BOARD MEETING DATE: March 17, 2000 AGENDA NO. 32




PROPOSAL: 

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, which is available on the AQMD website.

COMMITTEE: 

Stationary Source, February 25, 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 has added nineteen new BACT listings to Part B of the BACT Guidelines. This work has been in coordination with the BACT Scientific Review Committee (SRC), 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) Dryer/Oven – Others, Direct and Indirect Fired, (3) Heater – Other Process*, (4) I.C. Engine – Emergency, Compression Ignition, (5) I.C. Engine – Stationary, Non-Emergency, (6) I.C. Engine – Fire Pump, Spark Ignition*, (7) Mixer/Blender – Wet, and (8) Polyurethane Tube Manufacturing*.

The boilers (four examples are attached) will use selective catalytic reduction (SCR) or ultra low-NOx burners to achieve very low NOx emissions. The larger boilers (> 20 MMbtu/hr) will be vented to SCR equipment, and the NOx and ammonia emission limits (specified in each permit) are 7 ppmvd and 5 ppmvd, respectively, at 3% oxygen. The smaller boilers (< 20 MMbtu/hr) will utilize ultra low-NOx burners, and the NOx emission limit (specified in each permit) is 12 ppmvd, at 3% oxygen. Two of the projects went through a 30-day public notice and comment period because they were more stringent than previous BACT determinations. No public comments were received.

Following review by the SRC and the close of public comment periods, several questions were raised by interested parties regarding the level of information and the process used by AQMD permitting staff to set the BACT emission standards listed above. In particular, staff has been requested to provide detailed information on how various permitting decisions, e.g., 7 ppm NOx for large boilers or 12 ppm for small boiler were analyzed. Staff is working on this information request and hopes to present the additional technical information to the interested parties and the SRC, prior to including it in a future revision of these permit listings. However, in the meantime, staff believes that the listed information is typical of recently permitted equipment and provides guidance to permit applicants and permitting engineers, as required by AQMD rules and Board directives.

The conveyorized, direct fired oven (one example is attached) is used to cure powder coatings, and the BACT requirement for NOx emissions is < 30 ppmvd, at 3% oxygen with a low-NOx burner.

The thermal fluid heater (one example is attached) is used to regenerate a liquid absorbent, and the BACT requirement for NOx emissions is < 20 ppmvd, at 3% oxygen with a low-NOx burner.

The emergency, compression ignition engines (four examples are attached) will use diesel fuel and the NOx and PM10 emissions will be below 6.9 and 0.38 grams/bhp-hr, respectively. The engines will achieve low emissions without using add-on controls.

The stationary, non-emergency engines (two examples are attached) are fueled with natural gas, and the BACT requirement is NOx, VOC, and CO emissions < 0.15, 0.15, and 0.60 grams/bhp-hr, respectively. The emissions are controlled by a 3-way catalyst and air/fuel ratio controller.

The spark ignited, fire pump engine (one example is attached) is fueled with gasoline and the NOx, VOC, and CO emissions are < 0.15, 0.15, and 0.60 gram/bhp-hr, respectively. The emissions are controlled by a 3-way catalyst and air/fuel ratio controller.

The mixing tank (one example is attached) is used to blend hair care products, and the BACT requirement is venting the emissions to a VOC control device, in this case a carbon adsorption system.

* new equipment category

The polyurethane tube manufacturing equipment (one example is attached) is used to produce medical devices, and the BACT requirement is venting the emissions to a VOC control device, in this case a carbon adsorption system.

Section 2 - Non-AQMD LAER/BACT Determinations

Attached is a BACT listing for a gas turbine that will be operated in McKittrick, California. The permits were issued by the San Joaquin Valley Unified Air Pollution Control District and the California Energy Commission.

The equipment will either be controlled by a SCO-NOx system or by SCR and an oxidation catalyst. The BACT requirements are typical of the many natural gas-fired, gas turbine, power plant projects proceeding through the certification process in California. BACT concentration limits are 2.5 ppmvd for NOx, 6 ppmvd for CO (above 221 MW) and 10 ppmvd for NH3.

Section 3 – Other Technologies

Attached are three BACT listings for relatively small boilers (< 20 MMbtu/hr) that will use selective catalytic reduction (SCR) or ultra low-NOx burners to achieve very low NOx emissions. The boilers are listed in Section III because the applicants requested permit limits that are below current achieved in practice BACT levels for small boilers. The applicants requested the low permit limits in order to avoid emission offsets requirements.

These emission standards are not considered to be achieved in practice since they have not yet been demonstrated. In addition, emission limits may be adjusted in view of source test results and other operational experience with these technologies. Due to the evolving nature of new and emerging technology, updates will be listed on the website and presented to the SRC as they are encountered. It is important to note that these emission standards cannot yet be specified as BACT in new source permits until they are demonstrated.

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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