BOARD MEETING DATE: November 7, 2003
AGENDA NO. 23
Stationary Source Committee
SYNOPSIS:
The Stationary Source Committee met Friday, October 24, 2003. Following is a summary of that meeting. The next meeting will be November 21, 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 10:35 a.m. Present were Ron Loveridge, Chairman (left at 11:30), Jane Carney, William Craycraft, Fred Aguiar (left at 12:05), and Leonard Paulitz (arrived at 10:45 and chaired upon Ron Loveridge’s departure).
ACTION ITEM
- Determine the Next Committee Meeting Date
The Committee approved the next meeting date to be November 21, 2003.
INFORMATIONAL ITEMS
- Update on Rule 1113 – Architectural Coatings
Larry Bowen, Planning and Rules Manager, presented this item. Staff is proposing amendments to Rule 1113 to partially fulfill the AQMP commitment under Measure CTS-07 to adopt a rule this year that achieves additional emission reductions of 8.5 tons per year of VOCs from architectural coatings and clean-up solvents. The balance of the commitment will be achieved by a separate amendment to Rule 1171 – Solvent Cleaning Operations. An overview of the proposed amendments was presented to the Committee last month. This presentation focused on the changes to the original proposal that staff is recommending in response to the public comments received. - Annual Status Report and Technology Assessment on Rule 1113 – Architectural Coatings
Lee Lockie, Director, Area Sources, summarized information presented in the 4th Annual Status Report on Architectural Coatings which includes a comprehensive technology assessment of compliant coatings. She discussed surveys, site visits and coating evaluations that indicate the availability and continuing use of architectural coatings that meet current and future VOC limits stipulated in the rule. These conclusions are drawn primarily from surveys of trends in sales of compliant coatings, job site visits and interviews with contractors who apply coatings as well as past and current technology studies conducted by the District and other agencies. Alternate means of rule compliance were also discussed including the averaging compliance option and the small container exemption, both of which are utilized by some manufacturers to comply with certain elements of this rule. She stated that staff is continuing to work with manufacturers and applicators to further evaluate the performance of several coating categories subject to future limits in the rule. Progress on these efforts will be presented as part of the next Annual Report in December of 2004. - Update on Rule 1171 – Solvent Cleaning Operations
Lee Lockie, Director, Area Sources, discussed the 25 g/l proposed limit for architectural coating application cleaning under November proposed amendments to Rule 1171 - Solvent Cleaning Operations. Ms. Lockie discussed ongoing testing of compliant materials for cleaning various architectural coatings and stated that staff will continue to work with industry in conducting testing of cleaning materials for coating application equipment where the architectural coatings chemistry may not be compatible with the cleaning requirements of the rule - Rule 1148.1 – Oil Field Production Wells
Rule 222 – Filing Requirements for Specific Emission Sources Not Requiring a Written Permit Pursuant to Regulation II - Update on Rule 1105.1 – Reduction of PM10 and Ammonia Emissions from Fluid Catalytic Cracking Units
- Status Report on Mitigation Fees Related to Rule 1173 – Control of VOC Leaks and Releases from Components at Petroleum Facilities and Chemical Plants
- Rule 461 - Gasoline Transfer and Dispensing
- Best Available Control Technology Guidelines Report
First, a change to the compliance dates for clear wood finishes, stains, waterproofing sealers and waterproofing concrete and masonry sealers is proposed to allow additional time for reformulation for those that do not have complying products on the market. Second, the limit for waterproofing sealers and concrete and masonry sealers has been changed to 100 grams per liter. Although there are compliant materials on the market, this change will allow for a wider range of compliant products to choose from without a significant impact on the potential emission reductions.
The proposal to reduce the limit for low-solids stains and waterproofing sealers is being withdrawn. All low-solids coatings will remain at a limit not to exceed 120 grams per liter of material. In addition, there has been clarifying language added to the averaging compliance option provision and a new subcategory of roof coatings has been established, aluminum roof coatings, with a proposed limit of 100 grams per liter.
At the time the presentation materials were forwarded to the committee members there were a number of outstanding issues. Staff now has proposed resolutions for those issues. For the elimination of the quart container exemption for clear wood finishes, staff is proposing phase out two years after the new limit goes into effect and in the interim, to establish emission limits on those coatings sold in the small containers. To address the issue on deck stains, staff proposes to extend the compliance date an additional year to July 1, 2007. This matter will also be addressed as part of a technical assessment required by the rule. Staff is also proposing to allow small manufacturers of waterproofing concrete and masonry sealers to be eligible for the limited exemption in effect for small manufacturers of several other coating categories. An exemption is also proposed until January 2007 for roof coatings that meet a 100 gram per liter limit that are Energy Star certified to allow time for recertification of their reformulations by the certifying agency.
The proposed rule will achieve about 4 tons per day of emission reduction, with a worst-case cost effectiveness of $13,230. Staff recommends adoption at the December regular Board meeting.
Curt Coleman made public comments and stated that industry needed the two-year extension for elimination of the small container exemption for clear wood finishes pending U.S. EPA’s decision to de-list certain solvents that may be used in their formulations. The company he represents said they would not sell coatings using acetone as an exempt solvent for consumer products due to flammability issues. He also stated that PCBTF would not be used because of odor issues.
Next, John Billheimer commented that he agreed with Mr. Coleman’s comment regarding PCBTF.
Last, Greg Adams stated that silane/siloxanes in the waste discharge to POTWs have the potential to cause problems with their combustion equipment to the formation of glass compounds.
Due to time constraints, staff suggested postponement of this item until the next meeting on November 21.
Dr. Laki Tisopulos, Assistant Deputy Executive Officer, Planning and Rules, reported that there’s nothing new to update the Committee on at this time. This item was a place holder to assure that potential new information could be shared in a timely manner with the Committee.
Mohsen Nazemi, Assistant Deputy Executive Officer, Engineering & Compliance, presented this item. Mohsen indicated that Rule 1173 was last amended in December 2002 to implement control measures from the 1994 AQMP, which were the subject of a law suit filed in 1997 by NRDC and CBE. The amended rule provides, among other requirements, options for monitoring and reporting of releases from pressure relief devices (PRDs). These options include installation of tamper proof monitoring devices on 20% of PRDs by the first turnaround after the end of this year, or use of electronic process control instrumentation to monitor process parameters by July 1, 2004. The amended rule also requires sources to submit a compliance plan by the end of this year to show an inventory of PRDs and the option chosen.
Upon a PRD release, the amended rule also requires the source to conduct a failure analysis and implement corrective action within 30 days of the release. Refineries with >20,000 BBL/Day crude capacity must connect all PRDs to a Recovery/Control system if a second release of >500 lbs of VOC occurs within a 5 year period from PRDs from same equipment, or any single release of >2,000 lbs of VOC from any PRD serving the same equipment. In addition, the amended rule allows a refinery to voluntarily select to pay a mitigation fee of $350,000 in lieu of connecting PRDs to Recovery/Control system for such releases.
Mr. Nazemi shared information about PRD releases so far, as shown in the handout. There were two releases from Shell Oil Products facility in Wilmington in the amounts of 1,697 and 19,962 lbs in February and May of this year, respectively; and two from the BP ARCO facility in Carson in the amounts of about 1,400 and 122,300 lbs in March of this year. Additional PRD releases are also being evaluated by staff. Both Shell and BP ARCO have elected to pay, and have paid mitigation fees. The total fees paid by two companies for the Rule 1173 mitigation fees to date is $700,000. Mr. Nazemi also informed the Committee that AQMD is also discussing the release quantity calculations and methodology with Shell and Conoco-Phillips’s regarding two releases. Therefore, additional cases may be identified.
AQMD Board members raised concerns with the frequency of releases and indicated that when this provision was added to the rule, WSPA gave assurances that this mitigation fee option is not going to happen that often; now that we know it is taking place at such frequency it might be necessary to revisit the rule. Staff indicated that at the time of last rule amendment we did not have this data, and now that we have this data we could further evaluate this provision. Mohsen indicated that the adopted Board Resolution requires staff to provide periodic updates of releases to the Stationary Source Committee and to develop air quality improvement projects with the mitigation fees in consultation with the impacted community and the source. At the last month’s Board meeting a separate account was approved for Rule 1173 mitigation fees. AQMD intends to form a Community Advisory Panel to consider public and refinery input into how to invest the mitigation fees. Shell Oil has also suggested that their mitigation fees be used to install an ambient monitoring station at the nearby Wilmington Park Elementary School. Mohsen indicated that AQMD staff will bring back to the Stationary Source Committee for review any proposal for expenditure of the Rule 1173 mitigation fees prior to going to the full Board.
Ben Shaw, Engineering and Compliance Manager, gave a short overview of the proposed administrative amendments to the Rule. At the January, 2004 Hearing, the Governing Board will consider amending the Rule to extend the time frame for submittal of test reports performed at gasoline dispensing facilities and other minor administrative changes.
Marty Kay, Program Supervisor, Science and Technology Advancement presented the semi-annual report on changes to the BACT guidelines. Fourteen new listings that had been added to Part B, LAER/BACT Determinations for Major Polluting Facilities, were briefly described. Staff also recommended amendments to Part C, Policies and Procedures for Non-Major Polluting Facilities, and Part D, BACT Guidelines for Non-Major Polluting Facilities. In Part C, it was recommended that cost-effectiveness criteria for new, more stringent, Part D guidelines, be updated for inflation adjustment. In Part D, to reflect recent AQMD rule amendments, it was recommended that the guidelines for eight equipment categories be amended and guidelines be added for four new equipment categories. The amended or new guidelines will cross reference to rules that have become more stringent than the current Part D guidelines.
WRITTEN REPORTS
All written reports were acknowledged by the Committee.
The meeting was adjourned at 12:10 p.m.
October 24, 2003 Committee Agenda (without its attachments)
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