Purpose Discuss third party review and findings for SCAQMDs Draft - - PDF document

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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

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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

• f 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

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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

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Technology Assessment and Review Timeline

Draft Technology Assessment Released for Public Review RFP Released For Independent Review of Draft Technology Assessment Draft Technology Assessment Received at Governing Board Meeting ETS Selected by Proposal Review Panel Including SCAQMD, VCAPCD, Furnace Dynamics & S.C. Small Business Alliance ETS Begins Review of Draft Technology Assessment ETS Meets with Stakeholders at Rule 1147 Task Force Meeting ETS Completes Review of Draft Technology Assessment and Stakeholders Comments Rule 1147 Task Force Meeting to Discuss ETS Findings and Suggestions Jan 29, 2016 Feb 5, 2016 Mar 4, 2016 May 31, 2016 June 29, 2016 Aug 3, 2016 Oct 26, 2016 Nov 8, 2016

ETS Review of Draft Technology Assessment

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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

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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 3rd 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 3rd 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

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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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ETS Review of Comments

(Continued)



Some Low NOx Burners Have Limited Turndown and are Less Efficient

 The burner cited by the commenter is the one of the most used burners  The comments on efficiency are not supported by enough information to evaluate

the comment



Information on Units with Large Burners or With Emissions Exceeding 1 Pound/Day

 Large units are outside the scope of the Technology Assessment Review 

Information Provided on Retrofits at Facilities

 Information on some of the units were incomplete or did not have sufficient detail

to evaluate emissions or cost of burner replacement

 When sufficient information was available to evaluate the emissions and cost, the

cost effectiveness was in the range used in the Technology Assessment



Comments on Previous Rule Development

 Comments on rule development for 2008 and 2011 are noted

ETS Review of Comments

(Continued)

 Heated Tanks and Spray Washers Cannot

Meet the Rule Limit of 60 ppm and Should be Exempt or Have an Emission Limit of 100 ppm

 The Technology Assessment has proposed to

exempt existing units from the retrofit requirement

 Technology is available for new units to comply

with the rule limit

 Some of the comments and information provided

were confusing or contradictory

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Summary of ETS Technology Review



Availability of Technology to Achieve Rule Emission Limits

 Low Temperature Processes – Technology is Available Except for Burners Rated

Less Than 400,000 Btu/hour

 High Temperature Processes – Technology is Available for All Sizes of Burners  Heated Spray Booths – Technology is Available for Small and Large Booths 

Agree with Staff Proposal to Amend Rule to Address the Following Technical Concerns:

 The smallest low NOx burners available for low temperature processes 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 preferred burners



Additional recommendation to that of staff’s:

 Recommend to Change NOx Emission Limit for Afterburner Processes

Operating at Temperatures Less Than 800° F to 60 ppm (Staff Agrees)

Summary of ETS Cost and Cost Effectiveness Review

 Agree with Cost Effectiveness Method Used by SCAQMD Staff  Consistent with EPA Method Used by Other Agencies  Consistent with Method Used for Rule Development and Other

District Programs

 Costs Used for Analysis are Representative of Costs for

Equipment and Installation of Burner Systems

 Agree with Staff Proposal to Amend Rule to Address the

Following Concerns

 Replacing Heating Systems on Existing in-use Spray Booths May

Result in a Cost Effectiveness Higher Than SCAQMD Criteria Used in Other Programs

 Retrofitting Units With Daily Emissions of Less Than 1 pound/day

May Result in a Cost Effectiveness Higher Than SCAQMD Criteria Used in Other Programs

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Future Activities and Schedule

 Present ETS Findings to SSC November

18th

 Revise Draft Technology Assessment for

December 2nd Board Meeting

 Initiate Rule Development – December 2016  Continue Task Force Meetings  Rule Amendment – 2nd Quarter 2017

Rule 1147 Contact

Wayne Barcikowski

wbarcikowski@aqmd.gov 909-396-3077 SCAQMD 21865 Copley Dr. Diamond Bar, CA 91765