 |
 |
 |
 |
|
|
|
|
|
|
|
Existing Regulations Which Affect Air Emissions From Laboratories in California
1. PLANNING
California Environmental Quality Act, California Public Resouces Code, section 21000 et. seq.
Before construction of a new laboratory building, Stanford must obtain approval from the Santa Clara County Planning Commission, or the Palo Alto Planning Commission. This approval must satisfy the requirements of the California Environmental Quality Act by evaluating environmental impacts. Generally, an environmental assessment is conducted to determine if an environmental impact report is necessary. The environmental assessment includes a thorough evaluation of the anticipated air emissions from the building, and has included risk assessments based on those air emissions. The air evaluation determines whether there are near and far cancer effects, calculates potential for near and far acute health effects and evaluates the possibility of emission re-entrainment in the proposed or adjacent buildings.
2. AIR PERMITS
California Bay Area Air Quality Management District, Rules and Regulations 2-1-113.2.11, 2-1-113.2.12, and 2-1-224.
Permits are generally required for sources of emissions unless an applicable exemption exists. A permit exemption exists for teaching laboratories and for research laboratories that meet all of the following:
a. laboratory floor space within a building is less than 25,000 square feet or the total number of fume hoods is less than 50,
b. open containers are to be avoided,
c. storage of open containers of volatile wastes is prohibited,
d. training for lab employees shall include information about minimizing emissions of volatiles,
e. lab personnel shall be directed to minimize open container procedures, and to avoid open container storage,
f. fume hoods must be posted with notices to avoid open container procedures and labs must be periodically inspected to ensure that the signs are present,
g. fume hoods must be monitored to ensure adequate face velocity,
h. evaporation of hazardous waste containing toxic air contaminants as a means of waste disposal is forbidden.
3. AIR EMISSION STANDARDS
A. General California Bay Area Air Quality Management District, Rules and Regulations, Regulation 1
This regulation prohibits air emissions from becoming a public nuisance.
B. Particulate matter
California Bay Area Air Quality Management District, Rules and Regulations, Regulation 6
This regulation limits emission from laboratory equipment used exclusively for chemical or physical analyses or experimentation to more than three minues every hour at Ringleman No. 2 limit.
C. Odorous substances
California Bay Area Air Quality Management District, Rules and Regulations, Regulation 7
The limitations of this regulation are applicable after the BAAQMD has received ten or more odor complaints from persons beyond the property line, within a 90-day period. Once the limits become effective, they are in force for 1 year from the last complaint received. The limits apply to odorous compounds or family of compounds and the types of emission points. Odorous compounds include dimethylsulfide, ammonia, mercaptans, phenolic compounds and trimethylamine.
D. Organic liquids
California Bay Area Air Quality Management District, Rules and Regulations, Regulation 8
E. Sulfur dioxide
California Bay Area Air Quality Management District, Rules and Regulations, Regulation 9, Rule 1
A general limitation requires that emissions of sulfur dioxide can not contain more than 300 ppm (dry) sulfur dioxide. Another section requires that emissions shall not exceed thresholds at the ground level on the perimeter of the property if the owner controls access, or at ground level enywhere on the property where the owner does not control access.
F. Hydrogen sulfide
California Bay Area Air Quality Management District, Rules and Regulations, Regulation 9, Rule 2
Emissions must not exceed thresholds at the ground level on the perimeter of the property if the owner controls access, or at ground level enywhere on the property where the owner does not control access.
4. AIR TOXICS INFORMATION AND ASSESSMENT
California Health and Safety Code, Section 44340
Facilities are required to prepare a comprehensive emissions inventory of listed toxic air contaminants. If emissions exceed threshold levels, facilities must conduct a health risk assessment. If the assessment shows elevated risk, exposed persons must be notified and the facility may be required to implement control measures. The list of toxic air contaminants includes EPA-listed HAPs.
5. SAFE DRINKING WATER AND ENFORCEMENT ACT (Proposition 65)
California Health and Safety Code, Section 25249, California Code of Regulations, Title 22, Sections 12000 et. seq.
Requires determination of cancer risk at the property boundary of specified set of chemicals, and notifications if results exceed a risk threshold.
6. CHEMICAL HYGIENE PLAN
29 Code of Federal Regulations,
section 1910.1450
8 California Code of Regulations, section 5191
The Chemical Hygiene Plan is designed to protect laboratory employees from chemical hazards, including inhalation exposure. Although the plan is considered a worker safety requirement, the overlap between practices that protect employee health and those that protect environmental health is very large for labs because persons attend to virtually all operations. Hence protection from inhalation exposure often reduces environmental emissions of toxic materials. The plan must cover standard operating procedures, control measures, and extra protection measures for particularly hazardous substances.
7. UBC and UFC -ventilation
Uniform Building Code, section 905 and Uniform Fire Code, section 80.105
Ventilation standards require that laboratories meet minimum ventilation rates and limit the amount of exhaust that can be recycled back into the building. The impact of these standards is to reduced the emitted concentration although the total quantity emitted it not affected.
8. HAZARDOUS WASTE REGULATIONS
California Code of Regulations, Title 22, sections 66262.34, 66265.173(a)
Require containers to be kept closed except when waste is being added or removed. Evaporation of waste is prohibited.
9. HAZARDOUS MATERIALS MANAGEMENT PLANS
Santa Clara County, Ordinance section B11-304.01 and City of Palo Alto, California Municipal Code section 17.16.010
Descriptions of protective measures used when storing hazardous materials are required as a part of the hazardous materials management plans (HMMPs). The HMMPs are required by County and City agencies.
10. TOXIC GAS REGULATION
Santa Clara County, Ordinance Sections B11-315 through 320
Potential for accidental discharges is reduced through leak testing, protective plugs, caps, inspections, exhaust ventilation, excess flow control, gas detection, emergency power. Emissions may require treatment.
11. SEWER CODE
Palo Alto, California, Municipal Code, sections 16.09.090 and 16.09.110
General provision to prevent accidental discharges, one of the ways that this is enforced is that all chemical containers are required to be closed.
Limiting the discharge of solvents and volatiles to the sewage treatment plant reduces air emissions at the plant.
12. ACCIDENTAL RELEASE PREVENTION
California Code of Regulations, Title 19, section 2735 et seq
Federal limits rarely apply to labs, but state standards apply to lower quantities. State mandated thresholds existed prior to the federal program. Under this program, if there is a potential
13. WASTE REDUCTION
California Code of Regulations, Title 22, section 67100 et. seq.
Requires preparation of waste minimization plans and reports. Waste minimization reduce emission of HAPs by focusing on the use of less hazardous materials and by reducing the quantities that are used in processes
Rules and Regulations Applicable to R&D Facilities in San Diego County
Veronica
Hoban from San Diego State University
(619) 594-6778 vhoban@mail.sdsu.edu
The California Air Resources Board delegates the regulation of stationary sources to the local air pollution control districts and air quality management districts. Accordingly, there are few state air quality regulations that apply to R&D facilities. The exception is Assembly Bill 2588, the "California Air Toxics 'Hot Spots' Information and Assessment Act of 1987." While the act originated as a state program, its requirements are now implemented by the local districts. As you are aware, AB 2588 has led California facilities, including most major universities, through an extensive process of emission inventory and health risk assessment. An interesting historical note, many universities (and hospitals) were brought into the program not because of their R&D use of chemicals, but because of their cogeneration plant emissions. Due to the extensive body of health risk data generated by AB 2588, most air districts have set aside their health concerns regarding universities.
The San Diego County Air Pollution Control District exempts certain laboratory equipment and related operations, including laboratory equipment and operations located at universities, from permit requirements. The exemption reads as follows:
Rule 11 Exemptions from Permit Requirements
The following laboratory equipment & related operations are exempt from permit requirements:
(i) Laboratory testing
equipment and quality control testing equipment, used exclusively
for chemical and physical analysis
(ii) Vacuum-producing devices use in laboratory operations
(iii) Hoods, stacks or ventilators
(iv) Research and development equipment
(v) Peptide and DNA synthesis operations
(vi) Equipment use to manufacture the following products, provided
the uncontrolled emission of VOCs from all such operations located
at a stationary source do not exceed 5 tons per calendar year
Copyright © 2002 The Campus Consortium for Environmental Excellence | contact_webmaster@c2e2.org