RECLAIM SeminarRECLAIM SeminarOctober 26, 2005October 26, 2005

Judy B. Yorke, P.E., C.P.P.Judy B. Yorke, P.E., C.P.P.Yorke Engineering, LLCYorke Engineering, LLC

949-248-8490 x25949-248-8490 x25JYorke@YorkeEngr.comJYorke@YorkeEngr.com

OutlineOutline

Managing Your Permit and Managing Your Permit and EmissionsEmissions

Planning for GrowthPlanning for Growth

Managing Your PermitManaging Your Permit

Understand your permit requirementsUnderstand your permit requirements Watch out for compliance issuesWatch out for compliance issues Look for opportunities to improve your Look for opportunities to improve your

permit termspermit terms

Always Keep the Future in MindAlways Keep the Future in Mind

Look out over the next 5 yearsLook out over the next 5 years Manufacturing changesManufacturing changes New product linesNew product lines New equipmentNew equipment Permit constraints and possibilitiesPermit constraints and possibilities

Keep Your Permit CleanKeep Your Permit Clean

Don’t be limited by Don’t be limited by unnecessary conditionsunnecessary conditions

Understand the origin Understand the origin of each requirement, of each requirement, limit, and emission limit, and emission factorfactor

Review Your Permit ConditionsReview Your Permit Conditions

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

Is the condition or limit based on a specific identifiable regulatory requirement?

General GuidelinesGeneral Guidelines

Does any other condition determine compliancewith the same regulatory requirement?

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

Obsolete Permit ConditionsObsolete Permit Conditions

Remove Conditions That Remove Conditions That are No Longer Applicableare No Longer Applicable

For Example:For Example:

– Start-up Source TestStart-up Source Test

– Initial Installation Initial Installation ConditionsConditions

– Start-up NotificationStart-up Notification

Broad Permit ConditionsBroad Permit Conditions

Ensure that Requirements Ensure that Requirements are Properly Specified.are Properly Specified.

Avoid Broadly Stated Avoid Broadly Stated Requirements, e.g.:Requirements, e.g.:

– ““Facility shall not exceed Facility shall not exceed 50lbs/day NOx”50lbs/day NOx”

Overlapping RequirementsOverlapping Requirements

Avoid requirements that Avoid requirements that may overlap.may overlap.

For Example:For Example:

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

Redundant RequirementsRedundant Requirements

Avoid Requirements Avoid Requirements that are Redundant.that are Redundant.

For Example:For Example:

A boiler subject to A boiler subject to RECLAIM and RECLAIM and Rule 1146 NOx Rule 1146 NOx Limits.Limits.

MistakesMistakes

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

Duplicate or Missing PermitsDuplicate or Missing Permits

Ensure that each Ensure that each permit unit is listedpermit unit is listed

Ensure that permit Ensure that permit units are not listed units are not listed more than oncemore than once

ConsistencyConsistency

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

Ensure that Conditions Ensure that Conditions on Identical Units are on Identical Units are ConsistentConsistent

NSR RequirementsNSR Requirements

Conditions from NSR may Conditions from NSR may be applicable, e.g.: “This be applicable, e.g.: “This equipment shall not be equipment shall not be operated when I.C.E. D14 operated when I.C.E. D14 is operating.”is operating.”

Each of these conditions Each of these conditions should be verified and should be verified and appropriateappropriate

Compliance should be Compliance should be demonstratabledemonstratable

MonitoringMonitoring

Ensure that an Ensure that an appropriate method appropriate method is specifiedis specified

Ensure that the Ensure that the Requirements are Requirements are clearly identified clearly identified and understoodand understood

Emission LimitsEmission Limits

Ensure that emission limits are Ensure that emission limits are from an applicable requirementfrom an applicable requirement

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

Know the difference between an Know the difference between an emission factor and a emission factor and a concentration limitconcentration limit

Strategies for GrowthStrategies for Growth

Rule 2012 Rule 2012 Concentration LimitConcentration Limit

Reduce or Control Reduce or Control EmissionsEmissions

Buy CreditsBuy Credits

Rule 2012 OpportunitiesRule 2012 Opportunities

Large Sources and Now Process Units may Large Sources and Now Process Units may Elect a Concentration LimitElect a Concentration Limit

A Realistic Concentration Limit can Lower A Realistic Concentration Limit can Lower RECLAIM Emission CalculationsRECLAIM Emission Calculations

……But Choose Wisely, Equipment Emissions But Choose Wisely, Equipment Emissions Must Always Comply with the LimitMust Always Comply with the Limit

Rule 2012 Opportunities (Cont.)Rule 2012 Opportunities (Cont.)

A Concentration Limit Replaces the A Concentration Limit Replaces the RECLAIM Emission Factor Specified in RECLAIM Emission Factor Specified in Your Permit for a Given DeviceYour Permit for a Given Device

After Approved, This Lower Value will be After Approved, This Lower Value will be Used to Quantify the Emissions for That Used to Quantify the Emissions for That SourceSource

Rule 2012 Opportunities (Cont.)Rule 2012 Opportunities (Cont.)

Select Wisely, e.g., Use Source Test Select Wisely, e.g., Use Source Test Data and Manufacturer’s GuaranteeData and Manufacturer’s Guarantee

To Change Your Permit:To Change Your Permit:– File a Permit Application for a Change of File a Permit Application for a Change of

Condition - Requesting the Concentration Condition - Requesting the Concentration LimitLimit

– Pay the Administrative Modification feePay the Administrative Modification feeForm 400A

Rule 2012 Opportunities (Cont.)Rule 2012 Opportunities (Cont.)

A Meter may be Necessary to Separate A Meter may be Necessary to Separate the Fuel Use for Reportingthe Fuel Use for Reporting

After Changing Your Permit, Be After Changing Your Permit, Be Prepared to Complete the Required Prepared to Complete the Required Source Tests:Source Tests:– Every 3 Years for Large SourcesEvery 3 Years for Large Sources– Every 5 Years for Process UnitsEvery 5 Years for Process Units

For Example…For Example…

Equipment Equipment TypeType

Current Current Emission Emission Factor Factor

(lb/mmcf)(lb/mmcf)

Possible Possible Concentration Concentration

Limit*Limit*

(lb/mmcf)(lb/mmcf)

Curing and Curing and Drying OvenDrying Oven

130130 7070

BoilerBoiler 130130 3535

Forging Forging FurnaceFurnace

213213 170170

Melting FurnaceMelting Furnace 130130 6565

* Concentration Limits are specified on permit in ppm

Control Emissions – Control Emissions – Technology OptionsTechnology Options

Retrofit existing equipment*Retrofit existing equipment*– Low-NOx burnerLow-NOx burner– SCRSCR– Emerging technologyEmerging technology

Replace old inefficient equipment and install Replace old inefficient equipment and install BACTBACT

*Retrofitting does not require BACT!(As long as emissions are not increased…)

Estimating Cost EffectivenessEstimating Cost Effectiveness

Is it cheaper to buy credits or control Is it cheaper to buy credits or control emissions?emissions?

Analyze capital, installation, maintenance, Analyze capital, installation, maintenance, and other costs vs. cost of RTCs!and other costs vs. cost of RTCs!– Prepare an initial estimatePrepare an initial estimate– Obtain vendor proposalsObtain vendor proposals– Apply for a modificationApply for a modification

Retrofit Regulatory RequirementsRetrofit Regulatory Requirements

Prior to Modification, Obtain a Prior to Modification, Obtain a Permit to ConstructPermit to Construct

To Obtain a PTC, File an To Obtain a PTC, File an Application Application

Typical SCAQMD Fees Range Typical SCAQMD Fees Range from $300-$4000from $300-$4000

We can Assist You using We can Assist You using PermitWorks …Just Ask Your PermitWorks …Just Ask Your Account ExecutiveAccount Executive

Retrofit Regulatory Requirements Retrofit Regulatory Requirements (Cont.)(Cont.)

Any Change Must Also Any Change Must Also Consider Non-RECLAIM Consider Non-RECLAIM PollutantsPollutants

A Modification Must Comply A Modification Must Comply with Existing Rules, e.g.,:with Existing Rules, e.g.,:– Rule 1110.2 for IC EnginesRule 1110.2 for IC Engines– Rule 1146.1 & 1146.2 for Rule 1146.1 & 1146.2 for

Boilers and Process HeatersBoilers and Process Heaters

Retrofit Regulatory Requirements Retrofit Regulatory Requirements (Cont.)(Cont.)

If There is Any Increase in If There is Any Increase in Emissions, Rating, or Emissions, Rating, or Throughput; New Source Throughput; New Source Review is TriggeredReview is Triggered

NSR Requires Best Available NSR Requires Best Available Control Technology, Control Technology, Modeling, and OffsetsModeling, and Offsets

Strategy ConclusionsStrategy Conclusions

Plan AheadPlan Ahead Get permit assistance Get permit assistance Ask vendors for referencesAsk vendors for references Get a guarantee of emissionsGet a guarantee of emissions Get a Permit to Construct Get a Permit to Construct

before purchasing equipmentbefore purchasing equipment

Resources for HelpResources for Help

Talk to Your AETalk to Your AE– For a Rule 2012, Concentration Limit ReviewFor a Rule 2012, Concentration Limit Review– For Permitting AssistanceFor Permitting Assistance– For Equipment InformationFor Equipment Information

Call The Gas Company’s Air Quality Call The Gas Company’s Air Quality AnswerLine with any combustion related air AnswerLine with any combustion related air quality question!quality question!

=> 1-562-803-7428=> 1-562-803-7428