1. RECLAIM Seminar October 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. Review 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?

7. 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?

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 Obsolete Permit Conditions  Remove Conditions That are No Longer Applicable  For Example: –Start-up Source Test –Initial Installation Conditions –Start-up Notification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… Equipment Type Current Emission Factor (lb/mmcf) Possible Concentration Limit* (lb/mmcf) Curing and Drying Oven 13070 Boiler13035 Forging Furnace 213170 Melting Furnace 13065 * 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