RECLAIM Seminar October 26, 2005 Judy B. Yorke, P.E., C.P.P.

Yorke Engineering, LLC 949-248-8490 x25 [email protected]

Outline  Managing Your Permit and Emissions  Planning for Growth

Managing Your Permit  Understand your permit requirements  Watch out for compliance issues  Look for opportunities to improve your permit terms

Always Keep the Future in Mind  Look out over the next 5 years  Manufacturing changes  New product lines  New equipment  Permit constraints and possibilities

Keep Your Permit Clean  Don’t be limited by unnecessary conditions  Understand the origin of each requirement, limit, and emission factor

Review Your Permit Conditions Is the condition or limit based on a specific identifiable regulatory requirement?

Is the condition specific, clear, and can compliance be demonstrated?

General Guidelines Does any other condition determine compliance with the same regulatory requirement?

Is there a simpler or otherwise preferable way to assure compliance with the same regulatory requirement?

Obsolete Permit Conditions  Remove Conditions That are No Longer Applicable  For Example: – Start-up Source Test – Initial Installation Conditions – Start-up Notification

Broad Permit Conditions  Ensure that Requirements are Properly Specified.

 Avoid Broadly Stated Requirements, e.g.: – “Facility shall not exceed 50lbs/day NOx”

Overlapping Requirements  Avoid requirements that may overlap.

 For Example: “This equipment is subject to the following rules… for CO… Rule 1110.1 and 1110.2”

Redundant Requirements  Avoid Requirements that are Redundant.

 For Example: A boiler subject to RECLAIM and Rule 1146 NOx Limits.

Mistakes  Check Carefully for any Mistakes: – Equipment Rating, – Equipment Description, – Equipment Dimensions, – Primary and Back-up Fuel, – Raw Materials, – Operating limits, – etc.

Duplicate or Missing Permits  Ensure that each permit unit is listed  Ensure that permit units are not listed more than once

Consistency  Ensure that Specifications on Identical Units are Consistent  Ensure that Conditions on Identical Units are Consistent

NSR Requirements  Conditions from NSR may be applicable, e.g.: “This equipment shall not be operated when I.C.E. D14 is operating.”  Each of these conditions should be verified and appropriate  Compliance should be demonstratable

Monitoring  Ensure that an appropriate method is specified  Ensure that the Requirements are clearly identified and understood

Emission Limits   Beware of using source test data to establish an emission limit!

 Ensure that emission limits are from an applicable requirement Know the difference between an emission factor and a concentration limit

Strategies for Growth  Rule 2012 Concentration Limit  Reduce or Control Emissions  Buy Credits

Rule 2012 Opportunities  Large Sources and Now Process Units may Elect a Concentration Limit   A Realistic Concentration Limit can Lower RECLAIM Emission Calculations …But Choose Wisely, Equipment Emissions Must Always Comply with the Limit

Rule 2012 Opportunities (Cont.)  A Concentration Limit Replaces the RECLAIM Emission Factor Specified in Your Permit for a Given Device  After Approved, This Lower Value will be Used to Quantify the Emissions for That Source

Rule 2012 Opportunities (Cont.)  Select Wisely, e.g., Use Source Test Data and Manufacturer’s Guarantee  To Change Your Permit: – File a Permit Application for a Change of Condition - Requesting the Concentration Limit – Pay the Administrative Modification fee

Rule 2012 Opportunities (Cont.)  A Meter may be Necessary to Separate the Fuel Use for Reporting  After Changing Your Permit, Be Prepared to Complete the Required Source Tests: – Every 3 Years for Large Sources – Every 5 Years for Process Units

For Example…

Equipment Type Current Emission Factor (lb/mmcf) 130 130 213 Possible Concentration Limit* (lb/mmcf) 70 35 170

Control Emissions – Technology Options  Retrofit existing equipment* – Low-NOx burner – SCR – Emerging technology  Replace old inefficient equipment and install BACT *Retrofitting does not require BACT!

(As long as emissions are not increased…)

Estimating Cost Effectiveness  Is it cheaper to buy credits or control emissions?

 Analyze capital, installation, maintenance, and other costs vs. cost of RTCs!

– Prepare an initial estimate – Obtain vendor proposals – Apply for a modification

Retrofit Regulatory Requirements    Prior to Modification, Obtain a Permit to Construct To Obtain a PTC, File an Application Typical SCAQMD Fees Range from $300-$4000  We can Assist You using PermitWorks …Just Ask Your Account Executive

Retrofit Regulatory Requirements (Cont.)  Any Change Must Also Consider Non-RECLAIM Pollutants  A Modification Must Comply with Existing Rules, e.g.,: – Rule 1110.2 for IC Engines – Rule 1146.1 & 1146.2 for Boilers and Process Heaters

Retrofit Regulatory Requirements (Cont.)  If There is Any Increase in Emissions, Rating, or Throughput; New Source Review is Triggered  NSR Requires Best Available Control Technology, Modeling, and Offsets

Strategy Conclusions      Plan Ahead Get permit assistance Ask vendors for references Get a guarantee of emissions Get a Permit to Construct before purchasing equipment

Resources for Help   Talk to Your AE – For a Rule 2012, Concentration Limit Review – For Permitting Assistance – For Equipment Information Call The Gas Company’s Air Quality AnswerLine with any combustion related air quality question!

=> 1-562-803-7428