) |(horsepower) |

|10-19 |17 |low efficiency cyclone |3,600 |10 |

|10-19 |69 |high efficiency cyclone |3,600 |20 |

|20-49 |37 |low efficiency cyclone |16,000 |30 |

|20-49 |75 |high efficiency cyclone |16,000 |40 |

|50-99 |44 |low efficiency cyclone |26,000 |50 |

|50-99 |26 |high efficiency cyclone |26,000 |60 |

|10-100 |178* |cyclone |900-13,000 |10-50 |

|>100 |78* |baghouse | ................
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