REPORT:

Stationary Source Committee

SYNOPSIS:

The Stationary Source Committee met Friday, November 21, 1997. Following is a summary of that meeting. The December Stationary Source Committee meeting has been canceled; thus, the next meeting is scheduled for January 23, 1998, at 11:00 a.m., in Conference Room CC8.

RECOMMENDED ACTION:

Receive and File.

Mee Hae Lee
Chair, Stationary Source Committee

Attendance

The meeting began at 11:38 a.m. Present were Committee Chair Mee Hae Lee (who left at 12:27 p.m.) and Committee Members Leonard Paulitz (who left at 12:55 p.m.), and Jon Mikels (who left at 12:56 p.m.). Absent were Committee Members Richard Alarcon, Ronald Loveridge, and James Silva. Also in attendance were Board Vice-Chairman Norma Glover (who appointed herself to the Committee when Ms. Lee left) and Board Member Nell Soto (who was appointed to the Committee when Mr. Paulitz and Mr. Mikels left).

Summary

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

1. Rule 1146.2 - Emissions of NOx from Boilers and Heaters 75,000 to 2MM Btu/Hr

Assistant Deputy Executive Officer of Stationary Source Compliance Jack Broadbent gave the presentation and explained that this rule affects approximately 65,000 units in the South Coast Air Basin. These units are located in a variety of places, such as commercial office buildings, restaurants, motels, dry cleaners, schools, etc. The rule is based on Control Measures CMB-B and CMB-02B (from the 1994 and 1997 AQMPs). Mr. Broadbent said the proposed requirement includes an exemption from retrofit for low-usage units. There is a potential 2005 retrofit compliance date for less than 1,000,000 Btu/hr units manufactured after 1991.

Mr. Broadbent said the rule will reduce about 9 tons per day of NOx by 2006. A public workshop was held on September 10, 1997, and a public consultation meeting on October 28, 1997. He told the Committee that staff has been working with the Gas Appliance Manufacturers Association (GAMA) and the Southern California Gas Company (SoCalGas). The Ventura County Air Pollution Control District currently requires retrofit down to 1,000,000 Btu/hr. He also said the new City of Pasadena boiler is specified to meet Proposed Rule 1146.2. Mr. Broadbent told the Committee that plans were being made for a Steering Committee that would look at concerns regarding safety, cost-effectiveness, etc. This committee would include GAMA.

He told the Committee of a three-phase study (each phase lasting approximately 18 months) to further evaluate technology advancement, cost impacts, and overall cost-effectiveness of new units (75,000 - 400,000 Btu/hr), retrofit units >1,000,000 - 2,000,000 Btu/hr), and retrofit units >400,000 - 1,000,000 Btu/hr). The study of each grouping of units will be completed approximately 18 months prior to its implementation date in the rule and results will be reported to the Board at the completion of each phase of the study. The proposed study will be outlined in the rule’s Board Resolution.

Mr. Broadbent discussed industry’s concerns regarding fuel savings of low-NOx units, baseline NOx levels of uncontrolled units, and capacity factor (fuel use). Regarding retrofits, Mr. Broadbent explained the potential safety concerns associated with retrofits, particularly for units of 1,000,000 Btu/hr or less; the enforcement of a large number of affected units; and the timing of retrofits (the current proposal is for 2002 and 2006).

Ms. Lee asked what the cost of retrofit would be. Mr. Broadbent said it would be as low as $6,000 up to about $8,500 per unit.

Mr. Paulitz asked why the concerns in this area if it works in Ventura County. Mr. Broadbent responded that it was due to volume. There are only about 60 retrofitted units in Ventura County and staff estimates that there are about 5,000 in the South Coast Air Basin.

Lee Wallace of Pacific Enterprises says the rule affects 60,000 (new and retrofits) sources and they do have some issues from this complicated rule they would like to have resolved.

John Billheimer said that small businesses are mainly affected by this rule and the small values should be looked at carefully. He suggests taking a look at all the low values to see the public creditability aspect of it.

2. Rule 1118 - Emissions from Refinery Flares

Stationary Source Compliance Senior Manager Mohsen Nazemi gave the presentation on this rule. He explained that this is a two-phase rule. Proposed Rule 1118 implements Phase I which requires monitoring of flare operations to determine if flares are a significant source of emissions. Phase II will evaluate data generated from Proposed Rule 1118 to determine the need for, or the level of, flare emissions control. He said the reported emissions from refinery flares are based on emission factors which are not fully representative of the actual emissions. The proposed rule requires preparation and submittal of a Flare Monitoring and Recording Plan and to classify flares as clean, emergency, or general service. The requirements would include limited monitoring/recording for Clean Service Flares, but more extensive monitoring/recording for Emergency and General Service Flares; calculating pilot and purge gas quantity and quality; continuous monitoring of vent gas quantity and periodic sampling for sulfur (S) and BTU (at each significant flare event); and monitoring and recording vent gas with a Continuous Flow Monitor (CFM) or a combination of CFM and on/off switches.

Mr. Nazemi said the recordkeeping and reporting would consist of calculating and reporting criteria emissions quarterly and maintaining records for two years. The schedule would be to submit the plan 90 days after adoption and to begin monitoring flares six months after approval of the plan. He told the Committee that the rule is Phase I of a 2-step control measure, and Phase I only requires monitoring and recording of flare operations. No direct emission reductions are required in Phase I. Mr. Nazemi said the total annualized cost of the monitoring, recording, and reporting requirement for this rule, for all the refineries, is a maximum potential of $4.1 million per year.

Mr. Nazemi reported the major concerns of industry (Western States Petroleum Association (WSPA)/Western Independent Refiners Association (WIRA)) are that, prior to adoption, it should be demonstrated that the benefits outweigh the cost of the rule and that mitigation exists for emergency flaring. They also have concerns in the area of Continuous Gas Flow Monitoring (volume); periodic gas sampling (S and BTU); time allowed for installation (9 months vs. 6 months); and they would like the rule revisited after two years of monitoring to evaluate the data. The major concerns of the environmental communities (Citizens for a Better Environment (CBE)), who support the rule in general, are to require identification of toxics in the vent gases to flares; reevaluate and improve emission factors to avoid underestimation; require actual measurement of vent gases to flare; and quickly move to Phase II to control flare emissions. He told the Committee the rule is scheduled for Public Hearing January 9, 1998.

Acting Executive Officer Barry Wallerstein told the Committee that this has been an item for discussion since 1984.

Ms. Lee asked what the time frame is for Phase I and Phase II. Mr. Nazemi answered that, if adopted at the January Board meeting, implementation would take place the latter part of 1998, that two years of monitoring information was recommended to best develop requirements, and Phase II would be considered in the year 2000.

Ron Wilkniss of WSPA explained that flare systems are safety systems consistent with past rules. He said it is not possible to measure emissions from flares. He asked for a delay of this rule and was concerned that WSPA was not certain of the content of the proposed rule.

Steve Mallon of Ultramar said the information is available, but they have not been asked for it.

Stationary Source Compliance Assistant Deputy Executive Officer Carol Coy pointed out the rule proposal had been delayed 30 days to accommodate WSPA’s request for additional review time and that the only changes between WSPA’s last review copy and the proposed rule was language to incorporate several of WSPA’s recent requests.

The Committee recommended this item to the Board for consideration.

3. Regulation IX - New Source Performance Standards (NSPS)

Stationary Source Compliance Senior Manager Ed Pupka gave a brief presentation. At the December Board meeting, these proposed amendments to Regulation IX will be presented. These are industry-specific standards of performance that EPA promulgates nationwide and which include such things as compliance determination, performance testing, and emissions limits. He said that NSPS is in effect whether or not the District adopts it. Mr. Pupka said that NSPS in this action are less stringent than District rules in all cases except for landfills (Rules 1150 and 1150.1), where the requirements differ.

4. Board Review of Permits for Multi-Year, Multi-Phase Projects

(Item #8 on the agenda)

Stationary Source Compliance Deputy Executive Officer Pat Leyden reported that a draft Board Policy has been developed. This policy was developed at Board request during the special Saturday meeting on LAXT to ensure future Board review of large, significant projects. The policy applies to multi-year, multi-phase projects subject to District permits under Rule 205. These projects are large, significant projects that are designed, permitted, and constructed in phases over an extended period of time. She also proposed a form "Permit Status Report on Multi-Year, Multi-Phase Projects," which could be brought to the Board each month with information on projects in this category which are seeking permits. The Board could then ask staff to bring back a full report the following month on any project they would like to have more information on. She also proposed a 60-day continuance to allow time to notice and hold a public consultation meeting on the proposal.

Greg Adams of the Los Angeles County Sanitation District (LACSD) said he supported the 60-day continuance and opportunity for public input. He also explained some unintended consequences of the proposal regarding public facility permitting.

Ms. Leyden said a workshop will be held and this item will be brought back to the Board.

5. Status on Environmental Justice Initiatives (Four Initiatives for Stationary Source Committee Review)

(Item #6 on the agenda)

Initiative #2 - Technology Advancement Assistant Deputy Executive Officer Chung Liu said no discussion was necessary; most Board Members had previously heard the discussion at the Administrative Committee.

Initiative #8 - Carol Coy gave a brief presentation on enhancement of Field Inspection Technology. This initiative calls for staff to use modern advances in technology for enhanced field inspection purposes to better detect pollution problems identified by the public and investigate ways to enhance AQMD’s field presence. Ms. Coy said November goals have included the preparation of work plans to refine testing and analysis technologies (being handled by Applied Science and Technology Director Mel Zeldin) and to improve in-field enforcement capability. These work plans were presented to the Committee and will be on the December Board agenda for approval. During December, an RFP for a state-of-the-science contract study to identify advanced inspection, testing, and analytical technology will be developed. A peer review group will be established to review all recommedations.

Greg Adams of LACSD expressed approval of what is being done with regards to hand-held equipment evaluation for Rule 1110.2 compliance.

Initiative #9 - Mr. Broadbent discussed I.C. engines which are located in a neighborhood and the potential impacts on schools or health care facilities. He said that recently a statewide portable I.C. engine program was adopted, whereby operators of the equipment can move around without being re-permitted by the District and without having impacts evaluated. He said that concern generated this initiative. Mr. Broadbent told the Committee we will be looking for a way for engine operators to notify the District when they will be located near schools, health care facilities, etc. The State of California has been very open to the idea being incorporated into part of the program and they will be initiating a working group beginning in January 1998. He said he would be reporting back to the Committee on this.

Greg Adams said there was a need for portable diesel equipment for emergency purposes, such as earthquakes, floods, etc.

Ms. Soto stated that perhaps language could be incorporated regarding portable engines for emergencies.

Initiative #10 - Mr. Broadbent explained that the Board will re-open for public comments the toxics significance thresholds for cancer and non-cancer impacts contained in Rule 1402 - Control of Toxic Air Contaminants from Existing Sources, and consideration of additional compounds and non-carcinogenic impact prevention into Rule 1401 - New Source Review of Carcinogenic Air Contaminants. Mr. Broadbent further discussed the status of rule development efforts which include a Board Air Toxics Workshop on December 18, 1997; rule development staff participation in the Air Toxics Technical Review Group; a working group to be established as a subset of the Environmental Justice Task Force established under Initiative #5; and rule development analysis needed.

6. Regulation XXX - Title V Permits

(Item #7 on the agenda)

Pat Leyden briefly told the Committee of a meeting set up for December 1, 1997 with EPA in San Francisco. One or two Board Member may attend. Discussion at that time will include portable equipment listing on Title V permits, periodic monitoring requirements, and SIP gap issues.

Due to time constraints, Agenda Items 4 and 5 were not discussed.

The meeting was adjourned at 1:39 p.m.

Attachments

November 21, 1997 Committee Agenda (without its attachments)

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