MEETING HIGHLIGHTS

	SRC Members
Greg Adams			Deanna Haines (represented by Steve Simons)
Martin Ledwitz			Karl Lany (not present)
Russell Greenhouse			Stan Romelczyk (by phone)
Gary Rubenstein			Hal Taback (not present)
Ted Guth (not present)			Bill Dennison
Katy Wolf			Nahid Zouestaigh (by phone)
Philip Hodgetts (not present)				Ron Joseph (not present)
Grant Chin (by phone)			Ron Wilkniss (not present)
Anoosheh Mostafaei (represented by John von Barzen)
		Attendees
John Clarke			Vance Markland
Masa Hirose			John Billheimer
Andy Wales			Damon Erickson
Todd Paxman			Brian Dominici
Hafizur Chowdhury (at CARB)			Stephanie Kato (at CARB)
David Hatfield (at CARB)
	AQMD Staff
Marty Kay			Howard Lange
Al 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 26th Meeting

¾    Responses to Comments from September 26th Meeting

¾    New and Updated BACT - Part B Listings

¾    Other Business

 

Minutes of the September 26thMeeting

Dryer or Oven – Aramark Uniform Services (A/N 391633)

A committee member asked why the Aramark laundry dryer, relative to the Part D BACT Guidelines, was considered to be in the “Other Dryers and Ovens” category rather than in the “Rotary Dryer” category, for which pre-existing BACT is less stringent.  AQMD responded that the “Rotary Dryer” category consists of large industrial rotary dryers, and a laundry dryer does not belong in that category.  The same committee member commented that this listing was not supported by a source test and had operated, on average, at only 30% of its capacity and thus did not seem to meet all achieved-in-practice criteria.  AQMD responded that this listing is an example of a BACT determination based on pre-existing BACT and is not establishing new BACT and it therefore does not need to meet the achieved-in-practice criteria. (Steve Simons, SEMPRA Utilities; Marty Kay, AQMD)

Gas Turbine – Silicon Valley Power (BAAQMD A/N 18547)

A committee member commented that the minutes may have been incorrect in stating that the only commercial availability of the Xonon technology is as embodied in the Kawasaki M1A-13X gas turbine.  This committee member had information that Catalytica Energy Systems had entered into an agreement with General Electric to market a similar product.  Other committee members and an audience member responded that. although Catalytica Energy Systems and General Electric are in the process of developing a new gas turbine product employing the Xonon technology, that product is not yet on the market. (Greg Adams, Los Angeles County Sanitation Districts; Gary Rubenstein, Sierra Research; Bill Dennison, Dennison & Associates; David Hatfield, Catalytica Energy Systems)

 

Responses to Comments from the September 26th Meeting

Dryer or Oven – Aramark Uniform Services (A/N 391633)

AQMD reported that information regarding violations not related to the laundry dryer had been removed from the listing as had been agreed at the September 26^th meeting.  (Howard Lange, AQMD).

 

Dryer or Oven – BMCA Insulation (A/N 322398)

A committee member had asked at the last meeting whether the emission limit achieved on the BMCA oven had been guaranteed by the burner manufacturer.  AQMD had resolved this question into two parts: (1) Is an emission guarantee required to establish achieved-in-practice BACT and (2) What, if any, emission limit was guaranteed in the BMCA oven case.  On the broader question of whether an emission guarantee is a requirement for a technology to be deemed achieved in practice, AQMD found that it is not.  Based on a review of Part C of the BACT Guidelines and consultation with AQMD’s counsel, it was AQMD’s conclusion that while a commercial warranty or guarantee is required, it need not be an emission guarantee.  Regarding the second question, AQMD found that in this case a 10 ppm (uncorrected) NOx guarantee was provided by the burner manufacturer. (Howard Lange, AQMD)

Several committee members were of the opinion that new BACT should be based on the manufacturer guarantee rather than on what is actually shown to be achieved in practice.  Committee members were concerned that future applicants would not be able to obtain guarantees to support emission levels required as BACT.  AQMD responded that it would be up to the permit engineer to make allowances for this situation should it occur in the future.  One committee member pointed out that for some types of equipment it is useful for BACT to be consistent with commonly available emission guarantees so that source testing will not be required (e.g., small standby generators). (Bill Dennison, Dennison & Associates; Gary Rubenstein, Sierra Research; Marty Kay, AQMD; Russell Greenhouse, Fluid Ink)

Two committee members commented that it was their recollection that SB456 requires that new BACT be supported by emission guarantees.  AQMD pointed out that while the requirements of SB456 must be met when minor source BACT is being made more stringent, it does not apply when new major source BACT is being established.  Nonetheless, both AQMD and the committee members planned to research SB456 on this issue and report back at the next meeting. (Greg Adams, Los Angeles County Sanitation Districts; Martin Ledwitz, Southern California Edison Company; Marty Kay, AQMD)

A committee member pointed out that the source test on the BMCA oven was performed at oven temperatures far below the oven’s “normal” operating temperatures that were specified in the listing.  AQMD responded that the applicant’s consultant had been questioned on this and it had been found that the “normal” operating temperatures specified for the three oven zones were actually maximum permissible operating temperatures and the normal operating temperatures were indeed much lower.  AQMD’s recollection was that the source test did represent the range of temperatures over which the oven was normally used, but AQMD agreed to check into this and report back at the next meeting.  Another committee member suggested that the oven may have been derated.  However, a third committee member pointed out that an oven is typically rated well above its normal operating heat input to allow for a higher firing rate for heating up to operating temperature. (Steve Simons, SEMPRA Utilities; Howard Lange, AQMD; Gary Rubenstein, Sierra Research; Bill Dennison, Dennison & Associates)

A committee member suggested that, in that the emission limit in this listing was not supported by a guarantee, a comment be added to the listing to clarify that the new BACT is use of a low-NOx burner and not the emission limit achieved in this case, i.e., this emission limit may not be achievable on all ovens in this category.  AQMD agreed that this would be an appropriate addition to the listing. (Gary Rubenstein, Sierra Research; Marty Kay, AQMD)

Boiler – Y2K Textiles (A/N 362616)

At the last meeting, an audience member had questioned information in this listing that the boiler is being used in an on/off mode.  This information had been provided by the plant engineer.  However, upon discussing this with the boiler supplier, it had been determined that the boiler is being used in a modulating mode.  Therefore, the listing was corrected in this regard.  A committee member asked whether the boiler source test included a low-load test.  AQMD responded that the boiler had been tested at nominally low, medium and high loads but the low-load heat input rate was actually no lower than the medium-load heat input rate.  The committee member pointed out that, although the listing is at present in Section III, the lack of a low-load test would be an impediment to its being moved to Section I.  The committee member also noted the lack of an emission guarantee.  AQMD responded that, as discussed in regard to the BMCA oven listing (above), an emission guarantee is not required to establish new Part B BACT. (Steve Simons, SEMPRA Utilities; Howard Lange, AQMD; Marty Kay, AQMD)

 

New BACT Part B, Section I Listings

Abrasive Blasting Room – Rohr, Inc. (A/N 391420)

This is a new abrasive blasting room installed in an aircraft parts manufacturing facility.  The abrasive blasting operation is done manually to remove residual adhesive material.  The abrasive medium is cornstarch particles suspended in a high-velocity air stream.  After contact with the part being finished, the particles fall through a floor grate and are air-veyed to a cyclone separator for recovery.  The cyclone exhaust passes through a cartridge filter before being vented to the atmosphere.  This satisfies the Part D BACT Guideline for an abrasive blasting room, which is a “baghouse or cartridge filter”.  A cartridge filter rated at 99.999% removal of 0.5 micron particles is used.  The listing includes a comment stating that the new Part B BACT being established in this listing is use of a cartridge filter rated at 99.999% removal for 0.5 micron particles and is not necessarily the achievement of that removal efficiency.  This distinction is intended to avoid triggering a source test requirement. (Howard Lange, AQMD)

Discussion:  A committee member asked why a source test was not required.  AQMD responded that the rating of this filter at 99.999% removal for 0.5 microns is supported by a substantial amount of statistical product testing both in house and by an independent testing laboratory.  AQMD further responded that it is common practice not to require a source test on a particulate removal device since the main concern with these devices is failure of the filter medium, which usually can be readily detected by visual observation. (Greg Adams, Los Angeles County Sanitation Districts; Howard Lange, AQMD; Marty Kay, AQMD)

Brake Pad Grinder – Covina Brake Bonding (A/N 391524)

This facility installs new brake pads on used brake shoes.  One step in the process involves grinding of the brake pads to shape.  This facility has three brake pad grinders located in one room.  Each grinder is separately vented to a common air filtration system.  The facility requested modifications to its permits for these three brake pad grinders to increase the maximum production rate for the three grinders from 2200 shoes/pads per day to 8000 shoes/pads per day.  To satisfy TBACT, the facility was required to replace the filtration system with a new system consisting of a cartridge filter rated at 99.999% removal efficiency for 0.5 micron particles followed by a HEPA filter rated at 99.97% removal efficiency for 0.3 micron particles.  This TBACT specification was based on reducing the cancer risk due to asbestos emissions from the facility to 10 in a million.  The listing includes a comment stating that the new Part B BACT being established in this listing is use of a cartridge filter rated at 99.999% removal efficiency for 0.5 micron particles followed by a HEPA filter rated at 99.97% removal efficiency for 0.3 micron particles and is not necessarily the achievement of those removal efficiencies.  This distinction is intended to avoid triggering a source test requirement.  It was noted that the listing contained an apparent error in item 2D, the total air flow rate to the filtration system, and AQMD was to investigate this and correct the listing. (Howard Lange, AQMD; Marty Kay, AQMD)

Discussion:  Two committee members asked why there is no minimum collection efficiency required in this case.  AQMD responded that the grinders themselves may satisfy the EPA (Method 204) criteria to qualify as permanent total enclosures  in that each one is fully enclosed in a shroud with a small opening at the grinding surface that is subject to a minimum (Industrial Ventilation Manual) suction velocity.  AQMD was to investigate the matter and report back at the next meeting. (Katy Wolf, IRTA; Russell Greenhouse, Fluid Ink; Howard Lange, AQMD; Marty Kay, AQMD)

Boiler – Cosmetic Laboratories (A/N 385770)

This was a new boiler installation in September 2001.  This boiler, which is rated at 21.46 MMBtu/hr input, is used for process steam in a cosmetics manufacturing process and is required to follow substantial variations in steam demand.  To satisfy Part D BACT requirements (9 ppm NOx and 100 ppm CO, both dry, corrected to 3% O2), a Clayton boiler equipped with a Clayton ultra low-NOx burner was selected.  This was a first-of-a-kind burner for Clayton, and was supplied with no emissions guarantee.  The boiler has operated well since its startup in April 2002 and passed a source test, which was performed shortly after startup.  An unannounced emissions test performed by AQMD in June, using a portable analyzer, found the emissions to be 10 ppm NOx and 2 ppm CO, both dry, corrected to 3% O2.  Clayton offers this boiler in sizes from 400 to 600 hp (approximately 17 to 25 MMBtu/hr input) and now guarantees it to meet AQMD BACT Part D emission requirements. (Howard Lange, AQMD)

Discussion:  A committee member asked why the CO limit in this permit (100 ppm) is so high.  AQMD responded that this limit was apparently based on Part D BACT for boilers.  While it is probably technically feasible to achieve lower CO limits on boilers, AQMD has not moved in that direction because the district is in compliance with CO air quality standards and lowering CO limits makes it more difficult to tune boilers for lower NOx. (Martin Ledwitz, Southern California Edison Company; Marty Kay, AQMD)

A committee member suggested deleting the information that Clayton uses a different type of ultra low-NOx burner in its smaller boilers, and AQMD agreed to do so. (Steve Simons, SEMPRA Utilities; Marty Kay, AQMD)

An audience member requested that more information about the warranty be added to the listing, and AQMD agreed to do so. (Audience Member; Marty Kay, AQMD)

A committee member pointed out that the Permit to Operate date preceded the date of the source test.  AQMD was to look into this and report back at the next meeting. (Greg Adams, Los Angeles County Sanitation Districts; Howard Lange, AQMD)

An audience member asked why the unannounced source test showing 10 ppm NOx was not considered to be out of compliance.  AQMD responded that its Enforcement group apparently felt that the accuracy of the test methodology did not provide sufficient basis for a citation, and suggested that the individual take this matter up with that group.  A committee member pointed out that AQMD generally allows a 1 ppm tolerance before taking enforcement action. (Audience Member; Marty Kay, AQMD; Gary Rubenstein, Sierra Research)

Heater-Other Process – Nelco Products (A/N 371784)

This horizontal coil type process heater was a new installation in February 2001 and was listed in Section III at the time that the Permit to Construct was granted.  The heater had since been source tested and found to be in compliance with its permit limits, and the listing was therefore being upgraded to Section I.  In addition to adding the source test results, the plant contact and operating history of the heater were being updated.  Also, more information was being added about the burner and the emission guarantee.  A comment was being added stating that the equipment supplier, American Hydrotherm, had gone out of business but that virtually the same product is expected to be available from American Heater Co. (Howard Lange, AQMD)

 

Updated BACT Part B, Section I Listings

Heater-Other Process – Southern California Gas Co. (A/N 347641)

This listing represents one of three identical horizontal coil type process heaters installed in 1999.  The emission limits in the permit represent a BACT determination based on the Part D BACT guideline for process heaters, and the original listing was therefore a Section I listing even though at that time a source test had yet to be done.  Since that time, a source test had been performed, and the listing was being updated with the source test results.  In addition to adding the source test results, the plant contact information and the operating history of the heaters since their startup in August 1999 were also being updated. (Howard Lange, AQMD)

Discussion:  A committee member pointed out that there were significant differences in the operating conditions (O2 and FGR) at which the three heaters were source tested, and questioned how the operating conditions of identical heaters could be so different with the same emission results.  AQMD agreed to investigate the reasons for these differences. (Gary Rubenstein, Sierra Research; Marty Kay, AQMD)

Aluminum Melting Furnace – Custom Alloy Sales (A/N 385864)

and

Aluminum Melting Furnace – Superior Industries (A/N 368982)

These listings, both of which represent the use of low-NOx burners to establish RECLAIM concentration limits, had been discussed at the last meeting, and some clarifications were agreed upon at that time.  SEMPRA Utilities still had concerns, so AQMD held separate discussions with members of that organization to address their concerns.  As a result, the listings have been revised to clarify that the new BACT for aluminum melting furnaces established by these listings is in each case the low-NOx burner and is not the specific concentration limit.  The listings suggest that in future permitting of this source category the initial emission limits, at the Permit to Construct stage, be based on Part D BACT or the emission guarantee, whichever is lower, and the final emission limit, in the Permit to Operate, be based on source test results.

In addition, the facility contact information was updated in both listings, it was noted that the Custom Alloy furnaces do not have recuperators, and information was added about the warranty provided in each case. (Marty Kay, AQMD; Howard Lange, AQMD)

Discussion:  Two committee members asked what the future policy will be with regard to warranties and guarantees.  AQMD responded that in establishing new major source (Part B) BACT based on meeting the achieved-in-practice criteria, information must be included to show that there is a manufacturer’s warranty or guarantee, but not necessarily an emission guarantee.  AQMD was to determine what warranty/guarantee criterion must be met in establishing new, more stringent minor source (Part D) BACT and report back at the next meeting.  The committee members requested that in future listings the warranty information specify whether it is an equipment or an emission warranty or guarantee.  AQMD agreed to do so.  The committee members also requested that a representative from AQMD’s legal counsel’s office be present at the next meeting to discuss this issue further.  AQMD agreed to place this on the agenda for the next meeting. (Russell Greenhouse, Fluid Ink; Gary Rubenstein, Sierra Research; Marty Kay, AQMD)

 

Other Business

The next meeting was scheduled for January 23, 2003 at 1:00 p.m. in AQMD conference room GB.

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

 

 Attachments