September 8, 1995

South Coast Air Quality

Management District Board

The proposed amendments to Rules 2011 and 2012 include three major elements addressing the monitoring, reporting, and recordkeeping requirements of the RECLAIM program. One element is the concept of Super Compliant status, which allows facilities with major sources to reclassify them as large NOx sources or SOx process units if they operate below their adjusted 2003 allocation. This reduces monitoring costs for these facilities while yielding a clean air benefit for the basin due to early emission reductions. A second element is the expansion of the acceptable valid data range to 10 to 95 percent of the full scale span for continuous emissions monitoring systems (CEMS). In conjunction with this, is the establishment of criteria which allow CEMS to measure below 10 percent of full scale. This will allow for the measurement of low level emissions without invoking the Missing Data Procedures which could quickly deplete a facility's Allocation. The third element is the continuance of the use of interim emission calculation methodology in lieu of using the Missing Data Procedures for major sources that cannot certify CEMS under specific conditions.

Specifically, the proposed amendments will:

1. SUPER COMPLIANCE

Provide for the reclassification of a major NOx source to a large NOx source or a major SOx source to a SOx process unit, if a facility can be deemed Super Compliant.

The term Super Compliant denotes a facility with existing current emissions that are below their 2003 allocation as adjusted by the addition of ERCs converted to RTCs in accordance with the proposed amendments or a facility which can reduce its current emissions by the installation of air pollution control equipment to below its adjusted 2003 allocation. There are a few RECLAIM facilities which are already operating with emission levels at or below their adjusted compliance year 2003 Allocations. Additional facilities may be able to reduce emissions to the level of their adjusted compliance year 2003 Allocations in the short term by installing control equipment. Therefore, staff proposes to amend Rules 2011 and 2012 so as to establish a methodology whereby the operators of such facilities can have their major SOx sources reclassified as SOx process units or their major NOx sources reclassified as large NOx sources, as appropriate.

2. CEMS SPAN RANGE

Expand the acceptable valid data range of a CEMS from 20 to 95 percent of the full scale span (FSS) range to 10 to 95 percent of the FSS range. This will also apply to O2 analyzers.

Currently, RECLAIM Rules 2011, Appendix A (SOx Protocol) and 2012, Appendix A (NOx Protocol) require the use of missing data procedures anytime a CEMS is reading concentrations below 20 percent of FSS range. For example, if a CEMS has a certified span range of 0 to 100 parts per million (ppm), anytime the CEMS is reading concentrations below 20 ppm, missing data procedures would be invoked.

Since the RECLAIM program focuses on the measurement and reporting of actual emissions and the use of missing data procedures does not necessarily yield the measurement or reporting of actual emissions, it is imperative that a RECLAIM CEMS can accurately measure emissions at both low and high concentrations. To accommodate the capturing of low emissions, staff is recommending to increase the valid range of acceptable CEMS data to 10 to 95 percent of FSS range.

Include procedures under which data measured by a CEMS below 10 percent can be reported at the 10 percent FSS value or, if the CEMS has the "lowest vendor guaranteed" FSS range, can report actual measured values, rather than resorting to Missing Data Procedures.

Staff is proposing to include in the NOx and SOx Protocols criteria under which the measurement of concentrations that fall below 10 percent of the FSS range can be deemed acceptable, rather than triggering the Missing Data Procedures. Also, the proposed procedures address the fact that some CEMS technology has advanced to the point that it can accurately read low concentrations below 10 percent of lowest vendor guaranteed FSS range and it also provides a technological incentive to other CEMS manufacturers to improve their instruments' accuracy at low concentrations.

In addition, rule language is proposed to modify Attachment C to both the NOx and SOx Protocols in order to clarify the testing frequency required for semiannual assessments.

3. MISSING DATA PROCEDURES

Amend the Missing Data Procedures to allow facilities with major sources that cannot certify CEMS using standard equipment to continue using, under specified conditions, the interim period emissions calculation methodology up until December 31, 1995 or when the CEMS is finally certified, whichever is earlier, in lieu of using the Missing Data Procedures. This calculation procedure would be retroactive to July 1, 1995.

Also, amend the Missing Data Procedures to allow facilities with major sources that cannot certify CEMS because; (1) there is an inordinate cost burden associated with flow monitoring as specified under (B)(11); and (2) they cannot apply the Reference Methods as specified in Rules 2011(h)(1) and 2012 (j)(1) and Appendix A, to continue using the interim period emissions calculation methodology up until June 30, 1996 or when the CEMS is finally certified, whichever is earlier, in lieu of using the Missing Data Procedures. This calculation procedure would be retroactive to July 1, 1995.

Additionally, the proposed amendments clarify some Rule language and correct typographical errors. Also, staff is recommending that the relative accuracy requirements for stack gas volumetric flow measurement systems be changed from 10 percent to 15 percent to be consistent with the United States Environmental Protection Agency's Acid Rain Program (40CFR, Part 75) relative accuracy requirements.

At the August 11, 1995 Set Hearing, a comment was made that facilities which had not certified their CEMS by July 1, 1995 because they were awaiting the outcome of these amendments, should be allowed to continue to use the interim period emissions calculation methodology to report mass emissions instead of using the Missing Data Procedures. The proposed rule amendments cover two main topics: Super Compliant facilities and low concentration CEMS. Both proposed amendments provide for the retroactive correction of missing data using the interim period emission monitoring methodology, actual emission data, or data at ten percent of full scale span range, depending on the specific situation. In addition, the proposed amendments include language allowing for the retroactive use of the interim period emission calculation procedures for facilities which can not certify because further development is needed in CEMS technology (e.g. special probes) or there is an inordinate cost burden associated with stack flow monitoring that prevents certification.

AQMD staff has reviewed the proposed amendments to Rules 2011 and 2012 and determined with certainty that the amendments have no potential to adversely impact the environment and are thus exempt from the requirements of the California Environmental Quality Act (CEQA). The amendments pertain to the overall administrative structure of the program. The amendments do not introduce any new control technology not previously analyzed nor do they create any additional emissions from the alteration in reporting requirements. The amendments are exempt pursuant to State CEQA Guidelines Sections 15002(k) and 15061(b)(3) [SCAQMD CEQA Guidelines Sections 1.2(k) and 5.1(b)(3)]. As such, a Notice of Exemption has been prepared and will be filed with the county clerks for Orange, Riverside, Los Angeles, and San Bernardino counties immediately following the adoption of the proposed amendments.

THEREFORE, IT IS RECOMMENDED THAT YOUR BOARD

-- Certify the Notice of Exemption for the Final Environmental Assessment for Regulation XX in accordance with the attached resolution.

-- Amend RECLAIM Rules 2011 - Requirements for Monitoring, Reporting, and Recordkeeping for Oxides of Sulfur (SOx) Emissions and 2012 - Requirements for Monitoring, Reporting, and Recordkeeping for Oxides of Nitrogen (NOx) Emissions, as set forth in the attached.

Respectfully,

James M. Lents, Ph.D.

Executive Officer