RECLAIM Seminar October 26, 2005

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RECLAIM SeminarOctober 26, 2005

• Judy B. Yorke, P.E., C.P.P.
• Yorke Engineering, LLC
• 949-248-8490 x25
• JYorke_at_YorkeEngr.com

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Outline

• Managing Your Permit and Emissions
• Planning for Growth

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Managing Your Permit

• Understand your permit requirements
• Watch out for compliance issues
• Look for opportunities to improve your permit
  terms

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Always Keep the Future in Mind

• Look out over the next 5 years
• Manufacturing changes
• New product lines
• New equipment
• Permit constraints and possibilities

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Keep Your Permit Clean

• Dont be limited by unnecessary conditions
• Understand the origin of each requirement, limit,
  and emission factor

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Review Your Permit Conditions
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General Guidelines
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Obsolete Permit Conditions

• Remove Conditions That are No Longer Applicable
• For Example
• Start-up Source Test
• Initial Installation Conditions
• Start-up Notification

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Broad Permit Conditions

• Ensure that Requirements are Properly Specified.
• Avoid Broadly Stated Requirements, e.g.
• Facility shall not exceed 50lbs/day NOx

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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

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Redundant Requirements

• Avoid Requirements that are Redundant.
• For Example
• A boiler subject to RECLAIM and Rule 1146 NOx
  Limits.

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Mistakes

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

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Duplicate or Missing Permits

• Ensure that each permit unit is listed
• Ensure that permit units are not listed more than
  once

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Consistency

• Ensure that Specifications on Identical Units are
  Consistent
• Ensure that Conditions on Identical Units are
  Consistent

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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

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Monitoring

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

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Emission Limits

• Ensure that emission limits are from an
  applicable requirement
• Beware of using source test data to establish an
  emission limit!
• Know the difference between an emission factor
  and a concentration limit

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Strategies for Growth

• Rule 2012 Concentration Limit
• Reduce or Control Emissions
• Buy Credits

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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

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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

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Rule 2012 Opportunities (Cont.)

• Select Wisely, e.g., Use Source Test Data and
  Manufacturers Guarantee
• To Change Your Permit
• File a Permit Application for a Change of
  Condition - Requesting the Concentration Limit
• Pay the Administrative Modification fee

Form 400A
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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

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For Example
Equipment Type Current Emission Factor (lb/mmcf) Possible Concentration Limit (lb/mmcf)
Curing and Drying Oven 130 70
Boiler 130 35
Forging Furnace 213 170
Melting Furnace 130 65
Concentration Limits are specified on permit in
ppm
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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)
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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

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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

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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

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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

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Strategy Conclusions

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

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Resources for Help

• Talk to Your AE
• For a Rule 2012, Concentration Limit Review
• For Permitting Assistance
• For Equipment Information
• Call The Gas Companys Air Quality AnswerLine
  with any combustion related air quality question!
• gt 1-562-803-7428