HomeMy WebLinkAboutAGENDA REPORT 1994 0817 CC REG ITEM 11D I I a
ITEM
AGENDA REPORT
CITY OF MOORPARK
TO: Honorable City Council �/�
FROM: Mary R. Lindley, Assistant to the City Manageryl \.
DATE: August 12, 1994 (CC Meeting of August 17)
SUBJECT: Consider the Draft and Alternative Federal
Implementation Plans
Background
The Clean Air Act Amendments of 1977 required all areas to submit
ozone and carbon monoxide plans in 1979 and 1982 demonstrating
attainment of the national health-based standards by 1987 . Because
of massive emission reductions needed for attainment in Ventura,
Sacramento, and the greater Los Angeles areas, State and local
agencies acknowledged that their plans would not result in
attainment by the Act's deadline. EPA took no action to disapprove
the attainment demonstrations, since the plans' failure to meet the
1987 deadline was not the result of a failure to pursue aggressive
controls.
Environmental groups (including the Citizens to Preserve the Ojai
and the Sierra Club) successfully challenged EPA's failure to
disapprove the 1982 State plan and then sought a court order
requiring EPA to set in place Federal Implementation Plans (FIP)
for the aforementioned areas. A Draft FIP was developed and has
been circulated to local governments, business leaders, and
residents for comment.
As currently written, the FIP will impose far reaching new
regulations for the control of air emissions. It has the potential
of significantly hurting Ventura County's economy.
Opponents cite numerous examples of Draft FIP regulations that will
cripple Ventura County businesses and industries. For example, new
or expanding stationary sources must currently offset 120 percent
of the emissions which they will produce. Typically, this is done
by the existing business retrofitting its equipment to reduce
emissions. A new business may have to pay to retrofit someone
else's equipment, or buy an existing stationary emission source and
Federal Implementation Plan
August 12 , 1994
Page 2
put it out of operation. Under the proposed FIP, the offset
requirements may be increased to a ratio of two to one. In other
words, a new stationary source will have to reduce existing
emissions by twice the amount of emissions that the new source is
expected to produce.
Ventura County's agricultural industry will also be subject to
severe restrictions. The use of oil-based suffocants now applied
to citrus trees, in place of poisonous insecticides, may be
strictly limited or banned completely. Farm equipment powered by
internal combustion engines will be required to be fitted with
exhaust emission controls.
Ventura County's business community, working through VCEDA, and the
Council on Economic Vitality have developed the Alternative FIP to
try to remove the onerous regulations in the Draft FIP. The
Alternative FIP acknowledges that Federal authority, under the
Draft FIP, brings greater power to the pollution control efforts.
Sources such as trains, heavy-duty trucks, airplanes, ships, garden
equipment, and construction machinery are beyond the control of
local governments and should remain in the final FIP document. On
the other hand, the Alternative FIP seeks to relax regulations that
would otherwise severely hurt local businesses and local
industries.
The Alternative FIP tries to equalize the emission reduction
efforts between mobile and stationary sources and calls for
emission fees and penalty fines collected locally to stay in
Ventura County (under the Draft, FIP fees would be returned to EPA
and the State) . The Alternative FIP attempts to provide greater
local control and overall flexibility by administering the program
through the Ventura County APCD, rather than the State or Federal
EPAs, and putting in place mid-program progress evaluations after
which more stringent measures could be implemented if necessary.
The one drawback to the Alternative FIP is that it places a greater
burden for emission reduction on light-duty and medium-duty
vehicles than does the Draft FIP (see page 15 of Attachment A -
Alternative FIP) . Proponents of the Alternative FIP believe that
these sources should carry a burden equal to their emission
contribution to the county's air pollution. Measures that impact
light and medium-duty vehicles are typically less popular with
residents.
VCEDA and the Council on Economic Vitality have requested that the
Moorpark City Council consider providing a letter, or adopting a
resolution, (see Attachment B) in support of the Alterative FIP.
Federal Implementation Plan
August 12, 1994
Page 3
While it would be preferable not to be faced with implementing
emission control measures that will undoubtedly impact Ventura
County residents, businesses, or industry, the fact remains that
control measures must be adopted. Staff believes that the
Alternative FIP provides Ventura County with more palatable
measures than does the Draft FIP. Even though the Alternative FIP
places a greater responsibility on light-duty and medium-duty
sources than does the Draft FIP, most of its other measures are
still preferable. Staff suggests that City Council's position on
the Draft and Alternative FIPs be addressed in a letter rather than
by resolution.
Recommendation
Staff recommends that the City Council:
1. Strongly oppose the Draft FIP; and
2 . Request that the Federal EPA consider less extreme
measures to reach Air Quality Standards - measures that
address local conditions and provide local control, as
the Alternative FIP attempts to do.
A mcY\+ A
DRAFT RESOLUTION
OF
WHEREAS, state and local regulatory efforts and the voluntary
accomplishments of businesses and individuals in Ventura County
have produced dramatic improvements in air quality; and
WHEREAS, despite these improvements, air quality in the county
continues to exceed the federal air quality standard for ozone on
several days each year; and
WHEREAS, federal courts have ordered the United States
Environmental Protection Agency (EPA) to prepare a plan to bring
the county into attainment; and
WHEREAS, the EPA issued a draft plan- called the Federal
Implementation Plan (FIP)- for, this purpose in February, 1994; and
WHEREAS, the proposed FIP contains measures which could
unnecessarily burden our economy; and
WHEREAS, the EPA has stated that they would accept a
replacement plan which attained the same air quality benefits at
less cost to the local economy; and
WHEREAS, the Council on Economic Vitality and the Ventura
County Economic Development Association have developed such a
replacement plan (CEV/VCEDA Plan) ;
NOW, THEREFORE, BE IT RESOLVED that the
supports the CEV/VCEDA Plan and urges the EPA to accept CEV/VCEDA
proposals in place of the more burdensome portions of the draft
FIP.
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Dear
The Council on Econoini-c Vitality is seeking _your endorsement for
a plan to improve the cauntv's air auality and protect the local
economy. The plan we propc;e is offered as an alternative to a
court-ordered plan prepared by the U. S. Environmental Protection
Agency (EPA) which could have severe economic consequences ,
The EPA plan is called the Federal Implementation Plan or FIP,
The draft FIP, if implemented, would affect every aspect of our
lives from the . way we mow our lawns to the way trucks collect
Produce from farms. The drafr Flp would cost our economy billions
Of dollars a year and unfairly 'penali2e local industries which have
done the most to- 'reduce air pollution.
e Cauncil o�Economic vitality (CEV) was created by the Ventura
County Board of Supervisors to improve our business climate during
the current recession. The Council is a public-private
partnership, dedicated to environmental protection without
unnecessary impediments to business. The CEV has been working with
the Ventura County Economic Development Association and the Ventura
County Air Pollution Control District to develop this alternative
air quality plan.
We would appreciate your review of the attached issue, paper and
your organization's endorsement of the principles of a revised
Federal implementation Plan as described in the paper. For your
convenience, we have attached a draft reso?ution of support.
If you or any of the members of your organization have questions
about these issues, please call us at the phone numbers below.
Sincerely,
Dana 'Weber Young Kevin V. Rubey
Co--Chair Co-Chair
(805) 654-2926 (805) 388 4134
VENTURA COUNTY
FEDERAL IMPLEMENTATION PLAN
REVIEW /ANALYSIS PROJECT
El
GED
,c4i
VENTURA COUNTY ECONOMIC DEVELOPMENT ASSOCIATION
Environmental Affairs Division
Air Quality Committee
VENTURA COUNTY
ALTERNATIVE FIP MEASURE
VOC EMISSION BUBBLE PROVISION
Background
In Section III.C.5.a (1) of the Preamble of the Federal Implementation Plan (FIP), the EPA
presents a rationale for the requirement of declining volatile organic compound (VOC) emission
caps for the Ventura County FIP area. The EPA indicated that "limitations of available
technology -based regulations" would result in a shortfall of necessary emission reductions to
bring the Ventura County FIP area into attainment by the year 2005. Therefore, facilities that
generate VOC emissions equal to or greater than 4 tons per year (tpy) would be subject to
facility -wide emission reductions of 4 to 9 percent per year between the years 2001 and 2005.
The total Ventura County FIP area emission reduction resulting from this FIP measure has been
estimated by the EPA (Docket No. A- 94-09, Index No. III -D -3) to be 8.2 tons per day (tpd).
Alternative Rationale
The proposed FIP declining emission cap measure will result in significant economic and
operational constraints on the regulated community. Contrary to the EPA's assertion in the
Preamble of the proposed FIP that the declining cap will provide more operational flexibility,
the declining VOC emission cap will result in production curtailment and /or significant capital
costs at facilities which have already invested in substantial pollution control. In general,
facilities which have historically worked toward emission reduction would be penalized for past
compliance under the proposed FIP declining cap measure. Furthermore, the administrative and
enforcement burden on the agency of authority could be substantial since the proposed FIP
program is not consistent with any current permitting program in Ventura County.
In order to provide for the emission reductions required by the proposed FIP, an alternative
facility "bubble" program is proposed which will have the following features:
• equitable baseline emission determination;
• facility -wide operational flexibility;
• credit for past emission control and additional early emission reductions;
• consideration of equitable stationary source control (e.g., RACT) throughout the
universe of sources prior to establishing emission reduction goal for year 2005;
• provisions for off -site emission reduction credit/trading for both stationary and mobile
source emissions;
• permit structure consistent with the objectives of the 1990 Clean Air Act - Title V (40
CFR 70) provisions; and
• local administration of program through the VCAPCD.
The facility bubble program described below provides a reasonable and verifiable approach to
stationary source permitting which is consistent with the objectives of the proposed FIP. It
provides for a mid - program progress evaluation during which the overall effectiveness of all FIP
emission reduction measures, both stationary and mobile, will be assessed. If it is determined
that additional stationary source VOC emission reductions will be necessary in order to achieve
NAAQS attainment, then 2005 emission bubble limits may be reduced by the amount necessary
to reach attainment in 2005.
Applicability for VOC Emitting Facilities
Facilities located in the Ventura County Area which emit 4 tons per year or more of VOCs from
the following VCAPCD - permitted processes or combination of processes:
• Industrial and commercial solvents and coatings;
• Manufacturing and use of products containing VOCs;
• Waste disposal facilities;
• Commercial food preparation and /or baking;
• Petroleum and natural gas extraction, processing, and storage facilities; and
• Any facilities which emit VOCs excluding those associated with fuel combustion which
request to be in the program and can meet the requirements.
Exemptions for Existing Equipment
If the combined permitted emissions for a group of units at a facility are maintained at or below
the designated emission facility bubble, the individual permit units are exempt from
BACT/BARCT and offset provisions of applicable VCAPCD rules: for VOC.
2.
Exemptions for Smaller Facilities
Owners or operators of exempt facilities which emit less than 4 tpy must certify to the VCAPCD
by January 1, 2000, that they are exempt from the bubble program (supporting calculations are
required). For exempt facilities which emit less than 2 tpy, this is a one -time certification unless
changes are made at the facility which increase emissions to 2 tpy or greater, whereupon they
become subject to one or more the following provisions:
Facilities which emit 2 tpy or greater and less than 4 tpy of VOC are required to
maintain records which demonstrate that 12 -month emissions are below the 4 tpy
threshold level. These exempt facilities must submit an annual certification of exemption
status to the VCAPCD by March 1 of each calendar year, beginning in 2002.
If an exempt facility exceeds the 4 tpy limit during any calendar year after January 1,
2000, the facility must notify the VCAPCD within 30 days and comply with the rule
beginning on January 1 of the calendar year following threshold level exceedence.
Any facility subject to the bubble rule can become exempt from the rule upon
demonstration by the facility that changes are made which decrease emissions to less than
4 tpy or less than 2 tpy, whereupon the applicable exemption status (described above)
will be given upon application to the VCAPCD.
Emission Baseline Determination
A baseline facility -wide emissions limit is the sum of baseline emissions from each non - exempt
process /equipment permit unit covered by the bubble. Baseline emissions limit for each unit are
defined as 80% of permitted emissions or the adjusted actual emissions, whichever is greater.
Actual adjusted emissions for a unit are defined as either of:
120% of actual VOC emissions during a 12 -month period between January 1, 1987 and
before January 1, 1990;
Amount of VOC emissions offsets acquired for the unit excluding offsets provided by the
community bank; or
120% of actual unit emissions during a 12 -month period between January 1, 1987 and
before January 1, 1990 prior to an increase in permitted_ emissions plus VOC emissions
offsets acquired for the unit excluding offsets provided by the community bank.
This annual average emission baseline criteria which reflects a 20% reduction of permitted VOC
emissions or a 20% increase in actual emissions during the baseline period is heretofore referred
to as the "20/20 Rule ". It allows for those sources which have reduced emissions in the past
but have operated at less than capacity to not be unreasonably penalized for past efforts.
3
Required Baseline Reductions
Baseline emission bubbles are applicable beginning January 1, 2001 through December 31, 2005.
Baseline emissions are subject to adjustment resulting from compliance with applicable VCAPCD
rules implemented after January 1, 1990. These emission reduction measures are part of the SIP
for CAAQS attainment.
As part of the mid - program progress evaluation, the overall effectiveness of all FIP emission
reduction measures, both stationary and mobile, will be assessed. If it is determined that
additional stationary source VOC emission reductions will be necessary in order to achieve
NAAQS attainment, then 2005 emission bubble limits may be reduced by the amount necessary
to reach attainment in 2005, but only after all other planned SIP/FIP emission reduction
measures have been implemented to the fullest extent feasible. In any case, additional
emission reductions must be first associated with application of RACT on those sources
previously uncontrolled. Any subsequent stationary source emission bubble limit reductions
would therefore be implemented only after all source categories have applied RACT on an equal
basis.
Voluntary Baseline Reductions
A mechanism for creation and trading of emission reduction credits (ERCs) will be used to
promote voluntary VOC bubble reductions by facilities in Ventura County:
• Baseline emissions bubble can be decreased voluntarily if a facility wishes to create
marketable ERCs available to other facilities seeking to offset emission increases.
• Facilities can choose to implement off -site VOC emissions reductions to create
transferable ERCs where on -site reductions are determined to be economically or
technologically infeasible.
• All inter - facility ERC transfers are discounted at a ratio of .1.3:1 until January 1, 2000.
Thereafter, all ERC transfers will be discounted at as ratio of 1.5:1.
• When ERCs are not used to offset emissions elsewhere, voluntary ERCs are bankable
for "pre - compliance" with applicable rules which mandate future emission baseline
reductions. Banked ERCs can be "cashed -in" (retired) to satisfy future emission
reduction mandates as necessary.
Increasing Emission Baseline
The ERC trading program shall allow facilities in the growth mode (and new facilities) to
acquire discounted offsets in order to increase permitted emissions of VOC.
4
Emission Baseline Adjustments
Emission baselines are subject to adjustment as a result of: (1) VCAPCD rule implementation,
(2) ERC banking or retirement, or (3) offset acquisition:
For baseline reductions due to equipment - specific VCAPCD rule implementation, use
records of emissions (120% of actual or 80% of permitted, whichever is greater) for the
equipment during 24 -month period prior to rule adoption to calculate average actual
emissions (annual basis). Reduce the emission baseline by multiplying the equipment -
specific emissions times one minus the ratio of the new emission factor (EF) to the old
emission factor (EF) and subtract emission reduction from the previous emission
baseline:
Emission Reduction = Initial Equipment Emissions x ( 1 - New EF / Old EF)
Adjusted Baseline = Previous Baseline - Emission Reduction
For emission baseline reductions due to ERC banking or retirement, subtract the emission
reduction from the previous emission baseline:
Adjusted Baseline = Previous Baseline - Emission Reduction
For emission baseline increases due to ERC acquisition or transfer for offsets, add the
emission increase to the previous baseline emissions cap:
Adjusted Baseline = Previous Baseline + Emission Increase
Recordkeeping, Monitoring, and Calculations
Mutually acceptable recordkeeping and calculation procedures must be agreed upon by the
facility and the VCAPCD for each unit and each pollutant. If no agreement can be reached,
then the unit/pollutant in question is subject to BACTBARCT and offset provisions of applicable
VCAPCD rules.
Information shall be collected and recorded for each unit for each day of each calendar
year beginning in 2001 and ending in 2005. Records must be compiled on a calendar
month basis an must include a summary of total emissions for the most recent month and
total emissions for the previous 12 months. These records are subject to inspection by
the agency at any time.
Emissions must be quantified using agreed -upon calculation techniques. For VOC
emissions from solvents and solvent - based materials, material balance calculations which
assume "use at time of purchase or first container opening" are acceptable, although "use
at time of use" is desirable.
All emission quantifications and source testing procedures must be in compliance with
applicable VCAPCD rules. Source testing may be required by the agency at any time
to demonstrate compliance with the rule.
Compliance Plans
Subject facilities must prepare and submit VOC emissions reduction compliance plans by January
1, 2000:
The plans shall demonstrate how the facility will comply with adopted, applicable, and
implementable VCAPCD rules and estimate actual emissions reductions to be achieved
prior to December 31, 2005.
Planned voluntary reductions which create marketable, transferable, or bankable ERCs
must also be included in compliance plans.
Baseline emissions and emission reductions are to be calculated on an annual basis.
Reporting
Beginning in 2002, owners or operators must submit to the VCAPCD an annual certification of
compliance with the rule by March 1 of each calendar year. The certification of compliance
must include actual emissions data and results, all necessary supporting data, and example
calculations. Ongoing compliance must be verified on a monthly basis by the facility. Ongoing
compliance is subject to verification by the agency at any time.
no
VENTURA COUNTY
ALTERNATIVE FIP MEASURE
ELIMINATION OF DECLINING NOx EMISSION CAP
Background
In Section III.C.5.a (1) of the Preamble of the Federal Implementation Plan (FIP), the EPA
presents a rationale for the requirement of declining oxides of nitrogen (NO,) emission caps for
the Ventura County FIP area. The EPA indicated that "limitations of available technology -based
regulations" would result in a shortfall of necessary emission reductions to bring the Ventura
County FIP area into attainment by the year 2005. Therefore, facilities that generate NOx
emissions equal to or greater than 4 tons per year (tpy) would be subject to facility -wide
emission reductions of 6 to 9 percent per year between the years 2001 and 2005. The total
Ventura County FIP area emission reduction resulting from this FIP measure has been estimated
by the EPA (Docket No. A -94 -09, Index No. III -D -3) to be 3.7 tons per day (tpd).
Alternative Rationale
The proposed FIP declining emission cap measure will result in a relatively small emission
reduction while creating significant economic and operational constraints on the regulated
community. Contrary to the EPA's assertion in the Preamble of the proposed FIP that the
declining cap will provide more operational flexibility, the NOx declining cap will likely result
in production curtailment and /or significant capital costs at facilities which have already invested
in substantial pollution control. In general, those facilities which have historically worked
toward emission reduction would be penalized for past compliance under the proposed FIP
declining cap measure.
In light of the relatively small amount of emission reductions associated from the proposed FIP
declining NOx cap (3.7 tpd) and the high cost of compliance /enforcement, a verifiable
replacement of these stationary source emission reductions would be consistent with objective
of the FIP. Concurrent with the preparation of the proposed FIP has been the preparation of
the Ventura County Air Quality Management Plan (AQMP) pursuant to the State Implementation
Plan (SIP). The AQMP process identified several measures where emission reductions not
accounted for in the proposed FIP. These stationary source emission reduction measures can
serve as reasonable, verifiable, and enforceable emission. reduction SIP provisions to replace the
proposed FIP measure.
7
NOX Emission Reduction Credit In Place of Declining Cap
Emission reductions not accounted for in the proposed FIP are summarized below:
The additional emission reductions associated with AQMP Measure N -106 result from the EPA
underestimating the emission reductions from VCAPCD Rule 59 for utility boilers operated by
Southern California Edison. Since the utility boiler emissions are reported using a continuous
emission monitoring system (CEMS), a higher emission control efficiency (>90%) can be
verified than the control efficiency (78 %) assumed by the EPA in the proposed FIP.
There is no evidence that the emission reductions associated with AQMP Measures N -101, N-
102, N -104, N -105, and N -108 were accounted for in the proposed FIP. As emission control
measures are either adopted by the VCAPCD or proposed for future promulgation, the emission
reductions associated with these AQMP measures can be reasonably considered as additional
emission reduction credits in the "zero sum game ".
VENTURA COUNTY
ALTERNATIVE FIP MEASURE
CREDIT FOR ADDITIONAL VOC EMISSION REDUCTIONS
Background
EPA has clearly indicated that the FIP process is a "zero sum game ". It is understood that the
total emission reductions from sources in the Ventura County FIP area must equal the value
identified by the EPA in their FIP analysis as documented in the FIP Technical Support
Documents (TSDs). Any proposed FIP measure which is modified or eliminated from the FIP
must be replaced by a SIP or FIP measure which results in an equal or greater emission
reduction. Review of the TSDs and the draft Ventura County AQMP has identified several
instances where the proposed FIP does not account for emission reductions which could be
legitimately credited to the "zero sum game ".
Alternative Rationale
It is understood that all emission reduction measures associated with the proposed FIP and the
Ventura County AQMP should be accounted for in the "zero sum game" in order to implement
an equitable emission control strategy. This alternative FIP measure simply recognizes the
verifiable emission reductions produced by these specific measures. In doing so, the overall
emission reduction increment required by the proposed FIP can be adjusted downward.
VOC Emission Reduction Credits
Summary of VOC emission reductions not accounted for in the proposed FIP is presented in the
following table.
9
X REDUCTION
atonslday).
1.11
0.17
0.15
0.18
0.58
There is no evidence that the emission reductions associated with AQMP Measures R -322, 8-
504, R -606, R -108, R-411, and R -311 were accounted for in the proposed FIP. As emission
control measures are either adopted by the VCAPCD or proposed for future promulgation, the
emission reductions associated with these AQMP measures can be reasonably considered as
additional emission reduction credits in the "zero sum game ".
10
VENTURA COUNTY
ALTERNATIVE FIP MEASURE
MODIFIED FUGITIVE EMISSION I &M MEASURE FOR OIL & GAS FACILITIES
Background
The proposed FIP defines a fugitive emission inspection and maintenance (I &M) program for
oil and gas facilities. This program builds upon VCAPCD Rule 74.7, VCAPCD Rule 74.10,
South Coast AQMD Rule 1173, and CARB's RACT guidance. In general, the proposed FIP
measure requires retrofit of gas - operated control valves, lower allowable leak thresholds, and
enhanced inspection /repair programs.
Alternative Rationale
In general, proposed 40 CFR 52.2961(i) and 40 CFR 52.2961(t) present reasonable leak
detection and repair requirements. There are, however, individual elements of the program
which provide little or no environmental benefit at a significant cost in monitoring and
recordkeeeping. The proposed alternative approach would retain the most stringent elements of
VCAPCD Rule 74.7, VCAPCD Rule 74.10 and CARB's RACT. In addition, it would include
the proposed FIP provision which stipulates the replacement gas - operated control valves. It is
believed that these measures will result in the emission reductions expected by the proposed FIP
for oil and gas operations.
Additional proposed FIP measures related to recordkeeeping, repair scheduling, and certification
which go beyond the stringent guidelines of the VCAPCD and CARB programs have not shown
any value in terms of decreasing fugitive emissions. Since proven recordkeeeping, repair
scheduling, and certification policy has been established in the existing local program, further
measures in these administrative areas provide no value to the fugitive emission program.
Finally, the proposed FIP Rule 2 (chemical plants, refineries, gas processing plants, bulk plants
or terminals) definition of a gas leak from a valve or fitting of 500 ppm is inconsistent with
CARB's RACT guidance. The alternative FIP measure would set the gas leak definition at
1,000 ppm which is consistent with treatment for other oil and gas facilities pursuant to proposed
FIP Rule 1 (oil and gas processing and conveyance facilities) as well as CARB's RACT
guidance.
Modified FIP Measure for Fugitive Emissions
Presented in the following table -is a summary of the modified (alternative) FIP measure for
fugitive emissions from oil and gas facilities. The measure elements identified in bold indicate
the rule which provides the controlling threshold value, definition, or action item.
. _.
RULE <OR` OETERM INATIO N
:,:STANDARD,,.`
Applicability
Refineries and Oil and gas Oil and gas
chemical plants production and production and
processing facilities processing
facilities,
refineries,
chemical plants,
pipeline transfer
stations
Gas leak definitions (ppm):
valves and fittings
PROS
All other components
10,000
200
10,000
10,000
10,000
10,000
1,000
1,000
1,000
Leak control requirements
(allowed no. of leaks):
A. (5200 components)'
valves
n/a
5
0.5%
pumps
n/a
n/a
0.5%
compressors
n/a
n/a
0.5%
fittings, other components
n/a
2
0.5%
B. ( >200 components)'
valves
n/a
2%
0.5%
pumps
n/a
n/a
0.5%
compressors
n/a
n/a
0.5%
fittings, other components
n/a
1 %
0.5%
Component identification:
A. Physical identification
n/a
n/a
major & critical
components
B. Identification on diagrams
all components
n/a
major, critical,
& inaccessible
components
12
`
��. >.RULE OR: AETERMINATION
STANDARD
;.:
VCAeCDule
`l4
VCAPCD Rule?
74 10
CARB's RACT
'
}
Inspection requirements:'
A. Visual inspection
P = daily
P = weekly
same as FIP
Rules
B. OVA inspection
PRSBs, GV, LV, P,
PRSBs, GV, LV, P,
same as FIP
quarterly schedule-d
C, PRDs
C, PRDs
Rules
semi - annual schedule
-
same as FIP
Rules
annual schedule
CN, inaccessible
CN, inaccessible
same as FIP
components
components
Rules
C. Time between repair and re-
n/a
7 days
same as FIP
inspection
Rules
Repair requirements:
A. Leak repair schedule
15 days
21 days
same as FIP
gas leaks
Rules
liquid leaks
15 days
21 days
same as FIP
Rules
leaks from critical components
90 days or next
90 days or next
same as FIP
turnaround
turnaround (15.
Rules
days at natural gas
processing plant)
B. Standards for the no. of
no
components awaiting repair
no
no
C. Gas - operated control valve
retrofit requirement
no
no
no
13
;>
: #RULE OR DETERMINATION
... :... ;
STANDARD >
VCAPCRule.
D I
VCAPCD
CARB's RACY
Exemptions:
A. Inspection requirements for
n/a
yes (but must be
no (alternative
unsafe -to- monitor components
inspected at least
inspection plan
annually)
required)
B. Components handling < 10%
n/a
yes (< 12% VOC)
yes
VOC fluids
C. Components operating under
n/a
n/a
yes
negative pressure
D. Components handling
n/a
n/a
no
commercial natural gas
E. PRDs, pumps, and compressors
n/a
n/a
yes
equipped with a VOC control
system
Administrative requirements:
A. Compliance plan or operator
yes
yes
yes
management plan
B. Certification of compliance
n/a
n/a
n/a
C. Maintain records for 2 years
yes
yes
yes
GV = gas valve; LV = liquid valve; CN = connector, fitting, or flange; P = pump; C = compressor;
PRD = pressure relief device; PRSB = polished rod stuffing box.
° For VCAPCD Rule 74.10, the number of components is 250 instead of 200 for all components
except valves. The value is given as a whole number or as a percentage of the number of
components inspected.
Rule 74.7, if operated in leak free condition for three consecutive months; otherwise monthly
inspections are required.
° Rule 74.10, at natural gas processing plants only; annual inspections are required at other facilities
subject to this rule.
14
VENTURA COUNTY
ALTERNATIVE FIP MEASURE
ADDITIONAL EMISSION REDUCTION MEASURES FOR LIGHT -DUTY AND
MEDIUM -DUTY VEHICLES
Background
The proposed FIP provides for significant emission reductions from mobile sources. Even with
these emission reduction measures, the light -duty and medium -duty vehicle categories remain
a significant part of the year 2000 emission inventory (larger perhaps than currently estimated)
for Ventura County. It is clear that any significant progress toward attainment of the NAAQS
will require reducing amount of emissions from these on -road source categories. Special
attention must be given to the small percentage of vehicles in the light - /medium -duty vehicle
category which produce a large percentage of the emissions.
Alternative Rationale
Several light -duty and medium -duty vehicle emission reduction opportunities exists beyond those
measures identified in the proposed FIP. The alternative FIP measure would incorporateTo
ensure that the mobile sources carry the burden of emission reductions proportional to their
emission contribution to the county inventory and to take advantage of additional opportunities
of further cost- effective emission reductions. In addition, these measures could serve to relieve
the burden of emission reductions from heavy -duty vehicles which have technological limitations
in emission reductions under the proposd FIP.
Proposed Additional Etnission Reduction Measures
Presented below is a listing for recommended measures beyond the proposed FIP for the purpose
of providing verifiable, cost - effective emission reductions:
• State -wide enhanced vehicle I &M program which separates testing and repairs equivalent
to the EPA's program.
• A Vehicle Miles Traveled (VMT) fee program based upon miles .driven and emissions
profile of the vehicle in manner consistent with SB 2050 (Presley).
• Special patrol and remote sensing ( "smog dog ") programs to identify non - compliance
vehicles with enforcement provisions.
• Application of AB 2247 to all FIP areas which would allow motor vehicle registration
15
surcharge to be used for specific mobile source emission reduction programs.
• Implementation of an "inverted" registration fee.
• Enhanced In -Use Compliance for light -duty vehicles.
• Implementation of CARB's LEV and ILEV programs.
• Ventura County governmental vehicle fleet conversion program.
H
VENTURA COUNTY
ALTERNATIVE FIP MEASURE
MODIFIED EMISSION REDUCTION MEASURES FOR HEAVY -DUTY VEHICLES
Background
There has been much discussion as to the technical feasibility of achieving the FIP heavy -duty
engine standard of 1.5 gm/bhp-hr. It is apparent that the technology does not exist for large on-
road engines. In addition, the FIP measures clearly involve the replacement or retrofit of many
smaller engines (over 1 million statewide) previously exempt and not operated continuously.
The compliance and enforcement requirement for these engines would be overwhelming for a
relatively small decrease in Ventura County mobile source emissions.
Alternative Rationale
The alternative FIP measure will provide for strict but realistic engine emission standard and
equitable means in dealing with existing engines. It adopts many of the in -use compliance and
maintenance provisions of the light -duty vehicles which results in consistency across the board
for all on -road vehicles. The alternative measure recognizes the potential for technology to
become available at different times for the various category of engines. Finally, it shifts the
burden of emission reduction from measures which are economically and administratively
untenable to measures which provide a balance throughout the mobile source inventory
(including light - /medium -duty vehicles).
Proposed Revised Emission Reduction Measures
Presented below is a listing for recommended measures beyond the proposed FIP for the purpose
of providing verifiable, cost - effective emission reductions:
A national heavy -duty engine standard would be established based upon technically and
economically reasonable engine emission reduction design (i.e., 3.5 gm/bhp -hr or
consistent with California standards) for regional and long -haul vehicles (greater than 51
miles radius).
A national heavy -duty engine standard of 2.5 gm/bhp-hr for other on -road heavy -duty
vehicles (gross vehicle weight of 60,000 lb or less).
Implementation of enhanced I &M program consistent to he light-duty vehicle
requirements.
17
t
ti
• Use -based emission allowance for engines utilized on an intermittent basis (similar to a
VMT program).
• Enhanced In -Use Compliance as with light -duty vehicles.
• Implementation of LEV and ILEV programs. r
Cf t`r
Ventura County governmental vehicle fleet conversion program.
• Federal incentive "buy -back" program. �'°
r
18
Waterworks No . 1 '"
Advisory Committee Comments
to
Moorpark City Council
Wednesday , August 17 , 1994
RECENT WW#1 BOARD OF DIRECTORS ACTION , 7/26/94
• No change in M & I Water rate
• Reduction of Ag . water rate by 11%
• Increased M & I service charge $1 . 75/Mo .
• Increased Ag . meter charges $4 . 50-$38 . 00/Mo . (A"-6" meters)
MWD/CMWD BOARD ACTIONS
• 5/94 MWD adopted a 3 year Interim Agricultural Water Program,
effective immediately , providing a discount of $137/A. F . for
agricultural use .
• CMWD adopted an increase in service charges , now known as a
"Base Facilities Charge" , effective 7/1/94 . The net effect
to WW#1 was an increased wholesale water rate to us in the
amount of $27/A. F .
WW#1 ADVISORY COMMITTEE RECOMMENDATIONS
• Pass through CMWD rate increase as a "fixed charge" , the
same concept passed on to WW#1 . This amounts to $1. 75/Mo .
per billing unit for M & I customers .
• Reduce Ag . rates by $45/A. F . (not the $137/A . F . mandated by
MWD) .
1. WW#1 already provides a 20% Ag . incentive , reduced rate
(reflect) .
2 . Approx . 30% of our total water supply is pumped from
ground water (reflect) .
3 . $27/A. F . CMWD rate increase to all consumers of imported
water (reflect) .
4 . Net effect is $45/A. F . MWD/CMWD "discount" pass through .
• Defer increase in meter charges (to achieve equity w/M & I)
until years 2 & 3 of MWD program due to "bad timing" (denied) .
WATER & SANITATION SYSTEMS
• Best in the County . Very efficient , considerably newer than
most .
• Water system maximizes economic and emergency use consideration
by continuing to expand development of our groundwater.
• Sanitation plant treating approx 1. 8 MGD . Capacity is 3 . 0 MGD
(roughly accomodates previous General Plan) . Tertiary treatment
Advisory Committee Comments (WW #1)
Page 2
August 17, 1994
addition capacity is 1.5 MGD.
WW #1 ADVISORY COMMITTEE POLICY RECOMMENDATIONS
• System expansion to be paid for by new development.
• Water & sanitation services handled as a utility, provided on
demand — not zoning incentive or growth inducement. City adopts
General Plan; WW #1 plans system to accomodate City authorized
growth & development.
TRANSFER OF RESPONSIBILITIES TO CITY
• Mr. Montgomery advised our Board of Directors, the Board of
Supervisors, that you were presently discussing transfer of
Water & sanitation responsibilities in closed session (7/26/94).
• Previous study identified 3 primary difficulties:
1. City's financial management /accounting system
capabilities inadequate — Presumably resolved.
2. 70% of the WW District boundary must be within
City limits — WW #1 perhaps twice as large as City.
Can be resolved by de- annexing a portion of WW #1,
forming a separate entity. WW #1 A.C. will be
concerned about economic impact and financial
solvency of remainder district.
3. All alternatives cited (7 ?) indicated a resultant
increase in water rates to City customers. Current
advantage is economies of scale and blended rates
involving groundwater. We are restricted to "no
profit" - all charges must equal costs(special district).
0 WW #1 A.C. has gone on record, repeatedly, that we will work
diligently on any future transfer proposal, in the best interests
of all of the district's customers. The City is by far the
largest customer base with approx. 9,000 meters and we are
keenly aware of our need to represent these customers.
RATE COMPARISONS
• 3rd lowest of 11 water purveyors in Ventura County, and 3rd
lowest of 12 sanitation system providers in Ventura County.
Water rates for baseline 35 NCF, average bi- monthly billing,
are lower than cities of Simi Valley, Thousand Oaks and
Camarillo.
AGRICULTURAL INCENTIVES
• Most people support justifiable offsets in Ag. water rates on
the basis of... "either assist in food & fiber production in all
Possible ways, or pay increased prices at the market." Some
support because Ag. is "nice to look at."
• Ag. is the # 1 industry in Ventura County and provides its
highest economic output.
• Moorpark's General Plan restricts considerable acreage to
Open Space and agriculture, perhaps half of its total land
Advisory Committee Comments (WW #1)
Page 3
August 17, 1994
area.
• Based upon City "sincerity" with respect to Ag. preservation in
prime Ag. areas, and City desire to preserve open space separation
between cities, Ag. water incentives are required. Otherwise the
land will be converted and developed. You can't have it both
ways.
John W. Newton,
Bart Miller
David Schwabauer
Wayne Jones
Sam Asadurian
Chair CITY RESIDENT
CITY RESIDENT
UNINC. AREA RESIDENT
CITY RESIDENT
CITY RESIDENT
AVERAGE BI-MqXTwTv BILLING (35 HCF)
Camrosa Water (Camarillo)
$48.96
City of Oxnard
49.95
VCWWD No. 1 (Moorpark)
54.43
VCWWD No. 19 (Somis)
56.20
City of Simi Valley
58-98
City of Camarillo
59.34
City of Ventura
61.29
VCWWD No. 17 (Bell Canyon)
70.48
City of Thousand Oaks
71.30
Lake Sherwood CSD
72.82
Cal - American (Westlake & T.O.)
91.67
BIKOWMY SEW SR SBRVICB CMM(;ZS
(Single Family Residential)
Camrosa Water District
City of Thousand Oaks
VCWWD No. 1
City of Simi Valley
City of Camarillo
Triunfo County Sanitation
VCWWD No. 16
City of Oxnard
City of Ventura
Ojai Valley Sanitation
North Coast (CSA 29)
Nyeland Acres (CSA 30)
(6/93)
C: \WPS1 \DISTRICT \SMRRT.DOC
$18.46
21.00 (City)
22.05 (County area)
25.00
26.94
32.50
37.00
39.80
41.72
42.06 (Depends on winter
water usage: 17+
HCF)
44.26 (County area)
48.52 (City)
61.60
74.20
RECEIVED
JUN 15 1994
PWAIWATER & SANITATION Prepared June 9, 1994
Number 8
MWD
METROPOLITAN WATER DISTRICT OFSOUTHERN CALIFORNIA
WATER SUPPLY UPDATE
PUBLISHED MONTHLY BY THE OPERATIONS DIVISION
SUMMARY
To date, Metropolitan has turned back 100,000 acre -feet of water to the State. Thus, Metropolitan's total water supply for 1994 is approximately
2.19 MAF. This is comprised of 1.25 MAF of Colorado River water and 0.94 MAF of State Project water. Demands are anticipated to be as high
as 2.10 MAF and as low as 1.60 MAF. The current track for demands is 2.04 MAF. This includes projected deliveries under the Cooperative
Storage Program (CSP), which amounts to approximately 91,000 acre -feet. Deliveries under CSP for the month of May were about 22,000
acre -feet. Total sales for May were approximately 166,000 acre -feet. This will be the last update for this water year.
CALENDAR YEAR 1994 MIND DIVERsIONs CALENDAR
SWP i
f
MAY Actual Deliveries
CRW
i
JUNE SWP Available for
CRW
Delivery,
N ...'
0 0.5 1.0 1.5 2.0 2.5
HUNDRED THOUSAND- ACRE -FEET
rn
WATERSHED RUNOFF cnNnrriuc
SWP
SACRAMENTO t I
RIVER
INDEX
CRW T } I
LAKE POWELL
APR -JUL
INFLOW I
FORECAST
0 5 10 15 20 25
MILLION ACRE -FEET
LAKE OROVILLE
SAN LUIS RESERVOIR
EAST BRANCH
WEST BRANCH
LAKE MATHEWS AND
LAKE SKINNER
COMBINED LAKE MEAD
i LAKE POWELL STORAGE
I
YEAR 1994 SUPPLIES
1994 PROJECTED DEMANDS BY MIND MEMBER ar,FNC1Fc
BELOW NORMAL
CURRENT TRACK 2.04
ABOVE NORMAL 0-00*
0 0.5 1.0 1.5 2.0 2.5
MILLION- ACRE -FEET
. v . vnwvc
1.0 z.0 2.5 3.0
MILLION ACRE -FEET
M 50.5
6 10 15 20 26 30 35 40 45 50
♦ CAPACITY
MILLION ACRE -FEET
3.5
3.5