RULE 1147 TASK FORCE MEETING November 8, 2016
Purpose Discuss third party review and findings for SCAQMD’s Draft Rule 1147 Technology Assessment For Small and Low Emission Sources Provide Preliminary Schedule for Future Rule Development Activity
Technology Assessment Commitments September 2010 Rule Amendment Includes a Requirement to Perform a Technology Assessment for Small and Low Emission Sources (< 1 pound/day NOx) EO Commitment to 3rd Party Review of SCAQMD’s Technology Assessment
SCAQMD Technology Assessment Findings Technical Feasibility The smallest low NOx burners available for low temperature sources are 400,000 to 500,000 Btu/hour Retrofitting heated process tanks that do not comply with the NOx limit requires replacement of the whole system A 30 ppm emission limit for the primary chamber of multi-chamber incinerators, burn-off ovens, burn-out furnaces and incinerators is not possible with the available burners Cost Effectiveness Replacing heating systems on existing in-use spray booths to meet the NOx emission limit may result in a cost effectiveness higher than SCAQMD criteria used in other programs (e.g., minor source BACT criteria of $27,000/ton) Retrofitting units with daily emissions of 1 pound/day or less to meet the NOx limit may result in a cost effectiveness higher than SCAQMD criteria used in other programs
Recommendations from Technology Assessment 1. Exempt sources with total rated heat input less than 325,000 Btu per hour from the Rule 1147 NOx emission limit. 2. Change the NOx emission limit from 30 ppm to 60 ppm NOx for the primary chamber for all burn-off ovens, burnout furnaces and incinerators. 3. Delay compliance for existing in-use heated process tanks, evaporators and parts washers from the NOx emission limit until the combustion system or tank is modified, replaced or relocated. 4. Delay compliance with the NOx emission limit for existing in-use spray booths until the heating system is modified or replaced or the unit is relocated. 5. Delay compliance with the NOx emission limit for existing in-use units with actual NOx emissions of one pound per day or less until the combustion system is modified or replaced or the unit is relocated.
Impact of SCAQMD Technology Assessment Findings on Affected Units Will Delay Compliance for up to 4,900 Small & Low Emission Units: Approximately 3,400 units are spray booths and paint prep-stations used in manufacturing and auto body repair Approximately 1,500 units are small ovens and dryers, furnaces, kilns and VOC/PM emission control equipment such as afterburners The Remaining Units Include: Approximately 750 units from about 20 - 50 years old which were required to demonstrate compliance with NOx emission limits by 2015 Approximately 750 units with compliant burners permitted since 2000 which must demonstrate compliance over the next 15 years (~ 50/year) Many units have demonstrated compliance because permit required testing Remaining units will require testing to demonstrate compliance with NOx limits
Technology Assessment and Review Timeline Draft Draft Technology ETS Completes Technology Assessment ETS Begins Review of Draft Assessment Received at Review of Technology Released for Governing Draft Assessment and Public Board Technology Stakeholders Review Meeting Assessment Comments Jan 29, Feb 5, Mar 4, May 31, June 29, Aug 3, Oct 26, Nov 8, 2016 2016 2016 2016 2016 2016 2016 2016 RFP ETS Selected by ETS Meets Rule 1147 Released For Proposal Review with Task Force Independent Panel Including Stakeholders Meeting to Review of SCAQMD, at Rule 1147 Discuss ETS Draft VCAPCD, Furnace Task Force Findings and Technology Dynamics & S.C. Meeting Suggestions Assessment Small Business Alliance
ETS Review of Draft Technology Assessment
Elements Reviewed by ETS SCAQMD Draft Technology Assessment: Availability of Technology for Low Temperature Operations Including Ovens and Dryers Availability of Technology for High Temperature Operations Including Furnaces, Kilns and Afterburners Availability of Technology for Individual Categories of Equipment Including Heated Spray Booths Cost Effectiveness Methodology Cost Effectiveness Analysis for Small and Low Emission Sources SCAQMD Recommendations Comments Received at August 3, 2016 Task Force Meeting Comments Received after August 3, 2016 Task Force Meeting
Information Sources Used in Review ETS Reviewed Information From the Following Sources: EPA Documents on Emissions, Technology and Assessing Cost Burner Manufacturers SCAQMD Permits Source Test Results Submitted to SCAQMD for Rule 1147 and Other Programs (summarized in the Draft Technology Assessment) Discussion at August 3, 2016 Rule 1147 Task Force Meeting with Stakeholders and SCAQMD Staff Oral and Written Information Provided to ETS by 1 Stakeholder at the Conclusion of August Task Force Meeting Oral and Written Information Provided to ETS by 3 Stakeholders during August through October 2016
Comments Received From Stakeholders Topics Discussed During and After the August 3, 2016 Task Force Meeting Rule enforcement, change of ownership, and potential future rule amendment General comment on applicability of potential to emit (PTE) used for New Source Review Comments specific to heated tanks and spray washers 4 Written Items at the August 3 rd Task Force Meeting from Anthony Endres of FDI 1 discussion of PTE versus of emissions based on operation and 2 examples using smokehouse oven and afterburner previously discussed in Draft Technology Assessment 1 item to SCAQMD dated 2/18/16 on Draft Technology Assessment with questions and comments on rule compliance, PTE, cost effectiveness calculations, and burner types 11 Written Items Received After the August 3 rd Task Force Meeting 4 Items received from Anthony Endres of FDI about several retrofits at 1 company, PTE and cost effectiveness and 1 item suggesting BACT and emission limits for furnaces should be individual determinations because each furnace is unique 5 Items received from Jim Waggoner of Industrial Process Equipment on heated tanks, other immersion tube heating applications and burners 1 Item received from Allan Roughton of Wirth Gas Equipment on heated tanks, spray washers and immersion tube heating application burners
ETS Review of Comments Received Rule Compliance and Issues Outside the Scope of the Technology Assessment Review are Identified and Summarized Information Supporting the Recommendations of the Technology Assessment are Identified and Summarized Use of Potential to Emit (PTE) for Estimating Emissions, Reductions and Cost Effectiveness The Technology Assessment does not use PTE The Technology Assessment uses estimates of average or ranges of emissions and reductions for the sources evaluated Average and ranges of emissions are appropriate and necessary for estimating emission reductions for agency rule development
ETS Review of Comments (Continued) The Technology Assessment Should Evaluate the Cost to Retrofit Existing Equipment The Technology Assessment analyzes the cost and cost effectiveness of retrofitting existing units The Technology Assessment Should be Consistent With SCAQMD BACT Guidelines The Technology Assessment is consistent with SCAQMD BACT Guidelines but Includes equipment useful life in the analysis Compliance and Maintenance Costs Should be Included In the Cost Effectiveness It is appropriate to exclude Rule Compliance costs in equipment cost effectiveness analysis. This is consistent with the SCAQMD BACT Guidelines. There is insufficient documentation of the maintenance costs proposed by the commenter i.e., Burner can replacements may be due to a variety of issues including selection of a can that is not appropriate for the unit or use of a constant pilot
ETS Review of Comments (Continued) Examples of Cost Effectiveness Calculations for a Smokehouse and Afterburner These specific examples were evaluated and addressed in the Technology Assessment The Technology Assessment recommendations would exempt those units from retrofit An Individual Cost Effectiveness Should be Calculated for Each Unit and a Cost Effectiveness Value That Should Not be Exceeded This comment concerns SCAQMD policy and not specific to the review, however: The SCAQMD has used a range of cost effectiveness criteria in its programs The Technology Assessment uses average and ranges of emissions The Technology Assessment uses the high end of the range of costs The Technology Assessment uses a screening criteria of $27,000 per ton consistent with SCAQMD BACT The SCAQMD Should Use a Cost Effectiveness Criteria of $30,000 per ton The SCAQMD used a screening criteria of $27,000 per ton
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