REPORT:
Stationary Source Committee
SYNOPSIS:
The Stationary Source Committee met Friday, November 17, 2006.
Following is a summary of that meeting. The next meeting will be January
26, 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 10:30 a.m. Present were Committee Chair Dennis
Yates and Committee Member Jane Carney. Absent were Committee Members
Ronald Loveridge and Gary Ovitt.
INFORMATIONAL ITEMS
Committee Member Jane Carney left the meeting for agenda #1 due to a
possible conflict of interest. Ms. Carney announced that Inland Concrete
Enterprises, Inc., Delilah Properties and Maruhachi Ceramics of America,
Inc. are sources of income for her.
1. Status Report on Rule 1157 – Emissions Inventory
Dr. Laki Tisopulos, Assistant Deputy Executive Officer, Planning, Rule
Development, and Area Sources, gave the staff presentation. Rule 1157 was
adopted in January 2005. At the time of adoption, industry challenged the
assumptions and emission factors. Settlement of a subsequent lawsuit was
reached in September 2005. Staff held numerous meetings and substantial
progress was made. Even though there were a few remaining areas of
disagreement, concurrence on the revised emission inventory was reached on
October 17, 2006. Overall, the revised emissions inventory reflects a 50%
decrease from the adopted pre- and post-rule emission inventories. However,
the revised inventories are significantly higher than that of the 2003 AQMP
control measure (BCM-08). Staff will use the data and assumptions used in
the revised emissions inventory in the 2007 AQMP and all future evaluations
(e.g., CEQA, permitting, and annual emissions reporting). At its December
2006 meeting staff will seek Board ratification of the revised inventory
and, upon approval, send an open letter to the industry regarding the
revised inventory and future uses.
Mr. John Hecht of West Coast Environmental, on behalf of the California
Mining Association (CMA), expressed appreciation to staff and stated that
although CMA believes the inventory is overstated, they support the revised
inventory and will support ratification at the Governing Board meeting.
Mayor Yates commented that this process was a good example of how
beneficial such cooperative efforts can be, particularly in light of ongoing
pressures from the state and federal agencies on the upcoming AQMP.
2. Status Report on Public Notification Procedures
During Flare Events
Edwin Pupka, Senior Enforcement Manager, presented this item. On
February 13, 1998, Rule 1118 – Control of Emissions from Refinery Flares,
was adopted to establish monitoring, recording and reporting requirements of
data on petroleum refinery flaring events and related activities. Analysis
of the flare data collected October 1999 through December 2003, illustrated
emission reductions but also confirmed the need for enhanced emission
control. On November 4, 2005, Rule 1118 was amended to continue allowing
flares to operate as safety devices while minimizing emissions releases from
flaring events and to improve previous monitoring, recordkeeping and
reporting provisions. Further, Board Resolution No. 2005-32 formalized the
ongoing commitment of staff, working with industry, local communities, and
local government agencies, to recommend strategies for implementing
community notification requirements set forth in the amended rule. Staff
formed a Stakeholders Working Group and explored options for implementing
appropriate public notification procedures for flare events. Mr. Pupka
outlined the discussions to date and summarized on-going efforts. This
action will include: (1) issuance of an RFP, not to exceed $10,000, to
design a survey of representative South Bay communities as a basis for
developing a sub-regional community flare event notification system; (2)
development of a work plan to improve existing sub-regional notification
systems; (3) maintaining monitoring and sampling equipment at AQMD Long
Beach field office; (4) preparation of a final staff report of Working Group
findings, survey results and recommended sub-regional community notification
systems; (5) continuing to convene quarterly Working Group meetings; and,
(6) reporting milestones semi-annually to the Board.
Committee Chair Dennis Yates related city experience with surveys and
urged staff to consider engaging a professional to design and conduct an
effective survey. He suggested that the survey be conducted through other
means than a mailing. He expressed concern that most households that
receive such mail surveys typically discard them without ever reviewing the
enclosed materials and therefore never respond. Board member Jane Carney
inquired about existing community alert notification systems in the South
Bay area and questioned whether they are effective in providing pubic
information regarding refinery flaring events and releases. Carol Coy,
Deputy Executive Officer, Engineering & Compliance, explained that although
there are various individual and collective alert systems already in place
in the South Bay area that effectively provide notification to the
community, the Working Group and various Community Awareness Emergency
Response (CAER) subcommittees that have been recently formed are looking at
ways to develop consistency in the information provided and how the it is
disseminated sub-regionally across cross-jurisdictional boundaries.
3. Rule 1118 Pilot Projects Progress Report
Larry Bowen, Planning and Rules Manager gave a status report on the Rule
1118 continuous monitoring pilot programs required by the adopting
resolution. BP West Coast Products is conducting the total sulfur
monitoring pilot. Their unit was installed and began operating in April.
This is the first of it’s kind installation and AQMD staff has been working
with BP West Coast Products staff to complete the testing certification.
This was completed in October and testing of the unit will commence again in
February. If everything goes as planned the final monitor certification
will occur in April.
Chevron volunteered for a HHV analyzer pilot program and actually elected
to test two separate technologies, a calorimeter and a mass spectrometer in
parallel to see which was best for them. Their equipment is currently being
delivered and if everything goes as planned the certification should be
complete in March and testing will begin.
With the available manufacturers and delivery lead times, installation
and operation into the 23 affected flares by the current rule deadline of
July 1, 2007 is not expected to be met although the actual time to achieve
final compliance will vary by refinery. For this reason staff is
recommending a variance approach whereas WSPA is recommending a blanket rule
amendment. Staff will continue to work with the refineries on their
individual variance requests.
Miles Heller of BP West Coast Products spoke to express his appreciation
for the cooperative effort by staff on this project and would like it to
continue. He did want to emphasize their agreement with the staff
presentation that the deadlines could not be met and that since all
refineries will be ordering the equipment at the same time it will lengthen
the actual delivery schedules.
Ron Wilkniss of WSPA spoke to thank the Board for the opportunity to
first complete pilot projects before full installation. He also said that
in addition to monitor certification that it was his belief that at least
six month of operation was necessary before the conclusion of the pilot
program to also demonstrate the equipment can be maintained to operate
reliably. He also expressed that it was desirable to install the
calorimeters and sulfur analyzers concurrently rather than consecutively.
Board Member Carney wanted an explanation of the variance process and the
cost. Each refinery will have to file individually but then the entire
group will be bundled together for the hearing. The cost is about $1000 per
application.
Board Member Yates questioned why the variance recommendation instead of
a rule change. Staff responded that the overall cost is less, compliance
dates can be tailored to the needs of each individual refinery and any
required future changes in schedule are much less cumbersome than a rule
change.
Board Member Carney expressed concern that sufficient time should be
allowed to complete the pilot programs and study the results before
requiring that significant sums of money be spent for the installation for
all flares.
4. Rule 1173 – Atmospheric Pressure Relief Devices (PRD)
Update
Larry Bowen gave a status report on Rule 1173 as it applies to pressure
relief devices (PRDs). The rule requires monitoring of PRDs and reporting of
releases to the atmosphere from PRDs. If there are significant releases the
refinery is required to vent the PRD to a control device or opt to pay
mitigation fees that are used for air quality improvement projects in the
affected areas. Since implementation in 2003 there were three releases in
2003, two in 2004 and none in 2005 and 2006. Four releases resulted in the
payment of mitigation fees and one resulted in additional control. In
addition, some refineries have begun to voluntarily connect some PRDs to
vapor recovery control systems. Staff will continue to monitor and analyze
the releases and recommend a rule amendment in the future, if necessary.
One refinery has opted to use wireless continuous monitors for it’s
required PRD monitoring. This is an emerging technology that is very
promising. Staff will continue to investigate its potential applications,
work with the refineries and likely return with a proposed rule amendment
further requiring its use.
Ron Wilkniss of WSPA wanted to emphasize that although there were
initially some releases, the data presented shows very positive trends that
the number of releases are not only much fewer but that the emissions from
the releases were much less. This was a result of the diligence of the
refiners.
Board Member Carney questioned if the mitigation funds have been spent.
RFP’s have been released to spend the funds from one PRD release and the
process is underway to identify air quality improvement projects for the
other three.
5. Status Report on Draft 2007 AQMP
Dr. Laki Tisopulos, Assistant Deputy Executive Officer for Planning, Rule
Development and Area Sources gave a brief summary of the key public comments
received during the six public workshops held for the draft 2007 AQMP. The
public is generally supportive and appreciative for the hard work that went
into developing the plan and the control strategy. However, concern was
expressed relative to the availability of funding to support the
implementation of the proposed control strategy. Staff received comments
advocating better enforcement of the smog check, vehicle idling and other
mobile source regulations since they are critical to reducing emissions from
these sources. Representatives of the Building Industry Association and
realtor interests expressed their concern regarding the control measure that
seeks to mitigate the emission impact of development projects. While they
are not objecting the use of the CEQA process as a means of mitigating
emissions, they are opposed to the mitigation fee option included in the
control measure. Staff received comments in support of stricter controls to
reduce emissions from wood burning fireplaces, stoves and fireworks. The
public commented in support of the ultra-fine particles discussion in the
draft AQMP and the global warming gas control measure and recommended staff
to set more aggressive goals and prioritization of the control measures
based on their global warming gas reduction potential. While some
participants commented on the stringency of the control measure for the
space heaters, another individual commented on the need for solar powered
technologies to reduce criteria and global warming gas emissions. A concern
was expressed relative to the use of pesticides at schools and AQMD was
asked to take a more aggressive role in regulating these substances rather
than relying on other governmental organizations.
Mayor Yates reiterated his concern he expressed in previous meetings
regarding the additional emission reduction commitments being made for
stationary sources while the bulk of the air pollution originates is caused
by mobile sources.
Staff will continue providing the Stationary Source Committee with its
regular updates on the draft AQMP.
WRITTEN REPORTS
All written reports were acknowledged by the Committee.
PUBLIC COMMENTS
There were no public comments at this meeting.
The meeting was adjourned at 11:55 a.m.
Attachment(s)
(DOC 56kb)
November 17, 2006 Committee Agenda (without its attachments)
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