BOARD MEETING DATE: November 1, 2002 AGENDA NO. 24
REPORT:
Stationary Source Committee
SYNOPSIS:
The Stationary Source Committee met Friday, October 25, 2002. Following is a summary of that meeting. The next meeting will be November 22, 2002, at 10:30 a.m., in Conference Room CC8.
RECOMMENDED ACTION:
Receive and file.
Ronald O. Loveridge, Chairman
Stationary Source Committee
Attendance
The meeting began at 10:40 a.m. Present were Jane Carney, acting Chair until Chairman Ron Loveridge arrived at 10:50 a.m. (Carney and Loveridge left at 12:00 p.m.), Leonard Paulitz (arrived at 10:45 and chaired meeting after 12:00 p.m.), and Cynthia Verdugo-Peralta. Absent were Norma Glover and Jon Mikels.
INFORMATIONAL ITEMS
Rule 1122 – Solvent Degreasers
Lee Lockie, Director of Area Sources presented this item. The proposed amendment will establish a new sunset date of January 1, 2005 for the exemption in (k)(1)(D) for degreasers with open-top surface areas less than 1.0 square foot, or with a capacity of less than two gallons, and used only for electrical, high precision optics or electronics applications; or aerospace and military applications for cleaning solar cells, laser hardware, space vehicle components, fluid systems, and components used solely in research and development programs, or laboratory tests in quality assurance laboratories. In addition, rule language is being modified to clarify rule intent.
Status Report on Rule 1113 – Architectural Coatings
Dr. Laki Tisopulos, Assistant Deputy Executive Officer, Planning, Rule Development & Area Sources, gave an update on changes to proposed amended Rule 1113 – Architectural Coatings based on additional public comments received. Rule 1113 which was amended on May 14, 1999, has been determined by the appellate court to require readoption. To ensure that VOC reductions are still achieved in a timely manner, staff is proposing to re-adopt the May 14, 1999 amendments with proposed changes to various compliance dates and other clarifying changes, while vacating the specific amendments adopted on May 14, 1999. The VOC emission reductions for Rule 1113 are approximately 21.8 tons per day. The Public Hearing will be on December 6, 2002.
BACT Guidelines Report
Marty Kay, Air Quality Analysis and Compliance Supervisor, Science and Technology Advancement presented this semi-annual report on BACT Guidelines. New listings have been added to the BACT Guidelines for major sources during the past six months. They include new and amended listings for furnaces, bulk material handling, dryers, heaters, printers, engines, plastic extruders, spray booths, boilers and gas turbines.
Update on Proposed Amendments to Rule 1421 – Control of Perchloroethylene
Emissions from Dry Cleaning Systems
Jill Whynot, Planning and Rules Manager, gave an update on Proposed Amendments to Rule 1421, highlighting the more recent or more significant issues. The issues are: toxicity, perc emissions estimates, VOC trade-off, and a recent industry hybrid proposal.
A recent toxicity study was summarized where researchers found a relationship with excess cancer rates in workers associated with the dry cleaning industry. A diagram was shown with emission points from perc machines. Staff summarized the mass balance approach and sampling used to estimate emissions, and described how the emission inventory has been revised downward during the rule development. Testing indicates that 50% of perc used is emitted. Industry recently sent data from New York inspections of dry cleaners which indicated a lower emission rate. There are numerous questions staff has about the applicability of this data. The sampling methods were described.
Some of the alternatives will result in increased VOC emissions, however, there are a variety of reasons why the very small increase in some contributing pollutants should be preferred over continuing levels of perc emissions.
Several industry groups are now proposing updating equipment in 5 years and requiring compliance with Rule 1402. Staff presented a graph of emission reductions for various alternatives, including baseline, original industry proposal, staff proposal, and an expedited schedule recommended by environmentalists.
An attorney representing an industry alliance raised the issue that there is additional source test data that shows a lower emission factor that should be preferred to staff’s estimated emission rate. EPA’s risk level of 100 in a million was mentioned as a safe risk and the EPA risk factor is 15 times more stringent than OEHHA. Staff explained that EPA does not set a safe level. Risks over one hundred in a million must be reduced, risks less than one in a million require no action, and risks between one and one hundred in a million should be evaluated for technical and economic feasibility of additional reduction. There was a request to take six months for additional emission testing in conjunction with adoption of an industry proposed alternative to the staff’s proposal at the November 1 meeting. The Board members asked several questions of staff.
A representative from an environmental health organization said it was not time to study the problem but the Board should act to correct the problem. The industry typically has "mom and pop" operators who would be in a much safer environment with non-perc alternatives.
A representative from the California Cleaners Association stated that cleaners would prefer a Rule 1402 type approach and that BAAQMD did a risk analysis indicating 90% of cleaners meet their risk limit. The industry does not want money for alternatives and she does not believe the technologies are ready.
A consultant expressed the opinion that the Air Quality Assistance Fund (AQAF) should be used for revolving loan or lease guaranty, which would help many businesses rather than used as a grant program to help just drycleaners. He believes that such action is more consistent with the history and basis of the program.
ACTION ITEM
Inspector Enhancement for Credit Generation Program Enforcement
Carol Coy, Deputy Executive Officer, Engineering and Compliance presented this item to approve two new Air Quality Inspector III positions, dedicated to port compliance. This includes compliance for Marine Vessel Credit Generation (Rule 1631), Port Community Air Quality Program Enforcement [AB 2650 – Lowenthal (H & SC 40720)] and other compliance activities such as smoking ship and petroleum coke piles (Rule 1158). Approved by Committee.
INFORMATIONAL ITEMS
Rule 1133 – Composting and Related Operations – General Administrative
Requirements, Rule 1133.1 – Chipping and Grinding Activities, Rule 1133.2 – Emission Reductions from Co-Composting Facilities
Zorik Pirveysian, Planning and Rules Manager, presented a brief overview of the proposed rules for composting and related operations. The proposed rules would in part, implement Control Measure WST-02 – Emission Reductions from Composting, which was included in the 1994 and 1997 AQMPs as well as in the 1999 Amendment to the 1997 Ozone State Implementation Plan for the South Coast Air Basin. The control measure called for the development of an emissions inventory as well as identification of technically and economically feasible control options for composting operations. Accordingly, a technology assessment was conducted by staff, which provided the industry profile and background information on composting operations, developed an estimated emissions inventory, identified and evaluated various control methods, conducted cost-effectiveness analysis, and provided recommendations for rule development. The technical assessment was presented to and approved by the AQMD’s Governing Board in April 2002. Accordingly, the Board directed staff to proceed with rulemaking and develop separate rules for each sector of composting. A composting technical advisory committee and a co-composting subcommittee were subsequently formed to further evaluate technical issues and assist in rule development.
PR 1133 would require composting and chipping and grinding facilities to register with AQMD and provide their facility and throughput information (e.g., type and amount of feedstock and products, process description, etc.). These facilities will also be required to provide annual updates to AQMD on their registration information. PR1133.1 would establish holding and/or processing time requirements for greenwaste and foodwaste chipping and grinding activities in order to prevent inadvertent decomposition associated with stockpiling greenwaste and/or foodwaste for extended periods of time.
PR1133.2 would require new co-composting operations to enclose their active co-composting operation and use forced-air aeration system for their curing part of the operation. Both the air exhaust from the enclosure and the aeration system are to be vented to an emission control system with a control efficiency of at least 80 percent for VOC and 75% for ammonia emissions. New co-composting operations may alternatively achieve an overall control efficiency of 80 percent by weight for VOC and 75% for ammonia emissions from both the active and curing phases of the composting process using any composting or control method. This alternative method of compliance would also require the submittal of a compliance protocol within one year prior to start-up. Under PR 1133.2, existing co-composting operations will be required to demonstrate an overall control efficiency of 70 percent for VOC and 65% for ammonia emissions. Existing co-composting operations would also be required to submit a compliance protocol one year prior to their effective date of compliance. The compliance date for new co-composting operations is as of the date of adoption of this rule. Existing co-composting operations compliance dates range from the year 2007 to 2009 depending on the size of their operations.
The emissions inventory for co-composting operations is estimated to be 1.67 and 2.74 tons per day of VOC and ammonia, respectively. The proposed rule is expected to reduce VOC and ammonia emissions by 70 and 65 percent (1.2 tons of VOC per day and 1.8 tons of ammonia per day) from existing co-composting operations. Depending on the control method selected, the cost-effectiveness would vary for co-composting facilities. For new co-composting facilities, the cost effectiveness is estimated to be about $24,000 per ton of VOC and $11,000 per ton of VOC and NH3 reduced. For existing co-composting facilities, the cost effectiveness would vary based on the composting/control methods selected. For existing facilities, assuming enclosure (with forced aeration system) for active phase and forced aeration system for curing phase, the cost-effectiveness would range from approximately $9,000 to $10,500 per on of VOC and NH3 reduced (and $23,000 to $27,000 per ton of VOC reduced) depending on type of enclosure.
The key issues for the Proposed Rule 1133.2 include: compliance for existing facilities that have limited lease term at their existing locations, control efficiency of biofilters (as an emission control equipment) for reducing VOC and NH3 emissions; and consideration for smaller co-composting facilities (e.g., those which already have control equipment).
Following a public workshop held on October 10, 2002, a public consultation meeting will be held on October 29, 2002 and CTAC and Co-Composting Subcommittee meetings on the same date. The Set Hearing and Public Hearing for the proposed rules are scheduled for November 1 and December 6, 2002, respectively.
Rule 1173 – Control of Volatile Organic Compound Leaks and Releases from
Components at Petroleum Facilities and Chemical Plants
Larry Bowen, Planning & Rules Manager, presented this item which included a brief discussion on the background and new requirements for this amendment, and the revisions made since the September 2002 Stationary Source Committee meeting. The revisions were a partial rule exemption based on flash point, physical tagging of heavy liquid pumps, defining process pressure release devices (PRDs), requiring simultaneous recording of VOC analyzer reading at the time of inspection, expanding the table listing the required repair periods for leaking components, and providing for an additional three to six months to implement the various requirements of PAR 1173.
Mr. Bowen stated that the proposed amendments, when fully implemented, would achieve an emission reduction of 0.57 tons per year of VOC at a cost of $48 to $10,712 per ton of VOC reduced (overall average: $157 ton VOC) and that this cost would be offset by the monetary savings from reduced emission fees. Two issues associated with PAR 1173 are the cost of controlling atmospheric PRDs (determined to be cost effective by staff) and that the leak threshold for light liquid valves and connectors should be reduced to 100 ppm VOC (determined to be not cost effective).
Ron Wilkness expressed concern regarding control requirements for PRDs.
Report on Rule 461 Implementation
Carol Coy, Deputy Executive Officer, Engineering and Compliance, gave a brief overview of the report on Rule 461 Implementation. This report was requested by the AQMD Board to be provided in November 2002, regarding the frequency of testing when Rule 461 was last amended in April 2000. The April 2000 amendments to Rule 461 have significantly improved compliance and reduced emissions at service stations. No further changes to Rule 461 are being recommended at this time.
Power Plant Emission Control Technology
This item has been carried over to the November meeting.
WRITTEN REPORTS
All written reports were acknowledged by the Committee.
South Coast Air Quality Management District