BOARD MEETING DATE: March 5, 2004
AGENDA NO. 28
Stationary Source Committee
SYNOPSIS:
The Stationary Source Committee met Friday, February 27, 2004. Following is a summary of that meeting. The next meeting will be March 26, 2004 at 10:30 a.m., in Conference Room CC8.
RECOMMENDED ACTION:
Receive and file.
William Craycraft, Acting Chair
Stationary Source Committee
Attendance
The meeting began at 10:35a.m. Present were William Craycraft, Acting Chair, and Committee Members Jane Carney and Dennis Yates. Absent were Committee Members Ron Loveridge and Bill Postmus.
ACTION ITEM
- Home Rule Advisory Group Goals and Objectives and Membership List
Dr. Elaine Chang, Deputy Executive Officer of Planning and Rules, presented this item. The materials were approved by the Committee. Board Member Yates asked if there are still vacancies on the HRAG for Board Member recommendations. Staff replied that there were vacancies and that they will prepare a memo to Board Members on the current status of the membership through the Advisory Group Chair.
INFORMATIONAL ITEMS
- Status Report on Rule 1148.1 – Oil Field Production Wells
- Status Report on Rule 1132 – Further Control of VOC Emissions from High Emitting Spray Booth Facilities
- Rule 1470 – Diesel Emission from Back-up Generators
- Addendum to the Air Toxic Control Plan
- Regulation III – Fees
- Proposed Rule 1127 – Emission Reductions from Livestock Waste
- Status Report on 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. Laki Tisopulos, Assistant Deputy Executive Officer of Planning and Rules, gave a status report on PR1148.1. Since the January 2004 Board Hearing, staff met with the Department of Oil and Gas and industry twice and held a consultation meeting. In response to comments received, staff is recommending minor changes to the rule proposal to address safety concerns, minimize cost impact of the rule to small producers, offer compliance flexibility and clarification. Dr. Tisopulos also summarized the key comments received since January 2004.
Larry Bowen, Planning and Rules Manager, presented this item. Rule 1132 requires an additional 65% control of VOC emissions from spray booth facilities that emit greater than 20 tons per year. U.S. EPA has disapproved that portion of the rule that allows the optional alternative compliance provisions. Staff is bringing forward amendments to correct that deficiency at the March 5 Board meeting in order to meet a SIP sanction deadline of April 15. The briefing addressed the two amendments that staff is recommending since the hearing was noticed. Neither amendment is substantive or changes the meaning of the rule noticed for hearing.
The first change was to the alternative compliance provision for the composite industry. The noticed rule allowed the use of the Unified Emission Factor Table (UEF Table) from the federal NESHAP. As a result of the spray gun manufacturers withdrawing from the testing program to substantiate the factor for non-atomizing gelcoat application, that factor cannot be used to demonstrate equivalency unless it is demonstrated by source test. Without the source test, applicants will default to the atomizing application of gelcoat factor in the UEF Table.
The second change was a result of comments received during the notice period. Although no company has taken advantage of the alternative compliance provision in (d)(3) of the rule, it was requested that flexibility be left in the rule rather than deleted, as staff proposed. Staff has incorporated an alternative compliance provision back into the rule that requires case-by-case approval by the AQMD, CARB, and U.S. EPA. This will correct the deficiency and allow some flexibility as requested by industry. Staff believes that very few, if any, companies will take advantage of this provision because of the level of effort required to receive approval from the three agencies and that the averaging plans discussed with staff will have to meet the U.S. EPA Economic Incentives Program (EIP) Guidelines that require a demonstration of an air quality benefit, not just a demonstration of equivalency.
Jill Whynot, Planning and Rules Manager, gave a summary of Proposed Rule 1470 (PR1470), which will reduce diesel emissions from stationary internal combustion engines. Last year, the Governing Board directed staff to develop a rule for their consideration that would enhance health protection for school children, and directed staff not to wait for the ARB Air Toxic Control Measure (ATCM), which was under development at that time. ARB adopted the ATCM on February 26, 2004. AQMD’s rule must be at least as stringent as the ATCM.
There are about 7,800 engines in the Basin, with the majority used as emergency back up. Reduction strategies include use of cleaner fuels, limiting hours of operation for non-emergency use, and in some cases, add-on controls, such as diesel particulate filters (DPF). Compliance dates range from 2006-2009 for most engines, with engines in remote locations due to comply by 2011. The important distinction between the ATCM and PR1470 is that the PR1470 is more stringent for engines located on or near schools; this will be the key policy consideration for the Board.
PR1470 would require DPFs on engines on or within 100 meters of a school, to prepare for eventual emergency use. It would also not allow routine testing or maintenance from 7:30 am to 3:30 pm. Emissions from a 500 hp engines for non-emergency use would be one pound of PM or less per year. The same engine, if complying with the ATCM but without a DPF, could emit 40 – 60 pounds if run 100 hours during emergency situations.
No adverse environmental impacts have been identified. Preliminary cost data was discussed and a socioeconomic report is being prepared. This rule will be set for hearing in March, with an April 2, 2004 public hearing.
Board Member Craycraft commented that during the hours identified, students spend much of their time in classrooms, with the afternoon hours being more likely to have students outside. Several parents with children attending an elementary private school in Claremont attended the meeting. They expressed their support for a strong rule, and gave the Committee members a copy of a comment letter with signatures from many parents.
This item was carried over to the March meeting.
This item was carried over to the March meeting.
Due to limited time, Dr. Julia Lester, PM10 Program Supervisor, waived her presentation and focused only on current PR1127 key issues. In response to public and board committee concerns about the out-of-basin manure shipping provisions and source equity in the November 2002 draft rule, staff has prepared a revised proposal. The revised proposal limits disposal options for large dairies to digesters or R1133.2-compliant composters (i.e. out-of-basin transport is not a compliance option). New composting technology (fabric in-vessel systems) has the potential of reducing composting costs while still achieving emission reductions beyond open windrow composting. Milk Producers Council, which represents many local dairies, has partnered with the Inland Empire Utilities Agency and others to build and test digesters and is partnering to set up and test a fabric in-vessel composter. Industry is concerned that the new PR1127 proposal will prevent them from sending manure to fields outside of the Basin, where it is used as a fertilizer and soil amendment. Staff is working to balance in-basin control technology use with beneficial manure use within and outside of the Basin. Based on this, staff is in the process of developing revised rule language and the supporting draft staff report. Mr. Bob Feenstra, Executive Director of the Milk Producers Council, spoke about his group's efforts to bring digesters and controlled composting to the Basin and his strong concerns about the latest PR1127 proposals going significantly beyond even those challenging efforts.
Due to time constraints, staff did not make a presentation on PAR 403, 1186, and 403.1. The set hearing for the amendments is March 5, 2004, with the amendments scheduled for Board consideration on April 2, 2004.
WRITTEN REPORTS
All written reports were acknowledged by the Committee.
The meeting was adjourned at 12:10 p.m.
February 27, 2004 Committee Agenda (without its attachments)
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