BOARD MEETING DATE: October 3, 2003
AGENDA NO. 28
Stationary Source Committee
SYNOPSIS:
The Stationary Source Committee met Friday, September 26, 2003. Following is a summary of that meeting. The next meeting will be October 24, at 10:30 a.m., in Conference Room CC8.
RECOMMENDED ACTION:
Receive and file.
Leonard Paultiz, Acting Chair
Stationary Source Committee
Attendance
The meeting began at 10:45 a.m. Present were Leonard Paulitz, Acting Chair, Jane Carney, William Craycraft and Fred Aguiar. Absent was Ron Loveridge, Chair.
INFORMATIONAL ITEMS
- Rule 1113 – Architectural Coatings
Larry Bowen, Planning and Rules Manager presented this item. The purpose of the presentation was an informational briefing on the ongoing rulemaking for amending Rule 1113. Since its adoption in 1977, the rule has been amended 22 times. It applies to the manufacturers, distributors and users of architectural coatings. These proposed amendments are to implement CTS-07 of the 2003 AQMP and along with a parallel amendment to Rule 1171. These amendments are committed in the AQMP to achieve an 8.5 TPD reduction in VOC with adoption of the rule by the end of this calendar year. This proposed amendment to Rule 1113 and the associated amendment to Rule 1171 represent the largest VOC reduction measures available in the Plan. - Rule 1171 – Solvent Cleaning Operations
Lee Lockie, Director of Area Sources presented this item. Rule 1171 currently exempts the cleaning of architectural coating application equipment from all requirements of the rule as long as the VOC content of the clean up solvents does not exceed 950 grams/liter (g/l). The proposed amendment eliminates this exemption and establishes a clean up solvent VOC content limit of 25 g/l for such cleaning starting on July 1, 2005. - Reg. XX - RECLAIM
Jill Whynot, Planning and Rules Manager gave a brief presentation on proposed changes to RECLAIM. This item is being set for hearing in October for a public hearing in November. - Rule 1110.2 Report on Snow-making Machines
Jill Whynot, Planning and Rules Manager gave a brief presentation on Internal Combustion Engines (ICEs) used for snowmaking or ski lifts in the Big Bear area. Rule 1110.2 covers ICEs. Amendments in 1997 exempted ICEs used for snow making in the Big Bear area. Reports on ambient monitoring for PM 2.5 have gone to the Board every 2 years to monitor emissions relative to daily and annual standards. Emission levels remain below the standards. Recent orders for abatement will result in replacement of some engines with lower emitting engines and electrification of other engines. Staff recommends continued monitoring and reports to the Stationary Source Committee or Governing Board only if issues arise in the future. - Proposed Rule 1105.1 – Reduction of PM10 and Ammonia Emissions from Fluid Catalytic Cracking Units
Laki Tisopulos, Assistant Deputy Executive Officer, Planning and Rules, presented this item. The point of the presentation is to focus on the major issues since the Committee has had this item before them on previous occasions. In May, staff proposed a rule that set emission limits for the six refinery FCCUs for filterable particulate and ammonia. In addition, to allow compliance flexibility, the proposal included a provision that allowed exceedances of those limits, within bounds, provided the refinery achieved mitigation alternatives or paid the AQMD a fee to acquire the mitigating emission reductions. The staff proposal was not well received by industry. They hired a consultant to look at the feasibility and cost issues and as a result of that study staff believed it was necessary to also get an independent opinion as well as a review of the WSPA consultant’s and our own analyses. Despite all the effort, staff and industry differ on two major issues, the ability to achieve compliance with the filterable particulate limit on an ongoing basis and the cost of the controls. - Area Source MACT Delegation
Mohsen Nazemi, Assistant Deputy Executive Officer, Engineering and Compliance presented this item to recommend to the Board members that the Executive Officer use his discretion so that on a case-by-case basis request delegation of Area Source NESHAP/MACT from U.S. EPA Region 9. The presentation included a brief overview of what is an area source, the number of area sources NEHAPs’ that have been developed to-date and under development, and the area sources that have been deferred from Title V permits until December 9, 2004. The pros and cons of receiving delegation of the area source NESHAP was also presented.
The proposed amendments to Rule 1113 are targeted at a limited number of specialty coatings categories, clear wood finishes, roof coatings, stains and waterproofing sealers. In addition, since a high percentage of clear wood finishes are sold in small containers that are also above current limits, staff is proposing to eliminate the current small container exemption for the clear wood finishes. Staff is also proposing a number of administrative and clarifying changes to the rule. The proposed limits are based upon coatings currently available in the marketplace and are expected to achieve a 4.26 TPD emission reduction. Since there are compliant coatings available, staff is proposing an effective date of January 1, 2005 and both the three-year sell through and averaging plans are available to aid in compliance. The cost effectiveness ranges from $2,472 to $10,306 per ton reduced depending on how the cost of reformulation is accounted for.
The industry has expressed a number of concerns, including a request to postpone the rulemaking to allow for further study. They also would like higher VOC limits for some categories, retain the small container exemption and an extension on the proposed compliance dates. Staff has been working through an industry working group and the next meeting for that group is scheduled for next week. There was a public workshop in September and there will be a public consultation meeting the middle of next month. Staff will be bringing this proposal back to the Stationary Source Committee prior to the targeted December public hearing. At the meeting Curt Coleman, on behalf of Sherwin-Williams, expressed some concern about elimination of the small container exemption, indicating there may be some value to it for specific applications.
This proposal reflects advances in low VOC cleaning technology and the commercial availability of cost-effective, compliant cleaning materials.
The Board made findings in June that power plants re-entering RECLAIM would not have any negative impacts. The proposed changes to Rule 2007 will remove trading restrictions and bring power plants back into the market. Additional minor changes are proposed to the protocols to clarify the time to recertify Continuous Emission Monitors (CEMs) that are new or modified. No significant comments have been raised through the public process. Next year there will be proposed changes to RECLAIM to implement a control measure in the AQMP that will seek to reduce allocations.
Regarding the feasibility issue, the three manufacturers of control equipment that would cooperate with staff and staff’s consultant believe the limits can be achieved on a continuous basis and the manufacturers will warranty the equipment at that level using the AQMD’s test method. WSPA’s consultant and the control equipment manufacturer that would provide information only through the individual refiners believed that a higher limit was the lowest achievable and the warranty would be based on a U.S. EPA test method that would leave the refineries with a less than desirable warranty.
The staff contention that the proposed limits are achievable is also supported by source testing that was conducted at ChevronTexaco by the company in May and by the AQMD in August. In both series of tests the proposed standards were achieved with little or no ammonia injection. In addition to this achieved in practice demonstration, the staff proposal accounted for building a 25% redundancy into the control equipment and allowing for gas conditioning with ammonia to address any operational fluctuations.
Regarding compliance costs, U.S. EPA/Vatavuk, staff and SP Environmental all were in the same ballpark on cost. U.S. EPA/ Vatavuk was at $50-$63 million, staff was in the middle at $63-$87 million and SP Environmental was slightly higher at $88-$100 million. The WSPA consultant was 2.5 to 4 times higher at $266 million. A possible reason for this is that staff and their consultants took a bottom-up approach at estimating the cost for each refinery, whereas WSPA’s consultant took the estimates of each individual refiner and adjusted those costs for specific contingencies.
Staff is proposing two versions of the rule for the Board’s consideration in October. Version 1 sets a filterable particulate limit of 0.005 grains/dscf and an ammonia slip limit of 10 ppmv. This is a slightly higher limit than was proposed in May and is consistent with the recommendation of SP Environmental. Version 2 is the same as Version 1 except that it adds an alternative compliance option. A refinery may operate up to 0.006 grains/dscf provided they provide equivalent emission reductions that meet certain requirements.
Staff believes this rule will achieve emission reductions of 0.5 TPD of filterable particulate, 1.5TPD of ammonia and up to 5.8 TPD of ammonium sulfate at a cost effectiveness of $3,000-$5,000 per ton based on the reductions of the filterable particulate and ammonia. This translates into an increase of one tenth of one cent per gallon to the cost of gasoline.
Ron Wilkness, on behalf of the Western States Petroleum Association, made several comments relative to the staff proposal, expressing concern regarding the feasibility and cost. He also indicated that WSPA had requested that the hearing be postponed to allow WSPA to review some material recently provided by staff. He also stated that WSPA members believed an acceptable rule limit was .008 grains/dscf. In response to the issue of postponing the hearing, Dr. Wallerstein stated that staff postponing the hearing to November.
WRITTEN REPORTS
All written reports were acknowledged by the Committee.
The meeting was adjourned at 12:35 p.m.
September 26, 2003 Committee Agenda (without its attachments)
/ / /