State of California
AIR RESOURCES BOARD
Crystal Ballroom
Hotel San Franciscan
1231 Market Street
San Francisco, CA
April 27, 1978
10:00 a.m.
AGENDA
Page
78-8-1 Public Hearing to Consider Adoption of a Rule for 1
the Bay Area, Fresno County, Kern County, Monterey Bay
Unified, San Diego County, San Joaquin County, San Luis
Obispo County, and Ventura County Air Pollution Control
Districts and for the South Coast Air Quality Management
District, and to Consider a Model Rule for the
Remaining Air Basins, to Prohibit the Burning of Liquid
and Solid Fuels if Natural Gas is Available.
78-8-2 Public Hearing to Consider Proposed Revisions to 55
the Meteorological Criteria for Regulating Agricultural
Burning.
78-8-3 Public Hearing to Consider Establishment of State 70
Ambient Air Quality Standards and/or Significant Harm
Levels for Vinyl Chloride.
78-8-4 Other Business -
a. Executive Session - Personnel & Litigation
b. Research Proposals
ITEM NO.: 78-8-1
Public Hearing to Consider Adoption of a Rule for the Bay Area,
Fresno County, Kern County, Monterey Bay Unified, San Diego
County, San Joaquin County, San Luis Obispo County, and Ventura
County Air Pollution Control Districts and for the South Coast
Air Quality Management District, and to Consider a Model Rule for
the Remaining Air Basins, to Prohibit the Burning of Liquid and
Solid Fuels if Natural Gas is Available.
RECOMMENDATION
A. Adopt Resolution No. 78-25, thereby adopting into the
regulations of the Bay Area, Fresno County, Kern County,
Monterey Bay Unified, San Diego County, San Joaquin County,
San Luis Obispo County, and Ventura County Air Pollution
Control Districts and the South Coast Air Quality Management
District a rule prohibiting the burning of liquid and solid
fossil fuels if natural gas is available.
B. Approve the proposed rule as a model rule for the remaining
Air Pollution Control Districts in the State.
SUMMARY
On February 24, 1978, the San Diego Gas and Electric Company
began rejecting natural gas that was available to it. The
Pacific Gas and Electric Company has not been taking all of the
interstate natural gas available to it. The Southern California
Gas Company, at Southern California Edison's request, has been
storing gas that is now available to Southern California Edison.
The Southern California Gas Company is concerned that it may have
to reject interstate gas that will be available to it later on
this year. The rejecting of natural gas is resulting in the
burning of fuel oil with a resulting increased emissions of
oxides of nitrogen, sulfur dioxide, particulate matter, and
hydrocarbons. Furthermore, the rejection of interstate gas will
prejudice future allocations of interstate natural gas to
California.
A regulation prohibiting the burning of liquid or solid fuels if
natural gas is available is proposed for adoption by the Board
for the Bay Area, Fresno County, Kern County, Monterey Bay
Unified, San Diego County, San Joaquin County, San Luis Obispo
County, and Ventura County Air Pollution Control districts and
for the South Coast Air Quality Management District. These
Districts are selected because the ambient air quality standards
for one or more of sulfur dioxide, sulfates, nitrogen dioxide,
and total suspended particulates are exceeded in each of them,
and each of the Districts has industry which either burns or
could burn fuel oil. A model rule is proposed for the remaining
Air Pollution Control Districts in the State.
Immediate action is required by the Board to eliminate this
immediate and pressing problem.
ITEM NO.: 78-8-2
Consideration of Proposed Revisions to the Meteorological
Criteria for Regulating Agricultural Burning.
RECOMMENDATION
Adopt Resolution 78-24.
SUMMARY
Two revisions to the "Meteorological Criteria for Regulating
Agricultural Burning" are proposed. One change pertains to the
Southern Section of the San Joaquin Valley Air Basin, and the
other to the San Francisco Bay Area Air Basin.
The Southern Section of the San Joaquin Valley Air Basin (SJVAB)
is divided at the elevation of 3000 ft above sea level into a
high and a low part for purposes of determining agricultural
burning days. Different meteorological criteria for determining
agricultural burn days exist for each part, with the lower part
having the more stringent criteria. On occasion, smoke
dispersion in the foothill regions at elevations above the valley
floor but below 3000 ft is good, but burning agricultural wastes
in these regions is prohibited by the current more restrictive
criteria for the lower part of the basin.
The proposed change to the meteorological criteria provides for a
variable elevation division between the low and high parts of the
Southern Section of the SJVAB. As proposed, the specific
elevation division, 3000 ft or less, would be determined daily
based on meteorological data and the expected impact of burning
on air quality. If adopted, this variable elevation feature
would tend to increase the percentage of time agricultural
burning would be allowed in the higher part of the basin without
adversely affecting the air quality of the basin.
Agricultural burning in the San Francisco Bay Area Air Basin
(SFBAAB) is currently governed by one set of meteorological
criteria, although it has been noted that differences in weather
patterns exist between the northern part and the southern part of
the basin. These differences have generally been associated with
more favorable dispersion conditions for burning in the northern
counties, particularly in the winter when much of the
agricultural wastes are burned. The use of a single set of
meteorological criteria, accordingly, has tended to result in
decisions regarding burning for the northern part of the basin,
which may be more stringent than necessary. In consideration of
these factors the Bay Area Air Pollution Control District
(BAAPCD) has requested that the ARB consider changes to the
meteorological criteria governing agricultural burning in SFBAAB.
Based on the observed differences in the meteorological
conditions, a change to the meteorological criteria is proposed,
which provides for a division of the SFBAAB into a Northern
Section and a Southern Section. The justification for having two
sections is based on the observed differences in the
meteorological conditions. If adopted it is estimated that the
proposed revision would allow agricultural burning in the north
section at times when burning would be prohibited in the south
section without adversely affecting the air quality of the air
basin as a whole.
ITEM NO.: 78-8-3
Public Hearing to Consider Establishment of State Ambient Air
Quality Standards and/or Significant Harm Levels for Vinyl
Chloride.
RECOMMENDATION
The staff recommends that: (1) the Board adopt an ambient
standard, to be designated as a significant harm level, in the
range of 0.01 to 0.05 ppm, twenty-four average; (2) ambient
concentrations in excess of this standard detected in areas of
public access be defined as an endangerment to the health and
safety of the public under Health and Safety Code Section 41700,
thereby providing a distinction from the significant harm level
adopted for sulfate, and a legal basis for immediate enforcement
action; (3) the Board specify the measurement method developed by
the ARB staff; (4) the Board urge the SCAQMD to adopt emission
regulations designed to reduce ambient concentrations below the
significant harm level and that monitoring be carried out at the
boundary line of facilities using and/or producing vinyl
chloride.
SUMMARY
The adverse effects of vinyl chloride (VC) upon human health --
its role as a carcinogen, mutagen and suspected teratogen -- have
been discussed in detail in Air Resources Board Staff Report 78-1-1
and by several medical experts at the January 25, 1978,
meeting of the Board.
In response to requests made by the Board at the January meeting,
the staff has carried out an analysis of the EPA's NESHAP
regulations and prepared estimates of the maximum ambient levels
of VC that can be expected when the largest VC facilities in
California come into full compliance with these regulations.
This report presents the results of this analysis along with the
results of additional air monitoring work requested by the Board.
In addition, an updated discussion of the measurement method
proposed for adoption by the Board is presented.
The staff, after reviewing the federal NESHAP regulation for
vinyl chloride has reached the following conclusions: (NESHAP does
not, in all cases, require the application of best available
control technology; (2) enforcement of NESHAP is extremely
difficult; (3) fugitive emissions are not adequately controlled;
(4) NESHAP does not include a total emission limitation for vinyl
chloride; (5) NESHAP does not assure that community exposure to
vinyl chloride will not exceed any specified level; (6) upset-breakdown
questions are not addressed adequately.
The staff has used air quality simulation modeling techniques to
provide estimates of ambient levels of VC that may result from
application of the federal NESHAP Standard. The analysis has
shown: (1) point source (stack) emissions from a facility just in
compliance with the federal 10 ppm limitation (assuming mass
flows scaled to plant throughput) produce maximum 1-hour levels
of VC of about 0.01 ppm. Ground level maxima would generally
occur within 100m of the plant and 24-hour average values would
probably be somewhat lower than those predicted by the model; (2)
fugitive emissions appear to play a dominant role in determining
community levels of VC; (3) the EPA emission factor for fugitive
emissions may be too high and a more refined emission inventory
is needed; and (4) total emissions from the Stauffer-Goodrich
facilities, if limited to about 0.5 kg/hr, would insure that a
0.01 ppm significant harm level would not be exceeded.
Monitoring conducted by the ARB an private industry since the
January Board Meeting suggests that: (1) ambient levels of vinyl
chloride in Saugus have dropped dramatically and (2) ambient
levels in Long Beach and Saugus are averaging well below worst
case modeling estimates. This may indicate that EPA estimates of
fugitive emissions are too high or that meteorological conditions
have not been conducive to maximum buildup of vinyl chloride
concentrations.
The vinyl chloride measurement method developed by the staff of
ARB's Atmospheric Studies Branch uses a bag sampler, followed by
direct-injection gas chromatographic analysis. The method
provides a minimum measurable VC level of about 0.10 ppm with a
standard deviation of about +0.002 ppm over the range between
zero and 1.0 ppm with good linearity. Further developmental work
since January has shown that the ARB method can provide reliable
measurements at the 0.01 ppm level and that the method can be
made less sensitive to hydrocarbon interference. Other sampling
and analysis techniques may be suitable but equivalency will need
to be demonstrated.