Report:

Stationary Source Committee

Synopsis:

The Stationary Source Committee met on Friday, March 21, 1997. A summary of that meeting is included with this report. The next meeting is April 18, 1997, at 10:30 a.m., in Conference Room CC8.

Recommended Action:

Receive and file this report.

Mee Hae Lee
Chair, Stationary Source Committee

Attendance

The meeting began at 10:35 a.m. Present were Committee Chair Mee Hae Lee and Committee Members James Silva (who left at 11:50 a.m.), Ron Loveridge (who left at 11:55 a.m.), and Nell Soto. Committee Members Marvin Braude and Norma Glover were absent. Present but not voting were Board Chairman Jon Mikels and Board Member Cody Cluff.

Summary

The Committee reviewed the items on their agenda (attached). Comments were noted on the following items:

1. Discussion of Area Source Credits

Stationary Source Compliance Senior Manager Pang Mueller explained the proposed rule, which was developed through an extensive public participation process, including ten Steering Committee meetings, over an 18-month period. EPA, ARB, and the business community support the proposed rule. However, the environmental community remains concerned about the calculation of credits. Also, the environmental community raised a concern regarding public notification of source-specific procedures for emission reduction quantification when neither pre-existing emission rates nor test methods are available.

The Board Members discussed the rule at length. Board Member Cluff asked a number of questions about the types of sources that would be eligible for credits. Gail Ruderman Feuer, Natural Resources Defense Council, spoke regarding the environmental community’s remaining concerns with the rule. She felt that the rule might provide too much credit to "dirty" equipment that only marginally reduces emissions. Bob Wyman, representing the Regulatory Flexibility Group, spoke on the same issue noting, however, that removing the "dirty" equipment from the market may produce the greatest environmental benefit. Chairman Mikels talked about the value in providing incentives for these types of non-regulated sources to advance technology and reduce emissions.

2. Report on CARB Hearing for the Proposed
Portable Equipment Registration Program

(Item taken out of order)

This item was discussed by Assistant Deputy Executive Officer Jack Broadbent and Stationary Source Compliance Senior Manager Larry Bowen, who told the Committee there are approximately 8,000 portable internal combustion engines (ICEs) in California and the AQMD has about 4,000 portable ICEs. Regulation 2100 was adopted in December 1995 to register portable ICEs and other equipment for use in participating districts. AB 531, promulgated in 1995, requires CARB to adopt a portable equipment rule to establish a uniform system to register portable ICEs and associated equipment. The rule will go to CARB’s Board for adoption on March 27, 1997. The proposed rule, which is more stringent in some areas and less stringent in others, is generally supported if emission standards are maintained.

Mr. Bowen told the Committee that staff recommends support of interim and final compliance limits for all engines and the "most stringent standard" concept for non-road and non-resident engines. Also, to include in the Resolution, a commitment to assess control requirements in light of the PM2.5 proposed standards and state emission standards developed as a result of the EPA non-road engine authority delegation. Recommendation to the Board should be as soon as practicable, but no later than July, 1998. AQMD staff supports annual and daily limits and CARB’s Executive Officer’s finding that if a district is effectively preempted from regulating engines, that the state voluntary program becomes mandatory. Recommendations also include amendment of reporting and recordkeeping requirements for centralized submittal; amendments such that inspection fees are collected by CARB and equitably distributed to districts, and inspection fees set at a level to cover the districts’ costs to enforce; and amendment of resident engines to disallow those for use in the AQMD we would not permit. Staff also recommends the registration certificate, or facsimile, with any operating conditions, should be present with the equipment at all times for enforceability. Otherwise, two inspections would be required to verify compliance.

Mike Lewis and Jeb Stuart, representing the Construction Industry Air Quality Coalition, presented to the Committee a report prepared by Booz-Allen & Hamilton on portable ICEs. (See attached executive summary; the full report is available from staff). The report provides information relative to the Board’s future consideration of amendments to Rule 1110.2.

3. SSC Permitting Summary for Calendar Year 1996

Deputy Executive Officer of Stationary Source Compliance Pat Leyden briefly discussed application processing efficiencies and historical application highlights from January 1, 1996 through December 31, 1996. The total number of applications (7, 30, and 180-day permits) in house at the start of 1996 was 7,375. The total number of applications received in 1996 was 11,704 and the number processed was 11,074. The total number of applications in house at the start of 1997 was 7,980.

4. Rule 1134 - Emissions of NOx from Stationary Gas Turbines

A presentation on this rule was given by Bill Thompson, Stationary Source Compliance Senior Manager. Mr. Thompson explained that this rule currently limits NOx emissions from gas turbine units rated at 0.3 MW and greater in size which, prior to August 4, 1989, were issued a valid Permit to Construct or Operate. Each engine must meet specific NOx emission limits based on unit size. If the specific NOx emission limits cannot be met without controls, then BACT must be applied. BACT usually consists of selective catalytic reduction (SCR). Los Angeles County Sanitation District (LACSD) installed three gas turbine units using sewage digester gas in 1984, and installed SCR in 1993. After extensive testing and attempts to meet the required NOx emission limit of 9 ppm, it has been determined by LACSD and AQMD staff that the required emission limit cannot be met. LACSD had requested that the AQMD amend Rule 1134 to relax the NOx emission limit of 9 ppm to 25 ppm for gas turbine units utilizing sewage digester gas. The only facility affected is LACSD’s Carson Plant.

Mr. Thompson said proposed amendments include definition changes, a NOx emission limit increase from 9 to 25 ppm, deletion of an outdated compliance schedule, deletion of an outdated emission control plan, monitoring and source testing clarification, a SIP-required recordkeeping fix, and exemption of clarity changes. He further explained policy issues which include a request to extend exempt hours for peaking gas turbine units from 200 to 1,300 hours, similar to RECLAIM; and a request to change the emission increases caused by changing the exempt hours from 200 to 1,300 to be placed under Rule 1135. The emission increase would be 254 pounds per day of NOx. The Public Hearing on Rule 1134 will be April 11, 1997.

5. Status Report on the Rule 461 Self-Inspection Program

Pat Leyden, Deputy Executive Officer of Stationary Source Compliance and Larry Bowen, Stationary Source Compliance Senior Manager, reported on this rule which requires CARB-certified vapor recovery equipment to be used at all gasoline dispensing facilities. There are 4,100 retail gasoline dispensing facilities in the AQMD that dispense approximately 90% of the gasoline district-wide. Rule 461 was amended in August 1995 to require station operators to inspect their vapor recovery equipment daily and AQMD-certified auditors to thoroughly inspect each station at least annually. The effective date was July 1, 1996. AQMD staff trained over 300 periodic auditors and 170 daily inspectors. In addition, 24 self-inspection training programs were approved that allow oil company staff and others to train daily inspectors.

It was further reported that a mini-audit of 200 stations from September through November indicated that a significant percentage of stations were not conducting the daily inspections as required, or keeping the necessary records. These companies were issued Notices to Comply. Also, the results triggered concern about industry implementation of the self-compliance program. Less than effective implementation could result in emission-related equipment failures.

Staff recommendations include meeting with industry to discuss the mini-audit findings and proposed actions; sending an advisory letter to each station operator and representative oil company, advising them of the requirements; training staff in the preparation of a targeted inspection campaign; conducting an inspection audit of a significant number of stations in all four counties, and issuing Notices of Violation, as appropriate; compiling results of the audit and briefing all interested parties; and amending Rule 461, if appropriate.

Ron Wilkniss, representing Western States Petroleum Association, expressed that group’s disappointment regarding the initial survey results. He said they would be working with staff to resolve whatever problems exist. They would like for this program to be a success.

6. Regulation XX - RECLAIM - Contractor’s Emissions

A brief report on this item was made by Pat Leyden, Deputy Executive Officer of Stationary Source Compliance. Ms. Leyden told the Committee that AQMD staff has been working with the regulated industries to ensure smooth implementation of RECLAIM. Proposed amended rule language concerning contractor emissions was continued from the February 14, 1997 Governing Board Meeting to the April 11, 1997 meeting, for further analysis. As a result, rule amendments were prepared to clarify the issue of contractor emissions at a RECLAIM facility.

The report adds a definition for contractor. The following monthly recordkeeping reporting requirements are being modified: (1) clarification that emissions from a contractor’s equipment, except for specific processes that do not contribute to a facility’s manufacturing process, should be accounted for by the facility in the same manner as rental equipment emissions; and (2) specifying the exclusion of emissions from certain contractor’s equipment at a Super Compliant facility.

7. Status Report on Title III Implementation

Deputy Executive Officer of Stationary Source Compliance, Pat Leyden, reported on the most recent negotiations with EPA on Title III implementation, which took place March 5-6, 1997, in San Francisco. Ms. Leyden told the Committee that negotiations were going well. In order to seek resolution to the concerns California has raised on implementing the federal Title III (Air Toxic) regulations, a core group of California representatives met with a core group of senior staff from EPA. The California team has pledged to ensure equivalent emission reductions. The main focus of the meeting was to discuss streamlining implementation and program delegation. The next stakeholders meeting is scheduled for March 27, 1997, in Washington, D.C.

The meeting was adjourned at 12:20 p.m.

Attachments

1. March 21, 1997 Committee Agenda (without its attachments)
2. Executive Summary of Booz-Allen & Hamilton Report Prepared for the Construction Industry Air Quality Coalition

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