HomeMy WebLinkAbout05. AB 129 Regulations Updates129
REGULATIONS UPDATES
Rita Cheng, P.E.
Associate Engineer
Real Estate, Environmental and Planning
Committee
March 8, 2016
BACKGROUND ON 129 REGULATIONS
• Clean Air Act Section 129 SSI Regulations
• Effective March 21, 2016
• Major Components
• Emission limits
• Visible emissions from ash loading operation
• Process operating limits
• Operator training program
• Emergency bypass damper operation
5.
1
OVERVIEW OF FURNACE OPERATION
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EMISSION LIMITS
• Emission Limits for Nine Pollutants
• Most Concerned Pollutant: HCI
.ff Stack limit of 1.2ppmv
• Current Status
HCI can be controlled by caustic injection
w Caustic injection pilot testing on MHF Nos. 1 and 2
Completed MHF No. 1 Initial 129 Compliance
Demonstration Source Test and passed all limits
Full-scale t t t
• caustic injection system is being constructed.
Expected completion in April 2016
• Optimization of full-scale system in April/May 2016
3/1/2016
2
VISIBLE EMISSIONS FROM ASH LOADING
• Visible emissions will now be limited to three minutes
in any 60 -Minute Period
• Current Status
• Installed mister ring for initial loading
• CH2M conducted ash handling improvement study
• Installed additional water injectors on pugmill
• Optimizing water addition to minimize visible
emissions
PROCESS OPERATING LIMITS
• New Parametric Minimum Operating Limits
• Hearth No. 1 afterburners temperature
• Wet Scrubber outlet pH, inlet flowrate, and pressure
drop differential
• Current Status
• Awaiting response from USEPA Region 9 on
proposed site-specific limits
• Pressure drop, inlet flowrate, and Hearth No. 1
temperature limits can be met without additional
E- modifications
3/1/2016
3
OPERATOR TRAINING PROGRAM
• Enhanced Furnace Operator Training Program
• Current Status
• Completed initial certification trainings
• Updated furnace O&M manual
• Working on video training for annual refresher,
expected to be complete in November 2016
EMERGENCY BYPASS DAMPER OPERATION
• Bypass damper in place to protect Waste Heat Boiler and Wet
Scrubber
• Opening of bypass damper will now require notifications to
BAAQMD
• Current Status:
• Minimize use of bypass damper
• Revised control scheme on Waste Heat Boilers
• Installed pressure switches for back-up scrubber pumps
• Known bypass triggers and appropriate operational
responses have been identified
3/1/2016
4
PROPOSED FURNACE SOURCE TESTING
CONTRACT SCOPE
• HCI Evaluation Emission Source Test
• During start-up of the full-scale Caustic Injection
System on Furnace No. 2
• Tentatively scheduled for May 2016
• 129 Initial Compliance Demonstration Emission Source
Test for Furnace No. 2
• Tentatively scheduled for June 2016
.00,10
POSITION PAPER RECOMMENDATION
Execute a Professional Services Agreement
with Blue Sky Environmental, Inc.,
in the Amount of $141,510
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3/1/2016
5
QUESTIONS?
3/1/2016
6