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Best Available Control Technology Guidelines Report

SYNOPSIS: 

This quarterly report provides the new BACT determinations/listings that were added to the BACT Guidelines Part B - Clearinghouse in the last quarter. The listings are currently available on the AQMD’s BACT website.

COMMITTEE: 

Stationary Source, May 26, 2000, Reviewed

RECOMMENDED ACTIONS:

Receive and file.

Barry R. Wallerstein, D.Env.
Executive Officer

Background

AQMD's New Source Review (NSR) regulations require applicants to use Best Available Control Technology (BACT) for new sources, relocated sources, and for modifications that increase emissions. Regulation XIII – New Source Review also requires the Executive Officer to periodically publish BACT Guidelines for commonly permitted equipment. On December 11, 1998, the Governing Board approved a new format, process, and procedures for updating the AQMD’s BACT Guidelines. The Board also directed staff to report back on progress made, on a quarterly basis.

Part B - BACT Determinations

Staff added nine new BACT listings to Part B of the BACT Guidelines since the last quarterly report. This work has been in coordination with the BACT Scientific Review Committee (SRC). The SRC is a technical group whose membership includes industry, environmental groups, CARB, and U.S. EPA. The purpose of the new listings is to provide information to permit applicants and permitting staff regarding recent BACT determinations.

Section 1 - AQMD BACT Determinations

Attached are new BACT determinations for the following categories of equipment:
(1) Boiler, (2) Boiler - Portable, and (3) I.C. Engine – Emergency, Spark Ignition. Also attached, is a revised BACT determination for a CO2 Plant.

The boilers (four examples are attached) are equipped with ultra-low-NOx burners (ULNB) in order to comply with the BACT emission limits. The NOx limit for the small boilers (< 20 MMbtu/hour) is 12 ppmvd at 3% oxygen, and the NOx limit for the larger boilers (when ULNBs are used) is 9 ppmvd at 3% oxygen. The attached BACT determinations are consistent with previous boiler BACT determinations.

The emergency, spark ignition engine (one example is attached) will use natural gas fuel and the NOx, VOC, and CO emission limits (in grams/bhp-hr) are 1.5, 1.5, and 2.0, respectively. Compliance with these emission limits will be achieved using a 3-way catalytic converter and air/fuel ratio controller.

A revised BACT determination for a CO2 plant is attached. The BACT determination was revised as a result of the public comment process. A public notice of intent to establish new, more stringent BACT (for the subject CO2 plant) was distributed in November 1999 which required the use of an add-on control device. Comments were submitted to the AQMD staff during the subsequent 30-day public comment period (which is required for new and more stringent BACT determinations). Based on a detailed review of the comments and after meeting with the applicant, staff revised the permit limit for VOC emissions to 0.72 pounds/hour and 10 pounds/day (from 1 pound/day). These emission limits can be achieved without additional add-on controls (i.e., a thermal oxidizer).

Section 2 - Non-AQMD LAER/BACT Determinations

Attached is a BACT listing for a boiler that will be operated in McKittrick, California. The San Joaquin Valley Air Pollution Control District (SJVAPCD) issued the permit. The boiler will be equipped with an ULNB and the permit limit for NOx is 12 ppmvd at 3% oxygen, and the permit limit for CO is 50 ppmvd at 3% oxygen. This is the second boiler permit issued with these BACT levels by SJVAPCD.

Section 3 – Other Technologies

Attached are two BACT listings for a printing facility in Rancho Dominquez, California. The listings are for a lithographic printing press and a silk screen press. The applicant is using low-VOC UV curable inks that are considered "super clean" materials. In addition, the lithographic printing press uses low-VOC fountain solution and low-VOC clean-up solvent. The equipment is listed in Section III because the applicant volunteered to use UV curable inks whose emissions are lower than BACT emission levels.

Public Comments on the BACT Process

Staff has recently been requested to enhance the involvement of the SRC in the review and discussion of new emission limits that qualify for BACT for new source permits. Staff is supportive of this request and is bringing this matter to the SRC for further discussion regarding process and reporting format. In the interim, a discussion has been included for informational purposes, based on the public request, of recent small boiler BACT determinations. Several other issues regarding technology transfer and achieved in practice criteria are being discussed with the affected public, SRC, CARB and U.S. EPA and appropriate revisions to AQMD rules or policies will be proposed as these developments are concluded.

A few SRC members and interested members of the public have expressed concern that the recent staff BACT determinations for small boilers may be inconsistent with AQMD rules and policies. In particular, they have disagreed that a permit issued for a small boiler by San Joaquin Valley Air Pollution Control District (SJVAPCD) and listed in U.S. EPA’s RACT/BACT/LAER Clearinghouse and the AQMD BACT Guidelines was an adequate basis for a small boiler BACT determination of 12 ppm NOx. Staff believes that this boiler does represent a valid example of an emission limit that has been achieved in practice consistent with U.S. EPA’s LAER policy, and represents BACT for similar equipment, unless it is demonstrated to be infeasible in specific permitting situations. This finding is based on discussions about this equipment’s operation with the SJVAPCD staff and review of source test data taken during 1997 and 1999 showing compliance with the 12 ppm NOx permit limit. The AQMD BACT Guidelines now list seven examples of permits recently issued with a 12 ppm NOx limit for small boilers or 7 ppm (with add-on controls) or 9 ppm (with ULNB) NOx limit for large boilers, and source test data and operating history information are being included in these BACT listing as they become available, following SRC review. U.S. EPA and CARB agree that AQMD staff followed appropriate procedures with due diligence in establishing BACT for small boilers.

Conclusion

Staff sincerely extends its appreciation to SRC members and others who assisted in updating the BACT Guidelines. In particular, the commitment of past and present continuing SRC members in the development and review of the attached information is much appreciated. The information in this package is available at the AQMD website at http://www.aqmd.gov/bact.

Attachments

Part B - BACT Listings

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