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PROPOSAL:

Set Public Hearing June 12, 1998 to Amend Rule 431.1 - Sulfur Content of Gaseous Fuels

SYNOPSIS:

Proposed amendments address SIP changes recommended by the U.S. EPA; provide relief to landfill operators from having to remove sulfur compounds from landfill gas (LFG) to the required level of 40 ppmv since a cost-effective control technology has not been developed; and exempt a person burning LFG from the installation and operation of continuous fuel gas monitoring systems or continuous emission monitoring systems until December 31, 1998.

COMMITTEE:

Stationary Source, April 17, 1998, Reviewed

RECOMMENDED ACTION:

Set Public Hearing June 12, 1998 to amend Rule 431.1 - Sulfur Content of Gaseous Fuels.

Barry R. Wallerstein, D.Env.
Acting Executive Officer

Background

Rule 431.1 - Sulfur Content of Gaseous Fuels, was first adopted in November 1977 and was subsequently amended ten different times, with the most recent amendment in November, 1995.

The purpose of the rule is to reduce SOx emissions from the burning of gaseous fuels in stationary combustion equipment. In order to achieve that, Rule 431.1 imposes limits on total sulfur content of gaseous fuels.

Landfill gas (LFG) and sewage digester gas sulfur limits were first set in 1982.

The amendments in 1990 implemented Control Measure 88-F-2 of the 1989 AQMP by imposing a uniform sulfur limit of 40 parts per million by volume (ppmv) with a final compliance date of May 4, 1992. Continuous monitors were also required to be installed by May 4, 1992.

Subsequent amendments were adopted to provide additional time extensions to develop sulfur removal technology and a continuous total sulfur monitoring system, with a final compliance date of May 4, 1994.

The November 1995 amendments provided a three-year extension for landfills and additional flexibility for other affected facilities to comply with the rule requirements.

During the three-year extension, a landfill industry group was formed to study available technologies and to install several research demonstration projects in an attempt to find a cost-effective control technology to remove sulfur from LFG.

The study identified 78 sulfur removal processes, of which only a few were found to be technically feasible and thus considered for further investigation and pilot testing.

Cost-effective analysis revealed a range of $21,000 to $41,100 for large landfills and $32,800 to $68,600 for small landfills per ton of sulfur removed. Pilot tests were conducted to confirm these cost estimates. For comparison, permit applications subject to a cost-effectiveness analysis do not require best available control technology (BACT) if the cost is greater than $18,300 per ton of SO_x removed. Additionally, waste disposal of spent chemicals and non-regenerative carbon present cross-media environmental problems.

On February 11, 1998 the AQMD received a limited disapproval for Rule 431.1 to be implemented in the SIP, because of two minor deficiencies.

Proposal

After evaluation of the above events, it is recommended that proposed Rule 431.1 be amended to address the SIP changes recommended by the U.S. EPA to change the word "may" to "shall" in subdivision (f), Test Methods, and to require CARB and EPA approval of alternative monitoring plans in Attachment A, Section III; to provide relief to landfill operators from having to remove sulfur compounds from LFG to the required level of 40 ppmv, since a cost-effective control technology has not been developed, and to exempt a person burning LFG from the installation and operation of continuous fuel gas monitoring systems (CFGMS) or continuous emission monitoring systems (CEMS) until December 31, 1998.

AQMP and Legal Mandates

The proposed rule amendments correct two minor deficiencies necessary to obtain SIP approval. A noticed public meeting was held on March 25, 1998

CEQA & Socioeconomic Analysis

Pursuant to the California Environmental Quality Act (CEQA) and AQMD Rule 110, the AQMD, as lead agency, has prepared a Draft Supplemental Environmental Assessment (SEA) for the proposed amendments to Rule 431.1 - Sulfur Content of Gaseous Fuels. The Draft SEA is currently being circulated for a 45-day public review and comment period which ends on May 15, 1998. All comments received on the Draft SEA will be incorporated into the Final SEA for the proposed project.

The proposed amendments do not require additional controls or result in emission reductions and therefore, are not expected to impose cost or other socioeconomic impacts. Since there will be no additional compliance costs, consideration of cost-effectiveness and an incremental cost-effectiveness analysis is not applicable.

Implementation Plan

Persons burning landfill gas are exempt from having to install and operate a continuous monitor until December 31, 1998. If the person burning landfill gas chooses to use an alternative monitoring plan instead of a continuous monitor, the plan is required to be submitted to the AQMD by September 1, 1998. Until December 31, 1998 or upon approval or disapproval of the alternative monitoring plan, the person burning the LFG will determine and report the sulfur content of the fuel as required in the Rule 1150.1 Compliance Plan for that landfill.

Resource Impacts

Not applicable.

Attachments

Summary of Proposed Amendments

Rule Development Process

Key Contacts

Proposed Rule Language

Draft Staff Report

• Environmental Agencies

- Environmental Protection Agency, Region IX
- California Air Resources Board

• Public Agencies

- County Sanitation Districts of Los Angeles County
- County of Orange Integrated Waste Management Department

• AQMD Committees

- Rule Team Development
- Stationary Source Compliance

• Industry

- BFI
- Ogden Power Pacific, Inc.
- Chevron Products Company

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