Of all of the regulatory agencies that exist, the South Coast Air Quality Management District (AQMD) has proven to have the most challenging rules for commercial bakeries. We’ve boiled down the most common AQMD rules for such businesses so you’ll have a better overview of how to maintain compliance.
1. Rule 1147 (NOx Reductions From Miscellaneous Sources – Combustion Equipment)
For facilities that operate in the AQMD, Rule 1147 is a catch-all rule designed to limit the oxides of nitrogen (NOx) emissions from miscellaneous sources by imposing emission limits and establishing maintenance requirements. As it relates to bakeries and other food production facilities, Rule 1147 normally applies to newer major pieces of equipment (usually meaning they were installed before November 7, 2014), such as deep fryers, ovens, griddles, and coffee roasters.
2. Rule 1153.1 (NOx Emissions From Commercial Food Ovens)
While Rule 1147 applies to new pieces of equipment, Rule 1153.1 covers existing equipment, which is defined as equipment that was in operation at the current location before November 7, 2014.
Generally, the emission limit and maintenance requirements for Rules 1153.1 and 1147 are the same, with the key difference being that Rule 1153.1 allows for a longer time period for existing pieces of equipment to meet the emission limit.
The rule requires combustion-system maintenance to be performed in accordance with the manufacturer’s schedule and specifications. A copy of the manufacturer’s written maintenance schedule and instructions must be kept, and a record of the maintenance activity for a period of no less than three years must be retained.
3. Rule 1155 (Particulate Matter)
Commercial baking facilities tend to store dry ingredients such as flour and farina in outdoor silos. Emissions from these silos are typically vented to a filter or some sort of control equipment, such as a baghouse.
Rule 1155 applies to control-equipment-venting sources of particulate matter (PM). In general, units larger than 100 square feet in overall surface area must comply with Rule 1155.
Under Rule 1155, a commercial bakery is required to:
- Meet certain PM emission limits
- Prevent visible emissions from the unit
- Conduct visible emission inspections according to Environmental Protection Agency Method 21
- Conduct maintenance on the units in accordance with the manufacturer’s operation and maintenance manual or other similar written materials supplied by the manufacturer
- Maintain all records for a minimum of five years
In certain cases, Rule 1155 requires larger PM-control devices to install bag-leak detection systems (BLDS).
4. Rules 1146 and 1146.1 (Boilers)
Boilers are common pieces of equipment in any industrial facility, but in bakeries and food production facilities, we have seen boilers used to produce steam to dry material, provide moisture to a process, etc.
For facilities in the AQMD, most boilers are subject to either Rule 1146 or Rule 1146.1. Units larger than 5 million British thermal units (MMBTU) per hour are subject to Rule 1146, while smaller units are subject to Rule 1146.1.
No matter what their size, boilers must meet specific emission requirements via a source/emissions test, maintenance performance, and periodic emission testing using a portable analyzer. Compliance with the NOx- and CO-emission requirements is determined using a contractor approved under the AQMD’s Laboratory Approval Program (LAP). Records of all source tests must be made available to agency personnel upon request.
5. Rule 1153 (VOC Emissions From Ovens)
Rule 1153 covers commercial bakery ovens that have a rated heat input of more than 2 MMBTU/hr and an average daily emission of 50 pounds or more of volatile organic compound (VOC) emissions.
If a bakery oven is subject to the rule, it is generally required to reduce the VOC emissions from the process by either 70 or 95 percent, depending on the amount of VOC being emitted by the yeasts used. Typically, meeting these control efficiencies requires the installation of a VOC destruction device, such as a regenerative thermal oxidizer or a catalytic oxidizer.
Bakeries that are subject to this rule are generally required to submit applications for permits to construct and operate, and to demonstrate compliance with the VOC emissions limits.
6. Rule 1470 (Emergency Engines)
Rule 1470 applies to emergency backup generators, which are commonly found in food-production facilities. Any backup generator greater than 50 brake horsepower (bhp) is covered by the rule.
Generally, Rule 1470 requires that a covered engine meet certain operational limits on the non-maintenance and testing; comply with certain emission limits for CO, VOC+NOx, and diesel PM; conduct maintenance and testing; prepare reporting; and maintain record-keeping on the engines.
7. Rule 301 (Annual Emission Reporting)
Under Rule 301, a bakery with emissions over 4 tons per year (TPY) of VOC, oxides of sulfur (SOx), NOx, specific organics or PM, or over 100 TPY of carbon monoxide (CO) is required to calculate, report, and pay fees on the emissions from the operation on an annual basis. These reports (with any applicable fees) are typically due on March 1 of each year.
In addition, any facility that receives an Annual Emissions Reporting (AER) notification from the AQMD — regardless of the annual emission levels, even if no fees are due — is required to file the annual emissions report to update the facility’s emissions records.
The AQMD uses these reports to determine applicability to programs such as Regional Clean Air Incentives Market (RECLAIM) and Title V. Being part of one of these programs can greatly increase the complexity of the bakery’s overall compliance program, so it’s particularly important to ensure that emissions are accurately reported in these reports.
8. Regulation 20 (RECLAIM)
The RECLAIM program is a regional cap-and-trade program for emissions of NOx and SOx. Inclusion in the program is based on the amount of NOx or SOx reported on an annual emission report. Currently, the limit is four tons per year of either, but because bakeries tend to fire their equipment using natural gas, it’s possible to be subject to the RECLAIM program if the overall NOx emissions from the plant exceed 4 TPY.
If a facility becomes subject to the RECLAIM program, it must increase monitoring of operation parameters and the reporting of these emissions to the agency either on a daily, monthly, or quarterly basis.
9. Regulation 30 (Title V)
Title V is a federal operating permit program that was established by the EPA and is administered by the AQMD. Under the Title V program, bakeries have increased monitoring, reporting, and record-keeping requirements to demonstrate compliance with all of the applicable rules and regulations.
Similar to the RECLAIM program, inclusion in the Title V program is based on emissions reported on an annual emission report. The most common way to be subject to the Title V program is to have facility-wide NOx or VOC emissions in excess of 10 TPY.
10. Rule 201 (Permit to Construct) and Rule 202 (Temporary Permit to Operate)
In the AQMD, equipment that emits or has the ability to control the emission of air pollutants is required to have a permit to construct and/or operate that piece of equipment. A permit to construct remains in effect until the permit to operate — for which the application was filed — is granted or denied, or the application is canceled.
Before operating equipment with a permit to construct, a facility must notify the AQMD, at which point the permit to construct shall serve as a temporary permit for operation of the equipment until the permit to operate is granted or denied.
There are exceptions to these permitting requirements, and they are dependent on the situation and type of equipment as noted in Rule 219.
AQMD rules can be lengthy and complicated, but knowing the most common rules that apply to commercial bakeries puts you on the right path to compliance.
If you need to deal with California’s air-quality regulations but can’t wrap your head around the details, contact us for guidance.