BOARD MEETING DATE: May 7, 2004
AGENDA NO. 28
Stationary Source Committee
SYNOPSIS:
The Stationary Source Committee met Friday, April 23, 2004. Following is a summary of that meeting. The next meeting will be May 28, 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 10:45a.m. Present were William Craycraft, Acting Chair and Committee Member Jane Carney (arrived at 10:50 a.m.). Absent were Ronald Loveridge, Bill Postmus and Dennis Yates.
ACTION ITEM
- Home Rule Advisory Group 2003 Accomplishments
The two Committee Members in attendance heard and concurred with the report.
INFORMATIONAL ITEMS
- Amend Rule 2015 – Backstop Measures
- Status Report on Proposed Rule 1127 – Emissions from Livestock Waste
- Rule 1132 – Further Control of VOC Emissions from High Emitting Spray Booth Facilities
- Rule 1162 – Polyester Resin Operations
- Update on Rule 1173 – Mitigation Fees
- Executive Contract with Los Angeles County Agricultural Commission Department of Weights and Measures for Gasoline Vapor Recovery Inspections and Testing
Jill Whynot, Planning and Rules Manager, summarized proposed changes to Rule 2015 – Backstop Provisions, one of the rules in the RECLAIM program. Rule 2015 is being amended before the more comprehensive revisions to RECLAIM later this year to make sure that the deadline is met for a U.S. EPA SIP approval issue.
Rule 2004 allows facilities to request that emissions from breakdowns at their facility are not covered by the facility’s RTCs. This has been part of the rule since the program was adopted in 1993, but has never been used. In 1999, U.S. EPA developed a policy regarding excess emissions, which caused U.S. EPA to publish a conditional approval of the May 2001 RECLAIM amendments.
To address this issue, staff is proposing that at the end of each compliance year, the total amount of unmitigated breakdown emissions, if any, be compared to the total unused RTCs. In the unlikely event that unused RTCs do not cover the unmitigated breakdown emissions, then deductions would be made from all RTC holdings in the subsequent year. This approach is acceptable to U.S. EPA. Staff is also proposing that AQMD could obtain credits to make up some, or all, of the difference. This aspect still needs to be discussed with U.S. EPA.
Curt Coleman, representing the California Manufacturers Association, commented that the companies with unmitigated breakdown emissions should be responsible, rather than requiring an adjustment for all RTC holders. Staff will consider this comment.
Dr. Julia Lester, Program Supervisor for Planning, Rules and Area Sources, presented a status report on rule development for PR1127 - Emission Reductions from Livestock Waste. After summarizing the proposed rule requirements, she discussed the technical and cost assumptions used in the impact analysis. Raw manure emissions in the mid-1990s were 26 tons/day ammonia and 10 tons/day VOC. Accounting for future dairy relocations, water quality regulations, and the implementation of PR1127, remaining emissions in 2010 would be 9.4 tpd ammonia and 3.3 tons/day VOC. A summary of outstanding issues raised in stakeholder meetings and the recent public workshop and staff responses was presented. Lastly, the schedule of PR1127 activities, including the proposed July 9, 2004 Board adoption hearing, was presented.
Board Members asked why the proposed rule did not have a greater removal frequency. Staff replied that the dairy industry was commenting that the proposed four times per year was already too stringent based on their inability to remove manure in the wet season and the limited availability of hauling service providers, which restricts a dairy’s ability to ensure timely removal. Board members urged staff to consider more frequent removal to increase emission reductions; they asked staff to identify barriers to removal that were truly technical versus those more related to cost and service availability. Board members asked that additional outreach be done to the community and Dr. Wallerstein suggested that one option is for staff to arrange for appropriate Town Hall meetings.
Larry Bowen, Planning and Rules Manager, presented this item. Rule 1132 is to be amended at the May Board Meeting to correct a typographical error in the version that was adopted in March. In the description of one of the emission factors for the alternative compliance provision for the composite industry, the word resin was used instead of gelcoat.
Larry Bowen, Planning and Rules Manager, presented this item. Rule 1162 is to be amended to change the compliance date for requiring the use of non-atomizing spray application technique for gelcoat from July 1, 2004 to July 1, 2005. Staff is working on a testing program designed to identify the appropriate operating parameters to include in the definition of non-atomizing spray application technique of gelcoat. If those parameters can be identified, staff will return with a subsequent rule amendment to include the parameters in the definition. The proposal also includes a definition of non-atomizing spray application technique for gelcoat based upon the definition in the U.S. EPA NESHAP for the composite industry that requires individual operators the demonstrate compliance with the emission factors in the approved Unified Emission Factors (UEF) Table. This definition will remain in place until and if the definition is altered to include the operating parameters identified by the testing program.
Mohsen Nazemi, Assistant Deputy Executive Officer for Engineering and Compliance, provided an update on the status of Rule 1173 – Mitigation Fees. Mr. Nazemi indicated that Rule 1173 was amended in December 2002, and part of the amendments dealt with emission releases from Pressure Relief Devices (PRDs) at refineries. The rule required refineries to conduct an inventory and submit a compliance plan by the end of 2003 to indicate which monitoring options they have chosen. The monitoring options included either equipping 20% of the PRDs with Tamper Proof Monitoring Devices by next turnaround starting in 2004, or use Electronic Process Control Instrumentation by July 2004. Three refineries have chosen the former and all the others have chosen the latter option. The rule also requires certain actions if a release is greater than specific amounts. For all releases >500 lbs of VOCs, the refining has to perform a failure analysis within 30 days of each release. Also, a second release of >500 lbs VOCs from the same equipment in any five years or any release of >2,000 lbs. VOC from a process unit requires the company to connect all PRDs from that unit to vapor recovery or control equipment. The rule also has a provision which allows the refinery to elect to pay $350,000 for each release in lieu of connecting to vapor recovery or control, provided the refinery notifies AQMD within 90 days of the date of the release. Mr. Nazemi provided a summary of the PRD releases to date and indicated based on refineries’ reported releases in 2003 five releases have exceeded 2000 lbs. Two of them were at BP Arco refinery in Carson and three at Shell Oil refinery in Wilmington. AQMD has received mitigation fee payments of $350,000 each for a total of $1.4 million for four of the releases (one from BP Arco and three from Shell Oil). With respect to the last release from BP Arco, the refinery did not notify us of BP Arco’s selection to pay a mitigation fee until after the 90 days deadline, and therefore is subject to requirements to connect to vapor recovery or control.
Mr. Nazemi also informed the Committee Members that Board resolution requires periodic status report to the Stationary Source Committee and that the mitigation fees be used to fund development of Air Quality Improvement projects in the impacted community, in cooperation with both the impacted community and the sources of release. Mr. Nazemi indicated that AQMD has formed a Community Advisory Panel (CAP) and met with them last night to get input from the community. Also, the two refineries have provided suggestions for air quality improvement projects. Mr. Nazemi indicated that upon further discussions with CAP and refiners, AQMD staff will bring any Rule 1173 mitigation fee expenditure proposal to the Stationary Source Committee prior to going to the Board.
Both Board Members Carney and Craycraft expressed concerns about the frequency and amount of emissions from PRDs (i.e. about 85 tons of VOCs in 2003). They indicated that staff should use the data gathered to date and future data to decide whether or not further amendments to Rule 1173 is necessary. One of the concerns expressed was that at the time of rule development, staff was told by the refineries that these types of releases are extremely rare and that’s why the mitigation fee option was added. Now that we have seen frequent releases, maybe staff should take a closer look at the mitigation fee option of the rule.
Ken Hudson of BP Arco and Stan Holmes of Exxon Mobil commented that the refineries are implementing all feasible measures to minimize the releases. John Billheimer also commented that the reactivity of the VOC s released should be considered.
Mohsen Nazemi, Assistant Deputy Executive Officer for Engineering and Compliance, stated that for the last nine years, AQMD has maintained a contract with the L.A. County Department of Weights and Measures to conduct vapor recovery inspection and perform tests at retail gasoline dispensing facilities. This action is to execute an additional one-year contract at a cost of $70,000 in FY 2004-05, subject to funding approval at the June 4, 2004 Board meeting.
WRITTEN REPORTS
All written reports were acknowledged by the Committee.
The meeting was adjourned at 11:55 p.m.
April 23, 2004 Committee Agenda (without its attachments)
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