BOARD MEETING DATE: October 2, 2009
AGENDA NO. 36
REPORT:
Stationary Source Committee
SYNOPSIS:
The Stationary Source Committee met Friday, September 25, 2009. Following is a summary of that meeting. The next meeting will be October 16, at 10:30 a.m., in Conference Room CC8.
COMMITTEE:
RECOMMENDED ACTION:
Receive and file.
Dennis Yates, Chair
Stationary Source Committee
Attendance
The meeting began at 10:40 a.m. Present were Dennis Yates, Dr. Joseph Lyou, Josie Gonzales (left at 11:40 a.m.) and Jane Carney. Absent were Ronald Loveridge and Michael Cacciotti.
As per Mayor Yates’ request, Agenda Item 6 was discussed out of order. Committee Member Jane Carney left the meeting for agenda item 6 citing possible conflict of interest, as Fleetwood Aluminum Products and Modular Metal Fabricators as sources of income for her.
INFORMATIONAL ITEM
- Update on Laboratory Testing to Implement Rule 1144 – Vanishing Oils and Rust Inhibitor
Naveen Berry, Planning & Rules Manager, presented an update on laboratory testing to implement Rule 1144. Committee Chairman, Dennis Yates stressed the importance of staff working closely with industry to develop a test method in a timely manner. John Burke of the Independent Lubricant Manufacturers Association distributed a letter and commented that Thermogravimetric Analysis (TGA) should be the preferred laboratory test method as opposed to SCAQMD Method 313L. Mike Pearce of W.S. Dodge Oil also distributed a letter and commented that industry is concerned that a test method would not be developed soon enough to allow reformulation and testing before the future limits become effective. Mr. Berry responded to all the comments.
ACTION ITEM
- Briefing on Tree Planting Initiative
Jill Whynot, Director of Strategic Initiatives, provided a briefing on staff’s recommendations related to the Tree Planting Partnership. This is one of the Chairman’s initiatives for 2009. The key objectives are to provide funding support for cities to plant California native trees and to provide an opportunity for student employment. Thirty-four applications were received from thirty-two cities.
At the October Board meeting, staff will recommend issuing twenty contracts, as outlined in the attachment to the committee agenda. This will result in almost 16,000 trees being planted and about 4,400 student hours. Funding will be less than $700,000. Staff will also recommend reissuing the Program Announcement so cities that previously applied could reapply, and other cities could have the opportunity to submit requests. Some of the cities that applied that were not recommended for funding either did not include student employment or included trees that were not native to California.
Funding for this program is from interest earned in the Rule 1309.1 Mitigation Fund. The Committee members recommended approval of this item.
Moved (Carney) seconded (Gonzales), and unanimously recommended for approval.
INFORMATIONAL ITEMS
- Update of South Coast Refinery Emission Trends
Dr. Laki Tisopulos, Assistant Deputy Executive Officer with the Planning, Rule Development and Area Sources, gave the staff presentation. This item was referred to the Stationary Source Committee by the Governing Board in July in response to a public comment. Dr. Tisopulos informed the committee that there are several rules and regulations that the Board adopted in the last several years aimed at reducing non-attainment emissions from this sector. In general, in line with expectations, there is a healthy downward trend in emissions from the entire refinery sector as a whole and the individual refineries with respect to all non-attainment pollutants. And, while there may be year-to-year variability in individual refinery emissions due to a variety of reasons, the trend in emissions from these refineries over the FY2000-01 and FY2006-07 timeframe is downward. Dr. Tisopulos gave examples of the reasons that may be contributing to some of the emission fluctuations observed. The higher fluctuations observed with CO, which is an attainment pollutant, are dominated primarily by two refineries. Mayor Yates asked how emissions are verified. Staff responded that SOx and NOx emissions are verified through District-approved continuous emissions monitoring and annual RECLAIM Audits; while, for other pollutants, facilities have to quantify emissions based on District-approved source tests or rely on District or EPA-approved emission factors when source test-based information is not available. Regular inspections, Blue Sky-type of enforcement operations and periodic emissions audits are among the tools staff use routinely to verify fugitive and other emissions reported by refineries. In response to a question from Ms. Carney regarding variability in emissions rates among the different refineries, Dr. Tisopulos responded that each refinery should be viewed independently and that the regulatory program in effect is reducing emissions from each refinery independent of their starting point in emissions rates. Staff anticipates the downward trends in emissions will continue once all adopted rules are fully implemented. While staff intends to continue to work with the individual refineries to better understand the variability in CO emissions and also refine/verify other reported emissions, no major alteration in trends are expected to result from such refinements.
Committee Member Jane Carney left the meeting for agenda item 3 citing possible conflict of interest, as U.S. Battery, Brithinee Electric, Precision Stampings and Jensen Enterprises are sources of income for her.
- Rule 1155 – Particulate Matter Control Devices
Jill Whynot outlined staff’s proposal for this rule, which is being set for hearing in October and will go to the Board for consideration in November. This rule would apply to many different types of particulate control devices (baghouses, electrostatic precipitators, scrubbers, and others) in many different industries. The proposal seeks to have equipment maintained and operated properly to minimize emissions.
For all equipment, the proposal would set a no visible emissions limit and require transfer of materials in a controlled manner. Visible emissions would be checked weekly for five minutes. There are additional proposed requirements for baghouses, including bag leak detection systems (BLDS) for the largest baghouses, upgrade of manual shaker units, and an emission limit of 0.01 gr/dscf.
Staff has formed a working group, has done many site visits and is conducting source testing at several facilities. Key issues raised by the asphalt industry relate to the 0.01 gr/dscf emission standard, ‘blue smoke’ and the proposed no visible emission standard, and concerns about whether BLDS will work in their operations. Staff is considering how to address these issues. A demonstration program is being set up with BLDS manufacturers to install equipment at asphalt plants. Costs to facilities are estimated at $325 per year for visible emissions checks, $9,000 for BLDS, and $8,500 for upgrading manual shaker systems. If asphalt manufacturers need to replace their bags, 2 or 3 dozen baghouses would cost ~$50,000 each.
Curt Coleman, representing the Southern California Air Quality Alliance, made the following comments: the rule needs to have phased implementation dates and not be effective immediately on adoption; the proposed 0.01 gr/dscf standard will be a problem for Title V facilities because they need to be able to demonstrate compliance; the emission standard should only be put in place if there is a way to demonstrate compliance without a source test or it should apply only to the largest baghouses.
Scott Taylor, from the Asphalt Pavement Association of California (APA), stated that their members are working with staff on the BLDS demonstration. They are concerned that ‘blue smoke’ cannot meet the proposed requirement of no visible emissions. Most asphalt plants have large equipment, and they’ll need time for budgeting and replacing bags in order to meet the proposed emission limit.
Ken Barker, from Sulley-Miller, also speaking for APA and the California Construction and Industrial Materials Association (CalCIMA) commented that his facility recently replaced equipment that controls ‘blue smoke’, but it would not meet a no visible emissions requirement. They need time to work on BLDS, which may give false positives in a moist environment. He agreed with previous speakers that it would be difficult to stay in compliance with a 0.01 gr/dscf emission standard and suggested that daily visible emission checks be required instead of an emission limit.
Christine Jones, from CEMEX, an aggregate ready mix company, recommended that the emission limit be used as a trigger for further action, and not be a standard for the basis of a Notice of Violation. There are no source test data available for aggregate ready mix plants, and she offered their facility for testing.
Dr. Lyou would like staff to evaluate whether 0.01 gr/dscf would be health protective for toxics, such as nickel. He understands the concerns that Title V facilities have because their permits have to include means to assure compliance.
Dr. Tisopulos responded to the points raised by industry representatives that equipment that is operating properly, should not have a problem and is expected to be below the emission limit. Staff did not feel it was reasonable to require source tests when 95 percent of the equipment tested is under that level. Random source testing will be done periodically by AQMD staff
Committee Member Josie Gonzales left the meeting.
- Rule 1111 – NOx Emissions from Natural Gas-Fired Fan Type Central
Furnaces
Joe Cassmassi, Planning Manager, provided an overview of the proposed modifications to Rule 1111, NOx Emissions for Natural Gas Fired Fan Type Central Furnaces. The proposed modifications to the rule would lower the emissions limit from 40 to 14 nanograms per Joule with implementation beginning in 2014. Furnaces in mobile homes would be required to meet the 40 ng/J limit in 2012 and 14 ng/J limit by 2018. Mr. Cassmassi stated that the implementation date for non-mobile homes was delayed by two years in response to manufacturers’ comments to provide more time to develop the required furnace technology. Also, the proposal provides for a sell through period of 300 days and enhanced labeling to identity compliant and non-compliant units. Staff is also proposing an alternate compliance plan option that would provide an extension of up to three additional years beyond the compliance date, but would require a mitigation fee and enhanced reporting to the District. The proposal made to SSC reflects a lower tiered mitigation fee ($140/unit maximum compared with the initial fee of $209 proposed at the Public Workshop), based on demonstrated emissions to dampen industries’ market concerns, and provides for an efficiency discount. In addition, the proposal included language committing Staff to provide a technology assessment report to the Governing Board 18 months prior to the main rule implementation. Also, staff is proposing a resolution to pursue partnering with industry in a technology assessment or conducting independent studies to evaluate research and development. Finally, the proposal is recommending incentives to manufacturers who deliver compliant units ahead of schedule.
Mr. Dan McGivney, of Southern California Gas, commented that he was pleased to find that several of the modifications to the proposed rule language responded to comments made at the workshop and task force meetings. However, Mr. McGivney stressed that further monetary incentives are needed to bolster the introduction of high efficiency units. Mr. Stan Van Vleck, of the manufacturer’s representative organization AHRI, asked to delay consideration of the rule pending the outcome of AHRI/SoCal Gas sponsored research project. Mr. Van Vleck stated that the industry would commit to abide by the outcome of the research study if the District delays the rule amendment and participates in the research program.
- Rule 1112.1 – Emissions of Particulate Matter from Cement Kilns
This item was continued.
WRITTEN REPORTS
All written reports were acknowledged by the Committee.
PUBLIC COMMENTS
There were no public comments.
Mayor Yates announced that the next Stationary Source Committee meeting will be on October 16, 2009.
The meeting was adjourned at 12:05 p.m.
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