BOARD MEETING DATE: September 3, 2004
AGENDA NO. 25
Stationary Source Committee
SYNOPSIS:
The Stationary Source Committee met Friday, August 28, 2004. Following is a summary of that meeting. The next meeting will be September 24, 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 10:30a.m. Present were Ronald Loveridge, Chairman (left at 11:20), Dennis Yates, (Acting Chair upon Ronald Loveridge’s departure) and Bill Postmus by Videoteleconference. Absent were William Craycraft and Jane Carney.
INFORMATIONAL ITEMS
- Rule 1118 – Refinery Flare Report
- Rule 1122 – Solvent Degreasing
- Update on RECLAIM Program Amendments
Pang Mueller, Senior Manager for Refinery/Energy and RECLAIM Administration presented this report. The report was generated pursuant to the Board Resolution adopted with Rule 1118 - Emissions from Refinery Flares, on February 13, 1998. The Governing Board directed staff to evaluate all the information and data collected and submitted to the AQMD by the affected facilities subject to Rule 1118 during the first two years of operations. Based on the information obtained, the Governing Board also directed staff to make a determination on whether emissions from flaring operations are significant and make recommendations for the AQMD Governing Board’s consideration on any changes to Rule 1118. At the request of the refineries, staff also incorporated data collected in 2002 and 2003 into this report.
The data collected over the past four years show that, of the 21 billion standard cubic feet of gas reported to be vented to the flares, 17 percent of the gas released to the flares was due to emergency, maintenance, planned start-ups and shutdowns, and process turnaround activities. For the remaining 83 percent of the gases reported to be vented to the flares, 2 percent was from venting of fuel gas to the flares, and 2 percent was from venting of process gas to maintain vessel operation pressure within the desirable operation, while 79 percent was due to unknown and non-recordable (vent gas at the flow rates and duration below recordable event) flare events.
Staff believes SOx emissions from flaring are significant; however, it should be noted that the reported SOx emissions have declined since the start of the flare gas monitoring under Rule 1118. In 2000, SOx emissions from flares were reported to be as high as 2,633 tons. However, the reported SOx emissions declined to 1,793 in 2001, 754 tons in 2002 and 735 tons in 2003. Pang also noted that reported emissions may vary due to sampling location, data substitution method, reporting methodology changes, and monitoring equipment operational status. Additionally, concerns were raised regarding flow measurement accuracy at low gas flow velocities. In addition to flow accuracy concerns, vent gas sampling location and sampling frequency are also factors influencing the accuracy of the reported emissions.
Although efforts have been made by many facilities to minimize flare emissions since the start of the program, there is no regulatory requirement to ensure that emission reductions will continue. Staff believes there are further emission reduction opportunities and emission reduction targets that should be explored by facilities subject to Rule 1118. Staff recommends that Rule 1118 be amended to set appropriate emission goals for facilities subject to the rule. In addition to setting emission reduction targets, Rule 1118 should also be amended to increase compliance and accuracy of emissions information.
Ron Wilkniss, Western States Petroleum Association (WSPA) representative, expressed appreciation for AQMD’s efforts to incorporate the last two years of data. He believes that the Executive Summary accurately reflects the status of refinery flare operations. However, he expressed concerns that SOx emissions from flares had been reduced over seventy percent and AQMD should continue to work with the refineries. He believes any attempt to initiate the rule making process is unnecessary at this time. He suggested the uniqueness and complexity of the flare systems would make it difficult to specify control approaches for flares.
Ken Hudson and Carolyn Keith, representatives from British Petroleum (BP) and ExxonMobil respectively, also expressed appreciation for AQMD’s efforts to incorporate an additional two years of data in this report. Ms. Keith also expressed concerns that the refinery flare systems and refinery operations are complex. Most refineries are making their best efforts to minimize flaring. However, flaring events may occur under various unforeseen circumstances, and it would be difficult to develop a rule that would appropriately address all situations.
Councilman Yates recognized that the refineries had already reduced emissions from flares and was concerned that positive efforts should not be punished by adopting a rule to control emissions from flares. However, he also recognized the needs to further reduce emissions in the South Coast Air Basin. Supervisor Postmus concurred with Councilman Yates.
Lee Lockie, Director of Area Sources, presented this item. Rule 1122 – Solvent Degreasers, establishes VOC and toxic emission reduction requirements for all types of degreasers that carry out solvent degreasing operations with VOCs or NESHAP halogenated solvents. Currently, certain small-sized degreasers that are used for specialized cleaning applications are exempt from the rule requirements. This rule exemption, under section (k)(1)(D), will expire after January 1, 2005. The AQMD staff has completed a Technology Assessment to determine the need to continue the exemption beyond the sunset date. The proposed changes to Rule 1122 reflect the findings and conclusions of the technology assessment.
Proposed Amended Rule (PAR) 1122 will establish a permanent but limited exemption for degreasing equipment used in cleaning high-reliable electronic components that are designed to travel over 100 miles above the earth’s surface. For other cleaning applications identified in section (k)(1)(D), staff is proposing to allow the use of high-VOC solvents in small-sized degreasers that are vented to an approved emission control system. Although the Technology Assessment concluded that most of these applications can readily use alternative (compliant) cleaning materials, the proposed amendment will provide the affected industries added flexibility in complying with the rule requirements after the exemption in (k)(1)(D) expires . In addition, staff is proposing a 90-day extension of the existing exemption in order to give facilities that choose to use the control equipment option additional time for purchase, permitting and installation of the control equipment. Staff is also proposing to add a permanent exemption for research and development/quality assurance programs. Additionally, staff is proposing to extend the exemption for the cleaning of photocurable resins from stereolithography equipment and models. Currently, certain types of photocurable stereolithography resins cannot be cleaned with low-VOC cleaners or VOC-exempt solvents. The proposed amendments do not allow the use of NESHAP halogenated solvents.
Jill Whynot, Planning and Rules Manager, provided an update on RECLAIM amendments. The Informational Hearing has been continued to the October Governing Board meeting because of the stakeholder requests. Staff will be releasing a draft white paper on August 27, 2004, and will make several files of technical information available on the web over the next week, to respond to requests for additional data. At the September Governing Board meeting, there will be a public hearing on Rule 2007 only. The proposed amendments will continue existing trading restrictions for power plants until the amendments to RECLAIM reduce credits to reflect BARCT. The RECLAIM rule changes will come to the December Governing Board meeting at the earliest.
Handouts were provided that illustrate, for several types of equipment, the range of the current emissions for equipment in RECLAIM, the level that represented the rules and control measures subsumed in the original program, and the proposed new level of BARCT to adjust allocations and cost effectiveness. A summary chart was also provided. Key issues related to BARCT and cost-effectiveness were discussed.
A chart was distributed showing RTCs available in the market, actual emissions, staff’s proposal for reductions and two variations proposed by industry. Issues related to this include the amount and timing of reductions, whether to apply rates of reduction equally to all facilities or to have variable reductions per facility and whether there should be any potential exemptions from reductions. Staff will continue to work with stakeholders on this important program.
A WSPA representative commented that they appreciate the informational hearing being done in October. A general concern from industry stakeholders is that the reductions not be too large to disrupt the liquidity of the market. BARCT evaluations will occur every three years, so they suggest additional reductions be deferred to that process.
A representative of one of the RECLAIM refineries stated that the compliance is demonstrated on a quarterly basis and facilities hold back some credits. Not all unused credits are available in the market.
WRITTEN REPORTS
All written reports were acknowledged by the Committee.
The meeting was adjourned at 11:35a.m.
August 27, 2004 Committee Agenda (without its attachments)
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