BOARD MEETING DATE: February 7, 2003
AGENDA NO. 21
Stationary Source Committee
SYNOPSIS:
The Stationary Source Committee met Friday, January 24, 2003. Following is a summary of that meeting. The next meeting will be February 28, 2003, 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 11:00 a.m. Present were Ron Loveridge, Chairman, (left at 12:04 p.m.), Jane Carney, (chaired after 12:04 p.m.), William Craycraft and Fred Aguiar. Absent was Leonard Paultiz. Cynthia Verdugo-Peralta was appointed as an ad hoc member of the committee for this meeting by Ron Loveridge.
INFORMATIONAL ITEMS
- Power Plant Emission Control Technology
Mohsen Nazemi, Assistant Deputy Executive Officer of Engineering & Compliance presented this item on the various options for controlling NOx emissions from power plants including turbines, internal combustion engines (ICEs) and boilers. This item was requested by Board member Cynthia Verdugo-Peralta and has been carried over from the October and November meetings. Mr. Nazemi explained that controls are typically installed as a result of modification of existing units, repowering of existing units and for new projects (central and distributed generation). - Report on Preview of 2003 AQMP
Dr. Elaine Chang, Deputy Executive Officer, Planning, Rule Development & Area Sources, presented this item earlier at the Mobile Source Committee, therefore the committee members waived the presentation. - Update of Rule 109 – Recordkeeping of Volatile Organic Compound Emissions
Jill Whynot, Planning and Rules Manager gave a brief status update on efforts to amend Rule 109, which involves recordkeeping. This rule development is a follow-up to the Recordkeeping Task Force work and deals with an exemption from monthly recordkeeping for super compliant materials. - Valero Wilmington Refinery Modified Hydrogen Fluoride Unit MOU
Pang Mueller, Engineering & Compliance Manager, presented this item. Ultramar Inc. – Valero Wilmington Refinery (Ultramar) proposes to modify the alkylation process at its refinery in Wilmington to eliminate the use of hydrogen fluoride (HF) in this process and replace it with modified hydrogen fluoride (MHF). MHF contains additives that reduce the volatility and aerosol formation properties of HF and the Ultramar refinery is the only remaining major user of HF in AQMD jurisdiction. In addition, Ultramar plans to upgrade the existing mitigation system that includes leak detection, process isolation, water spray and the HF deinventory facility. The use of MHF in combination with the mitigation system will significantly reduce the quantity of airborne HF in the event of an accidental release. Under the MOU, the company would agree to expedite the construction of equipment required for conversion to MHF by dedicating sufficient resources for timely submittal, preparation and review of both CEQA documents and permit applications, as well as the actual design, procurement and construction of the new system. Execution of this MOU will address Environmental Justice initiative enhancement # I-1, to reduce the risk associated with accidental release of HF in the Basin. - Report on Rule 1162 – Polyester Resin Operations
Larry Bowen, Planning and Rules Manager, presented this item. Staff was directed to conduct a technology assessment confirming the feasibility of applying gel coats using non-atomizing technologies. The report summarizes the results of that technology assessment. When Rule 1162 was last amended in November of 2001 the Board directed staff to conduct a technology assessment on the gel coat application requirement prior to the effective date of July 2003. The projected emission reduction is approximately 0.7 tons per day. - Status Report on PR 1127 – Emission Reductions from Livestock Waste
Dr. Julia Lester, Program Supervisor, Planning, Rule Development & Area Sources, briefed the committee on Proposed Rule 1127, "Emission Reductions from Livestock Operations." She reviewed livestock operation locations in the Basin, the latest emission estimates and dairy relocation trends. AQMP control measure WST-01 calls for a 50% reduction in ammonia and a 30% reduction in VOC from base year levels. Controls (e.g. PR1127) would only be implemented if emission reductions from relocations and water quality regulations do not meet the WST-01 goals. The VOC goal was met in 2001, but the 2006 ammonia goal will not be. PR1127 achieves the required additional reductions by specifying acceptable manure disposal options for increasing percentages of a dairy’s manure (50% in 2006). These options are an anaerobic digester, controlled composting facility, or shipment out of the Basin. Reductions from PR1127 in 2006 are 2.1tpd ammonia and 0.6 tpd VOC (overall reductions, including the impact of relocation, water quality regulations and current practices, are 11.1 tpd ammonia and 3.5 tpd VOC in 2006). Preliminary cost-effectiveness estimates are ~$2,000/ton of combined ammonia and VOC, ~$2,500/ton ammonia, and ~$9,000/ton VOC. A variety of issues and comments have been raised at working group and public meetings and have been addressed by staff. PR1127 is scheduled for Board consideration in May 2003, with implementation beginning in 2004.
NOx emissions are created in two ways: by the presence of nitrogen in the fuel (fuel NOx); and by the burning of fuel (thermal NOx). There are several pre-combustion and post combustion control technologies available for controlling NOx. Pre-combustion methods include fuel/feed modification such as ultra low nitrogen fuel and excess air combustion; temperature absorption such as flue gas recirculation and water/steam injection, and combustion staging/modification such as overfire air, ultra-low NOx burners and catalytic combustion (e.g. XONON cool air combustion).
XONON was certified by the ARB in June 2002 (at 2.5 ppmvd NOx and 6 ppmvd CO) and is presently installed and operated in a 1.5 MW turbine with two other installations proposed.
Post-combustion technologies include Selective Non-Catalytic Reduction (SNCR) and catalytic reduction such as Selective (SCR) and non-selective (NSCR) catalytic reduction. SCR and SNCR require the use of ammonia or urea while NSCR does not require ammonia or urea. SCR can achieve 80 – 95+ % reduction in NOx while SNCR can achieve from 40 to 70% NOx reduction. NSCR, on the other hand, can achieve an 80 – 95% NOx reduction. One example of NSCR is the three-way catalyst used to reduce NOx, CO and VOCs in rich burn ICEs. Another one is SCONOx which involves absorption and oxidation of NOx through a catalyst. SCONOx can also reduce CO and VOCs at the same time. ARB certified SCONOx (at 2 ppmvd NOx, 15% 02, and three-hour averaging) in November 1998.
AQMD is presently processing a permit for a power plant (Malburg in Vernon) where emission limits are 2 ppm for NOx and CO and 1.2 ppm for VOC with 5 ppm NH3 slip. The project is proposing to use SCR and oxidation catalyst to achieve this BACT emission level.
SCR is a mature technology and has been used and proposed in hundreds of installation while SCONOx is installed and operating in nine facilities with a few others proposed. Based on AQMD and other source information, SCONOx and XONON have higher capital costs than SCR. However, the SCONOx manufacturer has claimed that the life cycle cost of SCR is equivalent or greater than the cost of SCONOx.
One area of concern for SCRs is the use of ammonia which is an acutely hazardous material and a precursor to PM10. The total ammonia inventory in the SCAQMD is 185 TPD based on the 2000 AQMP. Industrial sources are 7% of this or 13 TPD. The percentage of the industrial source total contributed by NOx control is 5% of the 13 TPD, or 0.65 TPD. By 2004, it is expected that if all existing and proposed projects install SCR and all projects have a 10 ppm ammonia slip, ammonia from NOx control will increase to 14% of the industrial source inventory or 2 TPD. This amount will be about 1% of the total ammonia inventory in the Basin.
Ms. Verdugo-Peralta raised concerns about the transport and emission of ammonia and its impacts on AQMD environmental justice initiatives. Mr. Nazemi indicated that for all of these projects, only aqueous ammonia is allowed to be used and has to be transported in the aqueous form. Ammonia emissions impact on the environment is reviewed during the CEQA analysis. The ammonia slip is limited to 5 ppm and is required to be monitored through permit conditions. There are also new direct ammonia continuous emission monitoring systems (CEMS) that may be required once they are certified. Toxic risk analysis and/or modeling is also conducted for any ammonia slip during normal operation as part of permit evaluation.
A member of the audience, Mr. Tom Girdlestone of EmeraChem (SCONOx), stated that the Board should also consider the multi-pollutant approach for SCONOx since it could reduce NOx, CO, VOC and PM10 simultaneously.
There have been several meetings with industry, ARB and EPA. Staff will bring forward proposed rule changes once a proposal that can be approved by the oversight agencies is developed. There are two remaining issues at this time – a threshold (maximum amount that can be used to qualify for annual recordkeeping) and some technical details regarding test methods. There is a conference call next week with the three agencies to continue the discussion. Once these items are resolved, and if that is satisfactory to the proponents, a public consultation meeting will be held. The public hearing is tentatively scheduled for April.
Rita Loof, Radtech, commented that it is difficult to measure very low concentrations and important to develop the test methods. She stated that she did not understand EPA and ARB’s insistence on a threshold. Ms. Whynot explained their rationale and reiterated that a rule change would be proposed only if the ARB and EPA can approve it.
John Billheimer, Environmental Reality, commented that some Rule 109 exemptions are political compromises when it is not possible to measure low concentrations.
A working group of end users, gel coat manufacturers and application equipment suppliers helped identify the successes and some of the problems encountered by some users such as those involving porosity and film thickness. Meetings with the working group were followed up with field assessments and demonstration of the non-atomizing technologies by several companies in various manufacturing sectors within the composite product industry.
The assessment confirmed use of the technology is achievable by most of the industry and should be implemented. The remaining companies still need a little time to work out some implementation issues specific to their operations and staff will continue to work with them to ensure this is accomplished. There is also a problem with the non-atomizing application definition in the rule that will require amendment scheduled to be brought to the Board for consideration later this spring.
Board members asked a series of questions concerning the presentation. Board member Carney requested that a community meeting downwind of the dairies be held. Staff answered questions from Greg Adams (LACSD) and Board members about the emission reductions associated with new water quality regulations and current manure handling practices, the potential for other control options, the potential for additional rulemaking phases, and about possible funding mechanisms (for example, through credit generation) for advanced technologies such as anaerobic digesters. Board Member Carney expressed concern to make sure this rule will obtain all feasible reductions from this category.
WRITTEN REPORTS
All written reports were acknowledged by the Committee.
The meeting was adjourned at 12:28 p.m.
January 24, 2003 Committee Agenda (without its attachments)
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