BOARD MEETING DATE: June 1, 2007
AGENDA NO. 33
REPORT:
Stationary Source Committee
SYNOPSIS:
The Stationary Source Committee met Friday, May 25, 2007. Following is a summary of that meeting. The next meeting will be June 22, at 10:30 a.m., in Conference Room CC8.
RECOMMENDED ACTION:
Receive and file.
Dennis Yates, Chair
Stationary Source Committee
Attendance
The meeting began at 10:35 a.m. Present were Dennis Yates, Jane Carney (left at 12:00 p.m.) and Gary Ovitt. Absent was Ron Loveridge.
INFORMATIONAL ITEMS
- Update on Air Quality Management Plan
Presentation waived. This item was presented earlier at the Mobile Source Committee meeting.
Larry Bowen, Planning and Rules Manager, Office of Planning, Rule Development and Area Sources, presented this item. A June 1, 2007 public hearing has been set for amendments where staff is recommending an enhanced monitoring program for pressure relief devices (PRDs) at petroleum refineries and inclusion of marine terminals and oil and grease re-refiners in the mandatory leak detection and repair provisions of the rule. No emission reduction is claimed for the enhanced monitoring although staff believes that it will result in fewer PRD releases. Inclusion of the marine terminals and re-refiners will result in 0.4 tons per day of VOC reduced at a cost effectiveness of $919/ton reduced.
During public comment period, two individuals provided comments.
Mike Wang representing WSPA – The PRD program is working as evidenced by fewer releases and less emissions over the last several years. The proposal that has developed through working with staff is one that can be supported.
Miles Heller representing BP ARCO - Want to clarify that the emissions from BP ARCO’s PRD release in 2006 were primarily as the result of a single release and actions have been taken to ensure a similar release will not occur in the future.
- Proposed Amended Rule 1309.1 – Priority Reserve and Re-adoption of Rule 1315 – Federal NSR Tracking System
Dr. Laki Tisopulos, Assistant Deputy Executive Officer, Office of Planning and Rule Development, presented this item. The Board directed staff to return with a proposal that reflects additional criteria for access to the Priority Reserve by electrical generating facilities (EGFs) proposing to locate in the more polluted areas of the AQMD. Through the public input process the staff proposal has evolved and now includes additional stringent emission rates, maximum emissions and concentration limits for EGFs that would locate in the more polluted areas. These criteria for toxics are in addition to the tiered mitigation fees and health protective criteria of previous proposals. Staff has prepared isopleth maps of PM10 impacts of some of the proposed projects that show that the maximum point of concentration from operation of the proposed EGFs is a fraction of current ambient concentrations. At the request of Committee Member Carney, staff will also prepare a map of another proposed project that recently submitted permit applications. Staff is still continuing to work the proposal with some of the commentors and is still planning for a July hearing.
During public comment period, two individuals provided comments.
Karl Lany of SCEC on behalf of Riverside Public Utilities – The most recent staff proposal does not adequately address the needs of the small peaker units necessary for municipal utilities such as the City of Riverside. The City will be meeting with staff next week to see if the proposal can be adjusted to address those issues.
Mike Carroll of Latham and Watkins – Represents many of the project proponents that will be impacted by the proposal. The proposed standards are very stringent and in some cases go beyond current BACT. His clients have indicated they can achieve some of the standards but currently no project can meet all without making some changes in the project. They are working very hard through re-design and other efforts to comply with all the requirements and will continue to work with staff to resolve these issues. The maps presented by staff were appreciated and believes they show the story of just how clean these projects are. Although they are large sources their impact is a fraction of the local ambient concentrations.
- Proposed Amended Rule 219 – Equipment Not Requiring a Written Permit Pursuant to Regulation II
Dr. Tisopulos summarized two sets of exemptions under PAR 219. Mayor Yates had requested this briefing by staff to clarify certain technical aspects of the proposal and to discuss options for taking the onus off the users to provide acceptable VOC content information for the low-VOC materials they use.
Dr. Tisopulos explained that staff is proposing to exempt certain additional equipment, such as spray machines, from permit requirements. There would be two sets of exemptions for the use of VOC-containing materials under the staff proposal: a uniform “technology neutral” exemption applicable to all printing, coating and adhesive application operations up to 3 pounds per day (0.4 ton per year) and an additional “technology neutral” exemption that would be applicable to all of the super clean technologies. This additional exemption applicable to all super clean material replaces the unrestricted usage exemption currently available only to the UV/EB materials. The proposal establishes a very liberal emissions cap of 1 ton per year per equipment line for all ultra-low VOC content material, which is 2.5 times more lenient than the standard exemption and would ask the facilities to register their equipment. Staff has discovered facilities using other ultra-low VOC materials with emissions of 10-20 tons per year and Dr. Tisopulos explained that AQMD has to draw the line somewhere in order to broaden incentives for the use of other equally clean technologies and still protect the air quality.
On the issue of test methods, Dr. Tisopulos explained that AQMD rules already specify acceptable VOC test methods for non-thin film materials, which constitute most of the applications of UV materials, and staff also accepts reasonable calculation procedures for thin film applications where acceptable VOC test methods are not available. Not contained in the rule, but established as an engineering policy, the 5% VOC content default factor is used only when acceptable test results and calculation procedures for specific materials are not provided by the applicant. This default value was established based on limited testing a few years ago. Staff is willing to conduct additional testing to refine/adjust this value. While industry was initially supportive of the additional testing, they withdrew that support in the March/April time frame. He added that during the recent conference call with industry RadTech has agreed to send to staff a proposal for a calculation-based procedure for determining VOC content for the thin film materials for staff’s review. In addition, staff would be contracting with a qualified laboratory to conduct further emissions testing on a wide range of UV materials to determine whether the 5% default factor should be further adjusted.
During the public comment period, two individuals provided comments. Ms. Loof representing RadTech and Mr. McConnell representing McConnell Furniture, and in response to public comments staff provided the following information:
- 1. Mr. McConnell, representing McConnell Furniture Inc., testified at the public hearing. The company is presently under permits, however, it may be exempt under the staff proposal should emission tests show that the company is indeed using ultra-low VOC materials and emissions from each equipment is less than one ton VOC per year;
- 2. The staff proposal is liberal enough to allow for increases in throughput without triggering permits;
- 3. Staff focused on printing, coating and adhesive application operations for this amendment because they are by far the largest potential sources of VOC emissions when compared to other source categories; and
- 4. One of the primary reasons for proposing different exemption levels for the different segments of UV technology is because some of the new, UV materials (i.e. solvent borne and water borne UV materials) have solvent content noticeably higher than the 100% solids UV materials, which was first introduced when the unrestricted UV/EB usage exemption was first developed years ago.
Committee Chairman Dennis Yates encouraged RadTech to work in a more cooperative manner with staff to identify appropriate VOC content and calculation methods for UV materials and instructed staff to return to the committee in 90 days to report results of laboratory testing that AQMD is planning to conduct.
The committee members approved staff’s recommendation to take the current proposal to the Board for public hearing on June 1, 2007.
- Proposed Amended Rule 1113 – Architectural Coatings
Dr. Laki Tisopulos presented this item. The staff at the direction of the Committee was proposing an amendment to remove primers from the alternative compliance option and clarify an inconsistency with metallic pigmented coatings between Rule 1113 and the U.S. EPA national rule. Based on the withdrawal of the request by Zinsser, the Committee directed staff to drop the alternative compliance option for primers from the proposal and proceed with the other amendments related to metallic pigmented coatings.
During the public comment period the following individuals provided comments.
Howard Berman representing Zinsser – Want to express their thanks for the Committee’s consideration and decision.
Curt Coleman representing Sherwin Williams – On behalf of Sherwin Williams wants to thank the Committee for their decision.
Jeffrey Margulies representing the National Paint and Coatings Association (NPCA) – On behalf of NPCA wants to thank the Committee for their decision.
- Report on Rule 1118 – Control of Emissions from Refinery Flares
Larry Bowen presented this item. Staff will be presenting a report to the Board on June 1 as directed by the adopting resolution of the November 2005 amendment. A rule amendment is not recommended at this time and staff will continue to monitor implementation of the rule. Staff will also be seeking guidance on proceeding with the analysis of the issue of uninterruptible power at refineries.
- Report on Dry Cleaner Grant Program & CO2 Machines
Committee member Jane Carney requested this item be moved to the June meeting.
WRITTEN REPORTS
All written reports were acknowledged by the Committee.
PUBLIC COMMENTS
There were no public comments.
The meeting was adjourned at 12:10 p.m.
Attachment (DOC 42.5kb)
May 25, 2007 Committee Agenda (without its attachments)
