State of California

State Building
107 South Broadway
Los Angeles, CA

July 30, 1981
10:00 a.m.



81-15-1 CONTINUATION OF Public Meeting to Consider a 001
Suggested Alternative Emission Control Measure
(Bubble Rule) to Source-Specific Emission Limitations
(not including discussion of compounds proposed for
special treatment).

81-15-2 Workshop to Receive Comment on Compounds Proposed for
Special Treatment in Suggested Control Measure.

81-15-3 Other Business
a. Closed Sessions
1. Personnel (as authorized by the State Agency
Open Meeting Act).
2. Litigation (Pursuant to the attorney-client
b. Research Proposals
c. Delegations to Executive Officer


ITEM NO.: 81-15-1

A Report to Consider An Alternative Emission Control Measure
(Bubble Rule) to Source-Specific Emission Limitations.


Federal and state laws require that California agencies adopt
regulations to reduce emissions of air contaminants which
contribute to the violations of ambient air quality standards.
These standards, which are designed to protect the public health
and welfare from adverse effects of air contaminants, are
currently exceeded in many of the air basins in California.
Accordingly, local air pollution control districts (APCDs) have
developed numerous source-specific emissions control measures.
These source-specific measures require reductions of specific
pollutants from specific pieces of equipment, processes or

An alternative to source-specific rules is what has come to be
known as a "bubble rule". In general, a bubble rule
theoretically allows a dome or "bubble" to be placed over a
facility, in effect treating all pieces of equipment or processes
at a facility as a single source. A source operator is allowed
to propose a plan for the entire facility which would provide
that the rate of all the emissions of the same pollutant that
come out of the facility are no greater than if each piece of
equipment or process at the facility complied with all of the
individual source-specific regulations. If a district confirmed
the emissions calculations and if provisions related to
enforceability and prevention of increases in emission of
hazardous compounds are adequate, a bubble plan could be

The proposed alternative emission control measure would provide
industry with a way of tailoring more cost-effective control
systems necessary to achieve emission reductions required by air
pollution control districts under source-specific control
measures. Accordingly, the bubble rule serves as an adjunct to
existing rules and regulations of the air pollution control
districts; it does not require new control measures, and will
neither increase nor decrease emissions. It merely represents an
administrative tool which districts and source operators can use
to reduce the cost of pollution control.

Bubble plans developed by source operators and approved by the
air pollution control officer (APCO) would have to contain
certain minimum requirements which ensure: (1) attainment and
maintenance of the ambient air quality standards as expeditiously
as practicable; (2) reasonable further progress toward attainment
of the ambient air quality standards; (3) enforceability; and (4)
protection from increases in emissions of hazardous compounds.
The proposed rule provides guidelines from which a source
operator and districts can develop enforceable permit conditions
which satisfy these requirements.

To further protect the public health, the alternative emission
control proposal includes a list of compounds which should not
be bubbled with a less hazardous compound or any other hazardous
compounds. This would prevent a source operator from increasing
the emissions of the hazardous substance in exchange for
decreases in emissions of a less toxic compound.

Under the proposal, source operators could develop bubble plans
for those emission sources which are regulated by source-specific
control measures approved and adopted by the local districts.
However, bubble plans developed under the bubble rule would not
apply to or supersede the conditions that a source must meet
under new source review (NSR) rules, prevention of significant
deterioration (PSD) requirements, or new source performance
standards (NSPS) promulgated by EPA. It is important to remember
that the proposal is intended to serve as an adjunct to
source-specific control measures and would not require emission
control beyond the current levels of these source-specific

The proposal was developed under the Suggested Control Measure
Development Process and has been discussed by the Technical
Review Group (TRG) at a number of meetings. In addition, the ARB
staff, in conjunction with the staff of the South Coast Air
Quality Management District (SCAQMD), has conducted two workshops
to discuss the proposal with industry, the districts, and
concerned citizens. With the exception of the list of substances
which should be considered as hazardous compounds, the TRG and
the ARB staff are in agreement regarding the proposed approach.
The TRG has taken no position on the hazardous compound list, but
instead requested that the ARB identify specifically those
compounds that should be considered as hazardous.

Based on its review of the proposed bubble rule, staff recommends
that the Board find the proposal a suitable means for complying
with the emission limitations set forth in district rules and
regulations. Staff also recommends that the board identify a
number of compounds as hazardous for the purposes of
administrating the bubble rule, and approve the provisions of the
proposed bubble rule which are included to eliminate the adverse
environmental and health impacts which may be associated with the
bubbling of hazardous compounds.

The proposed bubble rule is designed to complement existing
rules. Because the proposal does not further restrict or allow
increases in emissions from any particular process, industry or
pollutant, there is no known environmental impact inherent in its