State of California
AIR RESOURCES BOARD

State Building
Room 1138 (Auditorium)
107 South Broadway
Los Angeles, CA

January 30 and 31, 1980
10:00 a.m.

AGENDA

Page

80-1-1 Public Hearing to Consider Amendments to Rule 001
475.1 of the South Coast Air Quality Management
District and to Rule 59.1 of the Ventura County
Air Pollution Control District which Control the
Emissions of Oxides of Nitrogen from Power Plants.

80-1-2 Continuation of Public Hearing to Consider 173
Adoption of Regulations Establishing Procedures
for State Board Review of Executive Officer Actions
Pursuant to Health and Safety Code Section 41561,
Amending Section 60004, Title 17, California
Administrative Code, Regarding Testimony at Hearings
and Clarifying the Effect of State Board Adoption of
Regulations for Local Districts.

80-1-3 Other Business
a. Research Proposals 215
b. Delegations to Executive Officer
c. Executive Session
Personnel
Litigation

January 31, 1980

80-2-1 Discussion of possible overcharges for anti-smog
control devices for vehicles sold in California.

80-2-2 Continuation of item 80-1-1 (above).

ITEM NO.: 80-1-1

Public Hearing to Consider Amendments to Rule 475.1 of the South
Coast Air Quality Management District and to Rule 59.1 of the
Ventura County Air Pollution Control District which Control the
Emissions of Oxides of Nitrogen from Power Plants.

SUMMARY

Rule 475.1 of the South Coast Air Quality Management district and
Rule 59.1 of the Ventura County Air Pollution Control District
are complementary rules in that they contain similar provisions
for the control of emissions of oxides of nitrogen from electric
power plants in their respective districts. These two rules are
necessary because Southern California Edison has power plants in
both districts and because emissions of oxides of nitrogen from
power plants in each district impact air quality in both
districts. As these rules are now written their principal
requirements are:

1. A 50% reduction in emissions of oxides of nitrogen by
December 31, 1982 and a 90% reduction of emissions of oxides
of nitrogen by January 1, 1990;

2. The use (and removing) of electrical generating units in the
system in the order of their rate of emissions of oxides of
nitrogen, the least NOx emitting units being used first
(this system is known as least NOx dispatch);

3. The demonstration of 90% reduction of oxides of nitrogen
emissions on a unit of at least 100 megawatts capacity by
January 1, 1982;

4. The Executive Officer of the South Coast Air Quality
Management District and the Air Resources Board to evaluate
the results of the demonstration unit in 1982 and to relieve
utilities of the requirement for 90% reduction of the
results indicate lack of feasibility, and

5. The concurrence of the Executive Officer of the Air
Resources Board with decisions of the Executive Officer of
the South Coast Air Quality Management District and the Air
Pollution Control Officer of the Ventura County Air
Pollution Control District.

The rules allow the utilities to achieve the required level of
NOx control on a system-wide basis rather than on each individual
generating unit, thereby facilitating the use of the least costly
method of reduction of emissions. However, compliance plans of
the utilities would have to show the level to which emissions
would be reduced on each individual unit and a utility would have
to keep emissions from each unit at or under those levels.

Following a remand by the Air Resources Board to the South Coast
Air Quality Management District that gave the District authority
to make limited changes to Rule 475.1, the staffs of the ARB, the
SCAQMD, the VCAPCD and the affected utilities have held a series
of meetings and workshops to discuss possible Rule changes.
Based on the information gathered at these meetings and
workhshops, the ARB staff has concluded that the 90% emission
reduction required by Rules 475.1 and 59.1 can be achieved even
earlier than the 1990 compliance date established by the Board.
The rate of progress in the development and commercialization of
selective catalytic reduction technology has been greater than
the staff had anticipated and the significance of the 90%
reduction demonstration unit has been substantially reduced. It
does appear, however, that the less stringent Stage I NOx
reduction requirements may not be achieved unless they are
relaxed somewhat, the compliance schedule is substantially
extended or some combination of relaxation of Stage I
requirements and schedule extension is adopted. It should be
noted that this conclusion regarding the need for amendments to
the Stage I requirements is based on the assumption that the
utilities subject to the rule do not have adequate reserve
capacity to shut down power plants for emission control
installation except during regularly scheduled overhauls. As
noted later in this report, this assumption is likely to be over
conservative, especially in the case of Southern California
Edison. However, the potential for retrofit during unscheduled
outages could not be clearly established by the staff.

Because of the staff's findings, amendments to Rules 475.1 and
59.1 incorporating the following main features would be
desirable:

1. Provision of two options for reducing emissions of oxides of
nitrogen. One option would require that such emissions be
reduced by somewhat less than 50% by December 31, 1983, and
by 90% by January 1, 1990; the other option would require
that such emissions be reduced by appreciably less than 50%
by December 31, 1983, and by 90% by January 1, 1988.

2. Provision for higher allowable emissions from an electrical
generating unit than are shown in a utility's compliance
plan if the utility makes specified efforts to reduce
emissions to the levels required in the plan and can only
achieve a higher emission level, if the utility accelerates
the installation of equipment to reduce emissions by 90% on
units on which the planned reductions for Stage I compliance
could not be made.

3. Restriction of the action of the Executive Officer or Air
Pollution Control Officer at the end of the evaluation of
the demonstration unit to relaxation of the requirement of
90% reduction to a lower reduction but would not allow
relief from the requirement of further reduction.

4. Reorganization and change in the language of the rule for
the purpose of clarification.

Air Resources Board action is necessary because the scope of the
proposed amendments is beyond the authority remanded to the South
Coast Air Quality Management District by the Board's decision of
January 23, 1979.