BOARD MEETING DATE: November 5, 2004
AGENDA NO. 26
Stationary Source Committee
SYNOPSIS:
The Stationary Source Committee met Friday, October 22, 2004. Following is a summary of that meeting. The next meeting will be November 19, 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 10:35a.m. Present were Ronald Loveridge, Chairman, William Craycraft, Dennis Yates and Jane Carney (left at 11:20 and returned at 11:50 due to conflict of interest). Absent was Bill Postmus.
INFORMATIONAL ITEMS
- Report on RECLAIM Rule Development
- Rules 102, 201, 201.1, 202, 203, 219 and 312 – Permitting/Fee Requirements for Agricultural Equipment
- Rule 1145 – Plastic, Rubber, and Glass Coatings
- Rule 1157 – PM10 Emission Reductions from Aggregate Operations
- Discussion on Concept Paper for Proposed Rule 1401.1 – Requirements for New and Relocated Facilities Near Schools
- Rule 1469 – Implementation and Compliance Status Report
- BACT Semi-Annual Report
Jill Whynot, Planning and Rules Manager, gave an update on RECLAIM BARCT determinations and power plant trading restrictions. The main purpose of the briefing was to address questions raised at the October 1st Informational Hearing about the source of data used for cost calculations. Next month, the committee will be briefed on options for reductions, and structural buyers.
The discussion of BARCT cost and cost effectiveness focused on two categories of equipment at refineries – FCCUs and large boilers and heaters, and the installation of SCR control equipment. The basis for the technical feasibility, equipment life, and cost calculations were described. Staff presented charts and tables showing the different sources of data and reasons why variations occur. Staff is working with industry and will have several meetings in the next 2 weeks regarding these topics.
Committee members asked for staff to clarify what the expected life of the equipment is and the guarantee provided by the manufacturer for the performance of the equipment. The relationship of SCR under Rule 1105.1 and SCR under RECLAIM was raised. Costs for SCR are assumed under RECLAIM because staff did not concur with industry that SCR was needed to obtain the particulate reductions in Rule 1105.1, so those costs were not included in the staff estimates for that rule.
Regarding power plant trading restrictions, staff is considering allowing power plants to purchase future credits once the rules are amended. This will enable credits to be secured for new facilities and expansions without adding large amounts of credits to be placed on the market before the total RTCs are adjusted.
Staff is still receiving data from power plants and refineries, and will continue to work with them, and other parties.
A representative from one of the refineries recommended that only data from actual installations be used, as vendors tend to have lower cost estimates than what they experience. There are 30 large heaters and boilers with SCR installed at refineries. The vendor guarantee depends on the emission rate.
Larry Bowen, Planning and Rules Manager, presented this item. The amendments to Rules 102, 201, 201.1, 202, 203, 219 and the new rule 312 are to provide a reduced fee schedule and streamlined permitting for existing agricultural sources and identify which agricultural sources require permits and which do not. Senate Bill #700 changed Health and Safety Code to require, among other things, certain agricultural sources to have written permits. This rulemaking package fulfils that requirement and provides for a transition of agricultural sources into the AQMD permit system. There have been concerns expressed by the agriculture industry and a request to delay this proposal. Staff recommends that we move ahead expeditiously otherwise these sources will have to pay substantially higher fees of Rule 301 that currently applies to these types of equipment at other sources. Staff is continuing to work with the agriculture industry on this and other SB 700 issues and is willing to create a SB700 task force or working group with the stakeholders to discuss all implementation aspects of the state law. Staff recommends adoption at the December Board meeting.
Committee Member Jane Carney left the meeting for the next two items due to a conflict of interest. TMI Products, Inc., Inland Concrete Enterprises, Inc., Delilah Properties, Maruhachi Ceramics of America, Inc., and J.R. Pipeline are sources of income for Ms. Carney.
Larry Bowen, Planning and Rules Manager, presented this item. Rule 1145 applies to the coating of plastic, rubber and glass and is to be amended to reduce VOC emissions and partially implement AQMP Control Measure CTS-10. The proposal reduces the VOC limits for several coating categories, effective 1-1-07, and adds new categories for leather coating and extreme performance. The proposal also clarifies the baseline for equivalency demonstration of transfer efficiency is HVLP spray application. A limited exemption for polyurethane shoe sole coating is also included.
The expected emission reduction is 1.27 tons per day at an average cost effectiveness of $3,900 per ton of VOC reduced. Although we believe most issues have been resolved there has been some concern expressed about the compliance date for the two-component general coating category. Although we have identified manufacturers with compliant coatings on the market some manufacturers have expressed that two years is not sufficient to develop compliant coatings. They have suggested an interim limit to go into effect in a year and additional time to achieve the final limit staff is proposing. Staff is considering this two-step process and extending the final compliance date for the two-component general category for perhaps a year.
This Rule is scheduled for hearing in December.
Lee Lockie, Director of Area Sources, presented committee with a brief status report on Proposed Rule 1157, Aggregate and Related Operations. She reported that staff has been meeting with the industry to resolve outstanding issues and has made progress. The rule structure and control measures have remained the same and there are 4 remaining issues with the affected sources. First, test methods to enforce the opacity limits are being discussed with the industry who are unfamiliar with the methods for measuring fugitive dust and staff is making sure that the industry understands how the measurements will be made and under what circumstances would excessive dust lead to a violation. She also reported that recent rains have created muddy conditions near to the exits to these facilities. The facilities are saying the mud is sticking to the tires, making it difficult to remove with rumble grates and wheel washers. They allege that this sticky mud is created by the use of chemical stabilizers which would be required to be used even more extensively on unpaved roads under this proposed rule. It is staff’s opinion that this is due to the lack of experience that many facilities have in applying the stabilizers properly. The third issue surrounds the requirement that active facilities have wheel washers and rumble grates at their exits to prevent track out of mud to public roads. The hot mix asphalt plants and the concrete batching plants have suggested that sweeping is a more cost-effective alternative to wheel washers since all of their internal roads are paved and their aggregate products are carefully metered to fully enclosed trucks. Lastly, some facilities have asked for removal of the requirement to sweep internal paved roads at the end of each work shift and that instead they be required to sweep at the end of a day or on a weekly basis. Ms. Lockie concluded by saying that she is confident that these issues can be resolved before the public hearing which is scheduled for December, 2004.
Susan Nakamura, Planning and Rules Manager, presented the results and findings for a Concept Paper for Proposed Rule 1401.1 – Requirements for New and Relocated Facilities Near Schools. The Concept Paper is being developed based on one of the ten early action strategies identified in the September 2003 Cumulative Impacts White Paper. The objective of the analysis is to identify the number and types of new or relocated facilities with toxic risks that were sited near schools. Based on permitted data over the past six years, there were 12,000 permits issued for new or relocated facilities. Of these 12,000 facilities, only 16 facilities were sited near a school and had a facility-wide cancer risk between 1- and 10-in-a-million, the remaining facilities were either not sited near a school, and/or posed no toxic risk or had a cancer risk less than 1-in-a-million. Based on the results, the AQMD staff is recommending that Proposed Rule 1401.1 be developed to establish a facility-wide risk threshold of 1-in-a-million for all new and relocated facilities that are sited within 1,000 feet of a school. The AQMD staff will present the Concept Paper at the November Governing Board Meeting. The Concept Paper is being released for a 60-day public review and comment period. The AQMD staff will proceed with rulemaking for Proposed Rule 1401.1 and anticipates a pre-hearing in spring 2005 and a rule adoption hearing in summer of 2005
Jay Chen, Engineering & Compliance Senior Manager, presented this item. Mohsen Nazemi, Assistant Deputy Executive Officer, indicated that Rule 1469 regulated hexavalent chromium emissions from chrome plating shops. The rule was amended in May 2003 and the Board required a status report to this Committee. Jay Chen reported that since the rule was amended, staff had certified 5 fume suppressants for rule compliance, implemented the streamlined permit format which was popular among the industry and District staff, and developed a guidance document for one of the compliance options. Since the industry raised several implementation issues, staff met and discussed with them and was able to resolve these issues. Staff also conducted outreach activities to promote compliance. Staff conducted six rule-required training classes including one in Spanish and certified 378 individuals who were responsible for day-to-day compliance at the facilities. Facilities near schools or sensitive receptors were inspected three times a year as directed by the Board, and all other facilities were inspected at least once a year. In addition, staff participated in several multiagency inspections as part of LA City Attorney's Chrome Plating Initiative. There were 176 facilities subject to the rule. Compliance status showed that during the reporting period of almost 16 months, staff conducted 566 inspections or an average of three per facility. Staff found 163 counts of recordkeeping and reporting violations and seven counts of emissions or emission-related violations. 85 facilities, or almost half, were issued notices to comply and three facilities were issued notices of violation. Most of the rule requirements had been in effect since May of this year and the next major compliance date was May 1, 2005, when the new emission limits would be in effect along with other control options. Another year from that, the two-year training and re-certification cycle would start all over again. As for staff's recommendations, since 98% of the facilities were in compliance, no rule amendment was necessary at this time. Staff would continue to monitor and inspect the facilities to ensure compliance and report back to this Committee in the future, if changes to the rule were necessary. Mohsen Nazemi indicated that making 566 inspections took significant compliance resources, but the results of frequent inspections has paid off as success in high rate of compliance.
Marty Kay, Program Supervisor, Technology Advancement, presented the semi-annual report on changes that have occurred in Part B of the BACT guidelines and proposed amendments to Part D. In Part B, LAER/BACT Determinations for Major Polluting Facilities, eight new listings had been added and two listings had been updated. In Part D, BACT Guidelines for Non-Major Polluting Facilities, staff recommended several minor changes to (1) clarify one guideline, (2) cross reference another guideline to a new rule that in some cases may be more stringent than the guideline and (3) correct typographical errors in two other guidelines.
WRITTEN REPORTS
All written reports were acknowledged by the Committee.
The meeting was adjourned at 11:55 a.m.
October 22, 2004 Committee Agenda (without its attachments)
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