Metal processing facilities are facing regulatory scrutiny and air emission controls unlike ever before, in a snowball effect of agency action. You may have heard about metal processing facilities such as Exide in Vernon. Or Anaplex in Paramount. Fast-forward to 2017, the South Coast Air Quality Management District (SCAQMD) has made findings of elevated and significant airborne levels of hexavalent chromium (CrVI) in Paramount and Compton. The findings were made by extensive ambient fenceline and community monitoring near metal processing facilities. Now, some metal processing facilities in the LA area are undergoing Order for Abatement actions to protect public health by SCAQMD, by controlling emissions and odors, and even by shutting down operations, at high capital cost. State and local rules are changing, to accelerate the allowed enforcement use of fenceline monitoring and expedited Orders for Abatement, and to codify stringent CrVI, lead, arsenic, cadmium and nickel air emission controls. The City of Los Angeles just announced that 21,000 metal processing sites will be prioritized for investigation for possible public health impacts from CrVI sources. These developments have implications in LA, California and beyond. This webinar discusses: • The background to SCAQMD’s Community Air Toxics Initiative. • Update of enforcement activities in Paramount and Compton. • What is the role public nuisance laws, monitoring, source testing and health risk modeling have in all this? • SCAQMD rule developments that may impact your operations; 1407, 1420, 1426, 1430 & 1469 • Relevant State legislation and other local actions flowing from the Air Toxics Initiative. • How to assess your status before SCAQMD visits your facility - what is a “bad” operation and what is “good” • Options to avoid enforcement action and revised SCAQMD toxics rule requirements, and streamline compliance costs. • How to proactively reduce emissions, including enclosures, scrubbers, dust collectors, housekeeping and other measures. The instructors for the webinar are James A. Westbrook, President of BlueScape, and Michael Stewart, Project Manager. Since 1987, BlueScape has managed or completed more than 100 air toxics related projects for metal processing facilities. BlueScape has been working with aerospace companies, metal finishing facilities and foundries on issues related to the Air Toxics Initiative. BlueScape can be reached at training@bluescapeinc.com or 877-486-9257 for questions, customized training, and support for your air permitting, compliance and HRA projects.

1. Pressure on Metal
Facilities is Heating Up!
Update on the Los Angeles Air Toxics Initiative
James Westbrook, CPP | President
Michael Stewart, PE | Project Manager
September 28, 2017

2. Webinar
Topics
• Background to the Air Toxics Initiative
• Summary of Enforcement and Rulemaking
• Impacts on Metal Processing Facilities
• Recommendations for Evaluation & Next
Steps

3. Poll – How did the LA Air Toxics
Initiative Begin?
• SCAQMD enforcement action against high-
emitters
• Erin Brockovich lawsuits
• A facility “turned themself” in to the health
dept.
• Community action
• The Exide Vernon case

4. Background to the
Los Angeles Air Toxics
Initiative

5. Air
Toxics
&
the
Snowball
Effect

6. Air Toxics Initiative Timeline
2007 – 2015:
Exide Lead
SCAQMD Rules
1420.1 and
1420.2
2017 - 2024??:
- SCAQMD Air Toxics
Initiative
- State & Local Rule
Developments
- Enforcement &
Monitoring in
Paramount, Compton
and Long Beach
- LA City Motion
- What’s NEXT?
2012-2017:
- Paramount CrVI
Monitoring
- Anaplex, Aerocraft
and Carlton Forge
2010 – 2015:
- Hixson Metal
CrVI
- Rule 1402 Risk
Reduction

7. CrVI – One Bad Hombre
(and the other guys)
• CrVI is a state that occurs in high-heat or strong
oxidation processes, or introduced in compound form
– Cr to CrVI - Furnaces, heat treating, welding rod use, laser or
arc cutting and other types of “hot work”
– Chrome plating, anoziding, chromic acid baths with heating or
sparging
– Cr compounds used in coating pigments and spray booths,
military spec
• CrVI is very toxic and known to cause cancer & other
long-term chronic health effects
• How can CrVI get into the air?
• Lead, nickel, arsenic, cadmium, beryllium

8. Summary of Enforcement
& Rulemaking Activities

9. Nuisance, Public Health, and SCAQMD
Enforcement
• SCAQMD has various tools to regulate air toxic metal
emissions
– Rule 1401/permits, Reg. IV rules, Rule 1402/AB2588
– But have to be a “fit”
• Public Nuisance laws primary enforcement tool
– SCAQMD Rule 402, H&S Code 41700
– “ shall not discharge … contaminants .. which cause injury,
detriment, nuisance or annoyance to any considerable number of
persons or to the public .. or which endanger the comfort,
repose, health or safety …”
• “Imminent and substantial endangerment” language not in
nuisance regulations
• Orders for Abatement issued by the Hearing Board
– Process, Evidence, Action
• SCAQMD’s mission to strengthen tools

10. 2015
Risk
Guideline
Changes
Increased
Monitoring
&
Tes<ng
EJ
Community
Ac<va<on
CrVI
Emissions
Increased
Public
Nuisance
Enforcement
Odors

11. Paramount Enforcement – Anaplex
• Metal finishing facility
• AQMD fenceline & community monitoring
• 1 ng/m3 CrVI ambient threshold, 3 samples
– 0.2 ng/m3 = 100 in one million resident cancer risk
• Anaplex Order for Abatement in Jan 2017 for emissions
exceeding 1 ng/m3
– Ordered to temporarily shut down all equipment w/PTE
CrVI on June 27th, 2017
• Required controls include:
– Close access doors, reduce tank emissions,
housekeeping
• Precursor to rulemaking, amended Rule 1469/1426

12. Paramount Enforcement - Carlton Forge
• Metal forging facility
• Public odor complaints starting in 2012-2013
– 190 odor complaints since Dec 9, 2016 à 17 NOVs
• Voluntary controls installed for grinding
• Nickel emissions went down, but CrVI constant
• Precursor to rulemaking, Rule 1430
– Related to grinding specifically
• Additional review of odor controls in process

13. Compton & Long Beach Enforcement
• SCAQMD putting the Air Toxics Initiative in
play ….
• Multiple facilities in Compton
– Ambient CrVI monitoring began June 2017
– 99 inspections conducted in July 2017
• 5 NOVs and 16 NTCs issued
– Expecting Orders for Abatement
• Lubeco in North Long Beach

14. South Coast AQMD Rulemaking
• Exide – Rules 1420.1 and 1420.2 for lead
• Carlton Forge – Rule 1430 for CrVI and odors
• Hixson, Paramount, Compton, etc. – Proposed
Amended Rules 1426 / 1469 for CrVI
• Other Proposed Amended rules, capture more
sites and consistency:
– Rule 1420 for small lead melters
– Rule 1407 for ferrous and non-ferrous facilities
• New Rules Coming - other units and operations
– heat treating, laser cutting, grinding; larger
facilities

15. New State Air Toxics Legislation
• Assembly Bill 617 (passed 7/26/17):
– ARB to expand community toxics monitoring for high
priority facilities
– Authorize air districts to require facility fenceline
monitoring
• Facility with elevated cancer or noncancer prioritization score
– Districts can require “best controls” to reduce toxics
• Assembly Bill 1132 (passed 8/7/17)
– Air districts can issue an “interim” Order for Abatement
• Currently must be noticed and hearing occur, with approval
before Order can be issued
– Finding of “imminent and substantial endangerment to the
public health or welfare”
– Air district must meet facility, work on a “stipulated”
interim Order
– The interim orders are temporary.

16. LA City Council Motion and beyond …
• Motion passed by LA City Council on 8/30/17
• Identified 21,000 metal processing sites with CrVI
• Bureau of Sanitation to work with SCAQMD and LA
Co Health Dept w/in 30 days
– Update priority ranking of sites with excessive CrVI
– Plan for joint inspections
– Analyze environmental justice impacts
– Update on ways to reduce health effects to LA residents
• What other cities, counties, agencies, initiatives,
areas in California?
– When will the air toxics snowball slow down??

17. SCAQMD Rule
Developments in Response
to Air Toxics Initiative

18. SCAQMD Metals Rule Applicability by
Operation Type
Activity 1420
1420.1 /
1420.2
1430
1469 /
1426
1407 1435 1445
Amendment
Review
Adopted Adopted
Amendment
Review
Amendment
Review
Pending Pending
Foundry ✔ ✔ ✔
Machine Shop ✔
Stamping
Metal Finisher ✔ ✔
Forger ✔
Smelter ✔ ✔
Grinding ✔ ✔ ✔
Saw Cutting ✔ ✔
Welding ✔
Dust / Fugitives ✔ ✔ ✔ ✔ ✔ ✔
Odors ✔ ✔
Finishing ✔
Melting ✔ ✔ ✔
Heat Treating ✔ ✔
Laser Cutting ✔

19. Proposed Amended Rules
• Rule 1420 – Emissions Standards for Lead
– SCAQMD proposed amendments to the rule
– Applies to metal melting or lead processing facilitates
• Exempt if process < 2 TPY lead
– Ambient lead concentration requirements:
• 0.150 µg/m3 through 2020, 0.100 µg/m3 2021 and beyond
– Emissions to be vented to HEPA filter controls (alternative
compliance option available)
– Source testing demonstrations
– Fenceline ambient lead monitoring
• If process more > 10 TPY lead
• If > 2 TPY, but < 10 10 TPY, can avoid with modeling studies
– Total Enclosures
– Housekeeping Requirements

20. Approved SCAQMD Metals Rules
• Rule 1420.2 – Emission Standards for Lead from Metal
Melting Facilities
– If facility melts > 100 TPY lead
– Would require total enclosure for all lead processing
operations
– Ambient air monitoring requirements
– Lead point source emission controls
– Source testing
– Total enclosures

21. Recently Adopted Rule
• Rule 1430 - Control of Emissions From Metal Grinding
Operations at Metal Forging Facilities
– Requires total enclosure for all metal grinding and cutting
operations
– Emissions requirements:
• 0.002 grains PM per dscf
• Vented to HEPA filter & continuous data logger
– Odor reduction
– Source testing
– Housekeeping requirements
– Compliance dates for total enclosures around metal
grinding or cutting operations started 9/3/17

22. Proposed Amended Rules
• Rule 1469 – CrVI Emissions from Chromium
Electroplating and Chromic Acid Anodizing Operations
– Would require enclosure for all tank operations with CrVI
– Point source controls Tier II tanks (high conc. or temp., or rectified)
– Periodic source testing
– Potential regulations on tanks currently not subject to Rule 1469 (Rinse,
passivate, dichromate seal, etc.)
– Getting help from other City of LA agencies to find CrVI emitters
• Rule 1426 - Emissions from Metal Finishing Operations
– Facilities performing Cr, Ni, Cd, Pb or Cu operations, or chromic acid
anodizing (See Rule 1469)
– Compliance reports & housekeeping requirements
– No control requirements
– AQMD is using facilities under this Rule as a vehicle to capture facilities
under Rule 1469

23. Proposed Amended Rules
• Rule 1407 – Control of Emissions of Arsenic, Cadmium,
and Nickel from Non-Ferrous Metal Melting Operations
– Proposed amendments
– Includes smelting, die casting, galvanizing & more
– Control fugitive emissions by building enclosures
– Point source controls
– More housekeeping
– Source Testing to measure control efficiency
– Exempt if < 1 TPY metal melting
– Next workshop in December 2017

24. SCAQMD Metals Rules In the Pipeline
• Rule 1435 Control of Emissions from Metal Heat
Treating Processes
– A proposed rule
– Being moved from Nov to 2nd quarter 2018
• Rule 1445 Control of Toxic Emissions from Laser
Arc Cutting
– Will establish requirements to reduce toxic metal particulate
emissions from laser arc cutting

25. Loss of Permitting Exemption
• Loss of exemption language clearly stated in rules.
• Can lose exemption if the AQMD see your process as a health risk
concern.
• Rule 219/222
– Equipment losing exemptions and will require permits
• Example: No exemptions for plating, stripping or anodizing if tank contains
Cr, Ni, Pb, or Cd and is rectified, sparged, or heated

26. Key Common Downstream Impacts of
Rulemaking
• Loss of permit exemption
• Increased source testing requirements
• Increased ambient monitoring
• Increased emission controls of point sources
– HEPA filters, baghouse, etc.
• Increased emission controls of fugitive sources
– Enclosures
• Increased housekeeping requirements

27. Impacts on Metal
Processing Facilities

28. How to Know if You Could be a High
Priority?
• Do you emit CrVI, cadmium, nickel, lead, or
arsenic?
• Is the facility located near residences or schools?
• Is the facility located in an Environmental Justice
(EJ) area?
• Potential for fugitive toxic emissions or odors?
• Any previous issues related to metal emissions:
NOVs, NTCs, etc?
• On other lists, like for Rule 1402?

29. Carlton Forge is a High Priority

30. How to Know if You Could be a “Bad
Player?”
• Know your emissions
• Are these sources controlled?
• Are all emission sources permitted?
• Metals-related NTCs/NOVs?
• Any odor complaints?
• Is your facility clean and is proper housekeeping
performed?
• Where are the prevailing winds coming from?

31. What Can Happen if the Emissions &
Monitoring Results are Too High?
• Installation of emission controls may be required:
– Baghouses/HEPA filters
– Enclosures
• Required to source test or monitor
• Emissions, source test or monitoring results may need to be
modeled:
– To assess health risk impacts
– HRA methodologies were updated in 2015 à 3x higher impacts
• Any of these activities are expected to yield high costs to the
facility
• If seen as “imminent danger” to public, potential process
limits or operation curtailment

32. What Can Happen if the Emissions &
Monitoring Results are Bad?

33. Potential Costs to Your Facility

34. Potential Costs to Your Facility

35. Lubeco Example – Formula for an Order
of Abatement
• July 2017, AQMD petitioned for Stipulated Order of
Abatement & was granted by Hearing Board on August 23
• Result of “intensive investigation” à high levels of CrVI
• Short & long-term measures to reduce CrVI
• Shut down equipment if > 1 ng/m3
• Removal of certain tanks w/CrVI
• Modification of certain practices
• Risk reduction plan
• Installation of control equipment
• Periodic AQMD inspections to ensure compliance with the
Order

36. Recommended
Evaluations

37. Prepare Yourself With All of the
Information
• Know the rules and those that apply to you.
• Make sure the emission inventory reports are accurate
– Review emission factors, process throughput and other
assumptions
• Which is the highest source of CrVI emissions?
– Furnace?
– Welding?
– Cutting?
• Do you think your equipment could be a problem? Perform a
fact-finding source test or ambient monitoring
• Has an HRA been previously performed?
• Know how this could affect your suppliers and purchasers.

38. Proactive Actions to Avoid SCAQMD
Enforcement
• Be prepared before SCAQMD arrives – know what the
potential problems are/will be.
• Be prepared to update emissions with better information.
• Begin getting cost estimates on expected control equipment.
– Plan for enclosures, scrubbers, dust collectors, HEPA filters,
housekeeping and other measures
• Attack the low hanging fruit first.
• Be prepared to communicate with the SCAQMD.

39. Conclusions

40. Develop a Plan
• Do your homework
– Collect all information
– Review compliance history
– Visit all the equipment
– Compare permits to equipment operation – is everything
accurate?
– Know your neighbors
• What is the “high risk” equipment?
– Know the emissions and health risk impacts, evaluate
need for controls, prepare for source tests and monitoring
• Get help!

41. Get Involved
• Keep up to date with rule development
• Know where you fit into these rule developments
• Attend workshops and public hearings
• Attend town hall meetings
• Submit comments for rule development
• Be active in local environmental organizations

42. A Consultant Can Help You
There are experts who can:
• Review rule applicability
• Help you know if you are a “target” or a “bad player”
• Ensure your emission reports are accurate
• Support source testing or ambient monitoring
• Perform health risk calculations & modeling
• Communicate with the air districts and other agencies

43. Ques:ons?
Contact
Informa:on
James A. Westbrook, CPP | President
jwestbrook@bluescapeinc.com
Michael Stewart, PE | Project Manager
mstewart@bluescapeinc.com
(877) 486 – 9257
www.bluescapeinc.com
Connect with us on Linkedin!
The webinar presentation will be posted on Slideshare and YouTube