South Coast Air Quality Management District

 

MEETING HIGHLIGHTS

 

	SRC Members
Nahid Zoueshtiagh (by phone)			Martin Ledwitz
Bill Dennison			Hal Taback
Katy Wolf			Anoosheh Mostafaei
Stan Romelczyk (by phone)			Todd Wong (by phone)
Seong Min (for Greg Adams)			Steve Simons
Gary Rubenstein (by phone)
		Attendees
Duc Tran (by phone)			Millie Yamada
Gabe Trinidad			Steve Hurlock
	AQMD Staff
Marty Kay			Howard Lange
Alfonso Baez

 

 

 

 

Marty Kay welcomed the SRC members and the audience to the meeting.  The topics listed below were discussed during the meeting.

¾    Minutes of September 25th Meeting

¾    Responses to Comments from September 25th Meeting

¾    New and Updated BACT - Part B Listings

¾    Other Business

 

Minutes of the September 25th Meeting

The minutes of the September 25th meeting were approved as written.

 

Responses to Comments from the September 25th Meeting

AQMD stated that changes in the listings presented at the September 25th meeting that had been agreed upon at the meeting, as well as any agreed-upon changes in the minutes from the prior meeting, had been made.  Committee and audience members could check the final listings and minutes as posted on AQMD’s web site.

At the September 25th meeting, AQMD had agreed to investigate and report back to the committee on several items as follows:

1.      A committee member had made a comment regarding AQMD’s proposed amendment to Part D of the BACT Guidelines adding a new guideline for co-composting consisting of compliance with Rule 1133.2.  The committee member had commented that an exemption of plants designed for less than 1000 tons per day or less than 35,000 tons per day if also less than 20% biosolids, which was included in the guideline, is not intended to be a general exemption but is intended to apply to only one facility.  AQMD had re-examined the Rule language and found that the exemption is a general exemption, not restricted to any specific facility.  However, AQMD also noticed that the exemption of facilities designed for less than 35,000 tons per day and less than 20% biosolids was for existing facilities only.  Therefore, that portion of the exemption had been removed from the proposed guideline. (Howard Lange, AQMD)

2.      Regarding the proposed update to the Part D guideline for fugitive emissions from bulk terminals, the committee had suggested that the term “bulk terminals” be replaced with a more definitive term.  AQMD recommended that the term “organic liquid loading facilities”, which is used in Rule 462, be used in the guideline, replacing “bulk terminals”.  The committee agreed with this suggestion. (Howard Lange, AQMD)

3.      Regarding the proposed update of the Part D guideline for lithographic printing, a committee member and an audience member had suggested that the requirement for oil-based inks be broadened to allow use of UV-curable inks and water-base inks.  AQMD had discussed this with the permitting team and found that UV-curable inks would be an appropriate addition but water-base inks are incompatible with the lithographic process.  A committee member had asked whether the 10 mm Hg vapor pressure limitation on blanket and roller washes applies to total vapor pressure of the wash or to vapor pressure of VOC components only.  AQMD had discussed this with the permitting team and found that it applies to the VOC components only.  The language in the guideline had been clarified accordingly. (Howard Lange, AQMD)

Discussion: The same committee member commented that, with the Rule 1171 limits on the VOC content of blanket and roller washes dropping from 600 and 800 g/l to 100 g/l in July 2005, the vapor pressure limit should probably be eliminated from the BACT guideline at that point for the following reasons: (1) it may be hard to enforce the vapor pressure limit since the manufacturers of the new cleaning products with <100 g/l VOC may not in all cases reveal the details of the VOC content, (2) some of the new products may rely upon high-vapor pressure VOCs as minor constituents and may thus not be able to meet the 10 mm limit, and (3) vapor pressure is not a useful criterion in any event since virtually all of the VOC is released regardless of its vapor pressure.  AQMD agreed to look into this and report back. (Katy Wolf, IRTA; Marty Kay, AQMD)

4.      Regarding the proposed new MSBACT guideline for Surfactant Manufacture, compliance with Rule 1141.2, a committee member had asked why soap manufacture was excluded.  AQMD had investigated and had found that surfactant and soap manufacturing are substantially different processes.  Surfactant manufacturing processes involve organic synthesis reactions whereas soap manufacture consists of reactions between caustic chemicals with fats or oils at elevated temperature. (Howard Lange, AQMD)

5.      At the September meeting, a representative from Prudential Overalls had registered an objection to the MSBACT NOx guideline for laundry tumbler dryers, which requires that they meet 30 ppmvd@3%O2.  The objection was that low-NOx burners that are available for this application are difficult to operate, are high-maintenance, and haven’t been proven to meet the 30 ppm limit.  AQMD had investigated and had found that (1) Aramark Uniform Services, which operates a laundry tumbler dryer permitted at 30 ppm that is listed in AQMD’s LAER/BACT (Part B) Guidelines, is satisfied with the burner after nearly three years operation and (2) the burner manufacturer who supplied the burner used in Aramark’s dryer did provide, and still offers, a 30 ppm guarantee.  AQMD therefore had decided that the 30 ppm guideline should stand, however AQMD stated that it would be willing to reconsider the 30 ppm limit if evidence is submitted showing that it cannot reasonably be met. (Howard Lange, AQMD)

 

New BACT Part B, Section I Listings

I.C. Engine - Fire Pump, East Los Angeles College (A/N 417691) I.C. Engine - Fire Pump, Los Angeles County (A/N 418342)

 

These are two newly installed fire pump engines, both supplied by Clarke Equipment Company, who is a major fire pump supplier.  Clarke purchases its engines from engine manufacturers, in this case John Deere (East Los Angles College) and Detroit Diesel Allison (Los Angeles County), and modifies them for lower emissions.  Part D of the BACT Guidelines generally requires that emergency diesel engines be certified to meet Tier 2 of the EPA Nonroad emission standards as Tier 2 takes effect for various engine sizes.  However, fire pump engines are exempt from that requirement if no UL-listed Tier 2 fire pump engines are available, which thus far has been the case.  At present, therefore, fire pump engines must only meet the Tier 1 standards.  These two engines are exemplary in that their full-load emissions not only meet the Tier 1 standards but are significantly less than the Tier 2 standards for all four regulated pollutants—NOx, CO, NMHC and PM. (Howard Lange, AQMD)

Discussion:  A committee member asked whether the engines are UL-listed and suggested that this be noted on the listing.  AQMD responded that they are UL-listed and agreed to add this information to the listing. (Gary Rubenstein, Sierra Research; Howard Lange, AQMD)

 

Dryer or Oven, ColorAmerica (A/N 364658)

This is a tenter frame fabric dryer equipped with a low-NOx burner.  The listing had been in Section III, Other Technologies, based on a Permit to Construct that contained a NOx limit of 10 ppmvd@15%O2, which is equivalent to 30 ppmvd@3%O2.  The Permit to Construct was issued with the provision that the final NOx limit in the Permit to Operate would be based on what the burner was actually able to achieve in a source test, up to a maximum of 60 ppmvd@3%O2, the Part D BACT guideline for tenter frame fabric dryers.  Since the date of the original listing, the source test had been performed and had been extensively reviewed by the permitting team and AQMD’s Monitoring & Source Test Engineering group.  In that the dryer exhaust was highly diluted with excess air, the corrected NOx level was subject to some interpretation.  It had been concluded that the source test proved that the NOx level was greater than 30 ppmvd@3%O2 but less than 60 ppmvd@3%O2.  The team had therefore decided to issue the Permit to Operate with a NOx limit of 60 ppmvd@3%O2.  The listing was being updated with the source test data and the revised NOx limit and was being moved from Section III to Section I. (Howard Lange, AQMD)

Discussion: A committee member noted that the source test had been performed at 38% of the maximum heat input.  AQMD and another committee member responded that this was not unusual for a fabric dryer in that this type of dryer will typically spend much of its operating cycle at low fire.  The second committee member commented that emissions turn-down is frequently a problem with low-NOx burners on this type of dryer.  An audience member commented that the burner used in this case was not the best choice for achieving low NOx on a tenter frame dryer and that there were other burner products available that can maintain 30 ppmvd@3%O2 or less over the full firing range that is required. (Steve Simons, Southern California Gas Co.; Bill Dennison, Dennison and Associates; Gabe Trinidad, Maxon; Howard Lange, AQMD)

 

Concrete Batch Plant, Cemex (A/N 406717)

This is a typical concrete batch plant, in which cement and/or flyash is mixed with aggregate (sand, gravel and/or crushed rock) and loaded into trucks.  This is an example of existing Part D BACT guidelines being required.  Applicable guidelines in Part D include enclosed cement/flyash storage, enclosure of the cement/flyash handling areas and the batching and loading areas, venting of all these storage and handling areas to baghouses or filters, and maintenance of sufficient moisture in the aggregate to prevent dust emissions. (Howard Lange, AQMD)

Discussion: A committee member noted that fines captured in the baghouse and filters might be recycled to the process.  Another committee member mentioned that there may be a New Source Performance Standard for concrete batch plants. (Hal Taback, HTC; Bill Dennison, Dennison and Associates)

 

Asphalt Batch Plant, Blue Diamond (A/N 364181)

This is a typical asphalt batch plant, in which aggregate is mixed with recycled asphalt product (RAP), asphalt oil, and in some cases mineral filler (mostly lime) and/or powdered rubber.  Mixing and heating takes place in a rotary dryer, from which the product is loaded into trucks.  This is basically an example of Part D BACT guidelines being required.  The rotary dryer and mineral and rubber load-out chutes are vented to a baghouse.  The aggregate is required to be kept sufficiently moist to prevent visible dust emissions.  The oil storage tanks are vented through condensers followed by steel wool filters, and the condenser exit temperatures are not to exceed 120F.  The truck loading area is enclosed and vented to filters.  The rotary dryer is equipped with a low-NOx burner and flue gas recirculation and is restricted to a 33 ppmvd@3%O2 maximum NOx level.  The permit condition on NOx exceeds the Part D BACT requirement, which is a low-NOx burner and 36 ppmvd@3%O2, and had been determined to be achieved in practice. (Howard Lange, AQMD)

Discussion: A committee member noted that the source test data included PM concentration in the flue gas and asked whether the BACT listing was setting a PM concentration limit.  AQMD responded that there was no intention to do so. (Hal Taback, HTC; Marty Kay, AQMD)

 

Bulk Solids Storage, All American Asphalt (418322)

This is an enclosed aggregate storage system at an asphalt batch plant.  Enclosed storage of aggregate represents a significant advancement in PM control relative to the normal practice of storing aggregate in open piles.  Enclosed storage together with the usual BACT requirement of sufficient moisture was a BACT determination in this case.  This BACT guideline also applies to concrete batch plants.  (Howard Lange, AQMD)

Discussion: A committee member asked what specifically will be required for future aggregate storage systems.  AQMD responded that enclosed storage equivalent to this case will be required if the facility is major.  AQMD added that the silos may be open topped to allow aggregate to be loaded in. (Hal Taback, HTC; Marty Kay, AQMD)

 

New BACT Part B, Section II Listing

Rotogravure Printing, Quad Graphics (R14-12B)

This is a publication rotogravure printing operation permitted in West Virginia.  While AQMD’s Part B guidelines contain an example of a packaging rotogravure printing operation, this is the first listing for publication rotogravure printing and is an example of a high degree of VOC control.  The rotogravure press rooms are to be certified as permanent total enclosures and must at all times be vented to a solvent recovery system (SRS).  The SRS, which consists of a carbon adsorption system, steam stripping system and VOC condensation system, must continuously achieve a minimum of 98.25% VOC removal efficiency.  Additionally, the facility must demonstrate, based on records, an overall VOC control efficiency of at least 95% on a monthly basis and 96% on a 12-monthly basis. (Howard Lange, AQMD)

Discussion: A committee member asked that information on the VOC loading to the SRS be added.  AQMD agreed to try to obtain this information and, if successful, add it to the listing.  Another committee member asked whether the method used to certify permanent total enclosure was EPA Method 204.  AQMD responded that the methodology had been reviewed and found to be the same as Method 204.  Committee members asked what solvent(s) are involved in this process.  AQMD agreed to try to obtain this information and, if successful, add it to the listing. (Gary Rubenstein, Sierra Research; Stan Romelczyk, San Diego APCD; Bill Dennison, Dennison and Associates; Katy Wolf, IRTA; Howard Lange, AQMD)

 

New BACT Part B, Section III Listing

Lithographic Printing – Heatset and Non-Heatset, Anderson Lithographics (A/N 368224)

Anderson Lithographic is a large lithographic printing operation with both heat set and non-heatset (in this case IR-dry) presses.  The Heatset presses are in one room and the non-heatset presses are in another room.  Compliance with Rules 1130 (inks) and 1171 (cleaning solvents) is achieved for the most part by using compliant materials; however, Rule 1130 compliance on the heatset presses is by use of an after burner, which is required by Part D BACT.  VOC in the fountain solution is limited to 0.7 lb/gal, which probably complies with the Part D BACT requirement of 8% maximum VOC.  The afterburner in this case is required to achieve a minimum of 98% overall VOC control efficiency.  This degree of VOC control exceeds the BACT requirement of 95% and had been determined to be achieved in practice.

A unique requirement in this permit is that the press rooms are required to be permanent total enclosures and to be vented to a gas turbine whenever the gas turbine is in operation, and the gas turbine is required to achieve at least 92% VOC destruction efficiency.  Anderson Lithographic was a recipient of a 2003 AQMD Clean Air Award for this innovative control of fugitive VOC.  The gas turbine had been installed approximately ten years earlier as part of a cogeneration system.  By listing this in Section III, AQMD is not requiring control of fugitive emissions from lithographic printing, but is suggesting that it be considered in cases where an appropriate combustion device is available. (Howard Lange, AQMD)

Discussion: A committee member asked whether the afterburner was a regenerative thermal oxidizer.  AQMD responded that it is not but it does have a recuperator. (Bill Dennison, Dennison and Associates; Howard Lange, AQMD)

 

Other Business

AQMD stated that the meeting schedule for 2004 will be published on the AQMD web site soon and proposed that the meetings continue to be held on the fourth Thursday of each odd month (January, etc.) at 1:00 p.m.  The committee seemed to agree with this plan.  AQMD stated that the meetings next year will probably be held in room CC-2.

AQMD stated that the proposed changes to Parts C and D of the BACT Guidelines, which had been discussed at the September meeting, were to be presented to the Governing Board on December 5, 2003 and that the board package containing those proposed changes would be available at the meeting and on AQMD’s web site the day of the meeting.  AQMD also stated that semi-annual report on changes that have occurred in Part B was also to be presented to the Board at the same meeting.

There was no further discussion, and the meeting was closed.

AQMD Home Page
This page updated: February 18, 2004
URL: http://www.aqmd.gov/bact/Minutes11-20-2003.htm