BOARD MEETING DATE: February 6, 2004
AGENDA NO. 21
Stationary Source Committee
SYNOPSIS:
The Stationary Source Committee met Friday, January 23, 2004. Following is a summary of that meeting. The next meeting will be February 27, at 10:30 a.m., in Conference Room CC8.
RECOMMENDED ACTION:
Receive and file.
Leonard Paulitz, Acting Chair
Stationary Source Committee
Attendance
The meeting began at 10:35a.m. Present were Leonard Paulitz, Acting Chair and Committee Member Jane Carney. Cynthia Verdugo-Peralta was appointed to the committee at 12:05p.m. by Leonard Paulitz. Absent were Committee Members Ron Loveridge and William Craycraft.
INFORMATIONAL ITEMS
- 2003 AQMP Commitment for Year 2004
- Report on Rule 1148.1 – Oil and Gas Production Operations
- Rule 1132 – Further Control of VOC Emissions from High Emitting Spray Booth Facilities
Larry Bowen, Planning and Rules Manager, presented this item. Rule 1132 was adopted by the Board in 2001 and U.S. EPA subsequently published a limited approval/disapproval for the alternative control plan portion of the rule. The basis for the disapproval portion was Executive Officer discretion. Staff is proposing amendments to correct that SIP deficiency and requested that they be considered by the Board in March to beat the April 15 deadline for approval imposed by U.S. EPA. In addition, staff is proposing to clarify in the staff report the compliant grams of VOC per liter of coating limits for the pound of VOC per pound of solids emission limit in Rule 1136. - Implementation Status Report on Rule 1102 – Dry Cleaners Using Solvent Other Than Perchloroethylene
Lee Lockie, Director, Area Sources, presented this item. Rule 1102 controls VOC emissions from dry cleaning operations that use solvents other than perchloroethylene and allows a delayed compliance date of January 1, 2005 for machines used in cleaning reusable textile materials. - Proposed Amendments to Rule 403 – Fugitive Dust, Rule 1186 – PM10 Emission from Paved and Unpaved Roads, and Livestock Operations, Rule 403 - Fugitive Dust, and 403.1 – Wind Entrainment of Fugitive Dust
Dr. Julia Lester, PM10 Program Supervisor, briefed the committee on Proposed Amendments to Rules 403, 1186, and 403.1, the main AQMD fugitive dust rules. The amendments are based on the 2002 Coachella Valley SIP control measures and 2003 AQMP control measure BCM-07. They also address enforcement and clarity issues that have been raised by U.S. EPA. Amendments to Rule 403 include more explicit Best Available Control Measure (BACM) descriptions by specific source categories, stricter track-out requirements, and lowering the Large Operation (LO) size threshold while modifying certain LO requirements. The amendments halve the size threshold for LO notification requirements to 50 acres or 5,000 yd3 of daily earth movement now rather than waiting for the area to fail to attain the PM10 standard, as was in the rule previously. The amendment would remove the rarely-used dust plan submittal option, relying on the current LO notification procedure amended to include annual updates and notification of cessation of operation. LOs would also be required to install dust complaint signs with company and AQMD contact information and, starting January 1, 2005, have an "environmental observer" with the authority to implement on-site dust control. Recordkeeping retention would be extended from 6 months to 3 years. Other amendments to Rule 403 would extend current Basin requirements on crop farmers to the Coachella Valley. Staff is working with Coachella Valley to prepare a specific agricultural PM10 best management practices (BMP) guide for that area. There are other minor amendments and a revised Rule 403 Implementation Handbook is being prepared. - Disneyland Fireworks Show & Air Quality Issues
Carol Coy, Deputy Executive Officer, Engineering and Compliance, presented this item in response to a commitment to brief the Committee made at the December 5, 2003 Board meeting after Mr. William Fitzgerald, of Anaheim Homeowners Maintaining their Environment (HOME), shared his community’s ongoing concerns regarding the Disneyland fireworks display during the public comment period. Ms. Coy summarized the seasonal nature of the aerial fireworks displays, the AQMD complaint history (which has declined in recent years), and the regulations which currently exempt pyrotechnic equipment and displays from permitting and open burning statutes. She also reviewed the AB2588 Health Risk Assessment values (1.8 in a million maximum cancer risk) which incorporated risk from fireworks displays and reported the results of AQMD particulate monitoring in 2002 which detected measurable firework components in the smoke traveling into the community, but no exceedance of State Relative Exposure Levels (RELs). Ms. Coy concluded by outlining the current work being done by Disney engineers to reduce smoke emissions by developing and implementing air launch technology for aerial shows as well as reformulated low level, reduced smoke fireworks. Mr. Fitzgerald addressed the committee members reiterating his concerns regarding the greatly expanded use of fireworks by Disneyland over the past decades and requested help in reducing their impact on the surrounding neighborhood. Committee member Jane Carney requested this report be presented to the full Board to discuss whether the current exemption policies as reflected in AQMD rules be re-examined. Ms. Coy committed to develop a discussion item for the May meeting. - Authorize Funding to Purchase Compliance Year 2003 NOx RECLAIM Trading Credits
Carol Coy, Deputy Executive Officer, Engineering and Compliance presented this item. Staff requested the Board authorize funding up to $300,000 from the RECLAIM and Executive Officer Mitigation Fund Account to purchase Compliance Year 2003 NOx RTCs for the purpose of mitigating excess emissions from power plants during the California Energy Crisis in 2001. These facilities paid mitigation fees pursuant to the Governor's Executive Order for the excess emissions in 2001 at the rate of $7.50 per pound. The requested funding will be used to purchase NOx RTCs to offset excess power plant emissions under that program and is expected to complete the acquisition process. - Progress Report on Fume Suppressant Testing for Rule 1469, Metal Plating
This item was carried over to the February meeting. - Proposed Rule 1127 – Emission Reductions from Livestock Waste
This item was carried over to the February meeting.
Dr. Laki Tisopulos, Assistant Deputy Executive Officer of Planning and Rules, presented AQMD’s emission reduction commitments for 2004 which are 2 t/d VOC, 3 t/d NOx, 1.7 t/d PM10, and 2.1 t/d SOx. Dr. Tisopulos also presented the specific control measures to achieve these reductions and the 2004 preliminary schedule for adoption of these measures by quarter along with the corresponding rule number: First quarter - FUG-05: Fugitive Emission Sources (PR 1148.1); Second quarter - BCM 07: Fugitive Dust (R 403, R 403.1, R 1186), BCM-08: Aggregate and Cement Plant Manufacturing Operations (PR1157), and WST-01: Livestock Waste (PR 1127); Third quarter - CTS-10: Misc. Industrial Coatings & Solvent Operations (R 1145), CMB-10: Additional NOx Reductions from RECLAIM (Reg. XX), and PRC-07: Industrial Process Operations (PR 1175); and Fourth quarter - CMB-07: Petroleum Refinery Flares (R 1118), MSC-08: Large VOC Sources (2004-2006) and PRC-03: Restaurant Operations (PR 1138.1).
Dr. Laki Tisopulos, Assistant Deputy Executive Officer of Planning and Rules, presented this item. Proposed Rule 1148.1 is a new rule to control VOC emissions from oil and gas production operations and includes additional requirements for wells located near sensitive receptors. Proposed Amended Rule 222 includes the wells regulated by PAR 1148.1 in the Rule 222 filing program since oil wells are exempt from written permit in the AQMD. Proposed Rule 1148.1 is similar to the rules that have been adopted in the Santa Barbara, Ventura, and San Luis Obispo districts and is expected to achieve 1.76 tons per day of VOC reduction at a cost of $ 2,483 per ton reduced.
Throughout the year-long development of this rule proposal, staff has had discussions and met numerous times with the industry, the California Department of Oil and Gas and Geothermal Resources (DOGGR), and members of the community, including a public workshop and public consultation meetings. Nevertheless, at the public hearing in January, there were a number of concerns expressed by DOGGR, some of which were new to staff. The significant comments and responses were summarized in this report and in addition, staff was able to schedule a meeting next week with DOGGR and industry to address their issues. The proposed rule is scheduleed for the March Board Meeting since the Board continued the public hearing to that date.
There were some issues staff heard at the public workshop and from subsequent comments. The proposed rule that staff proposed for the workshop included a compliance limit for wood furniture manufacturers that was based on grams of VOC per liter of material rather than the way it is expressed in Rule 1136. Since the solids content of the various coatings for this industry differ, it could not be demonstrated that the grams of VOC per liter of material limit is equivalent to the grams of VOC per liter of coating limits for all cases.
A second issue was to allow compliance averaging across spray booths. The rule does allow this under the alternative compliance plan provisions but at a higher control efficiency than requested by the commenter. To allow the lower level of control efficiency suggested by the commenter would be a relaxation of standards that would be unacceptable to U.S. EPA.
A representative of the UV/EB coatings industry expressed concern that the Unified Emissions Factor Table referenced in the rule for composite manufacturers does not include a factor for UV/EB coatings. Staff has amended the rule to allow the use of any new Unified Emissions Factors developed for the composite industry and approved by the agencies to address this concern.
One commenter expressed concern that accepting permit conditions limiting throughput to qualify for exemptions could affect their ability to expand at a later date if they chose to control rather than qualify for the exemption because it may have an effect on their NSR threshold. Staff is addressing this in the staff report that limiting permit condition or an additional permit condition will clarify that the Rule 1132 condition will not affect the NSR threshold for that facility. This has been coordinated with Engineering and Compliance.
One commenter expressed concern that a Unified Emission Factor for UV/EB coatings has not been developed and will take about a year to do so. He expressed appreciation that staff addressed this in the rule and will review the latest rule version.
Two commenters expressed their belief that averaging should be allowed across multiple spray booths and one of those commenters expressed that his clients cannot meet the higher control standard of 71.5 % that the rule requires. Reducing the 71.5 % standard to a lower level would result in a relaxation that will not be acceptable to U.S. EPA for approval into the SIP.
One commenter wanted assurance that the requirement to accept permit conditions would not be an excuse to issue more violation counts when noncompliance is determined. Staff explained that the purpose of the condition is to allow the inspector to more effectively identify that the source is in compliance and this change merely clarifies the practice that had been in effect since the rule was originally adopted.
The Board directed staff to assess the availability, feasibility and cost-effectiveness of closed-loop dry cleaning machines for large industrial applications. Only one facility falls into this category. This final status report presents staff’s findings that cost-effective, rule-compliant machines are available that can replace this company’s existing transfer units and meet the performance needs of the company. However, additional time may be needed by the effected company and can be provided through a variance.
Amendments to Rule 1186 would extend post-event clean-up and street sweeping requirements to the Coachella Valley to backstop their Clean Streets Management Program. They would also activate the requirement for new roads to have curbing or paved shoulders (previously only activated if the area failed to attain the PM10 standard). Lastly, the limited street sweeper exemption is removed and equivalency determination provisions clarified.
Amendments to Rule 403.1 involve a name change to "Supplemental Fugitive Dust Control Requirements for Coachella Valley Sources" and requiring the submittal of detailed dust control plans to the AQMD for those projects not required to submit one under a local ordinance. A revised Rule 403.1 Implementation Handbook is being prepared.
Staff has had several stakeholder meetings and Public Workshops on January 15th and 21st. The adoption hearing is scheduled for April 2, 2004.
WRITTEN REPORTS
All written reports were acknowledged by the Committee.
The meeting was adjourned at 12:17 p.m.
January 23, 2004 Committee Agenda (without its attachments)
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