RECLAIM Seminar October 26, 2005

1. RECLAIM SeminarOctober 26, 2005 Judy B. Yorke, P.E., C.P.P. Yorke Engineering, LLC 949-248-8490 x25 JYorke@YorkeEngr.com

2. Outline • Managing Your Permit and Emissions • Planning for Growth

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

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

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

6. Is the condition specific, clear, and can compliance be demonstrated? Is the condition or limit based on a specific identifiable regulatory requirement? Review Your Permit Conditions

7. 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? General Guidelines

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 Obsolete Permit Conditions • Remove Conditions That are No Longer Applicable • For Example: • Start-up Source Test • Initial Installation Conditions • Start-up Notification

9. Broad Permit Conditions • Ensure that Requirements are Properly Specified. • Avoid Broadly Stated Requirements, e.g.: • “Facility shall not exceed 50lbs/day NOx”

10. 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”

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

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

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

14. Consistency • Ensure that Specifications on Identical Units are Consistent • Ensure that Conditions on Identical Units are Consistent

15. 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

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

17. 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

18. Strategies for Growth • Rule 2012 Concentration Limit • Reduce or Control Emissions • Buy Credits

19. 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

20. 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

21. 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 Form 400A

22. 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

23. For Example… * Concentration Limits are specified on permit in ppm

24. 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…)

25. 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

26. 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

27. 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

28. 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

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

30. 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