BOARD MEETING DATE: December 5, 2003 AGENDA NO. 31

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 Board approved a new format, process, and procedures for updating the AQMD’s BACT Guidelines. On October 20, 2000, the Board approved an amendment to the NSR regulations to bifurcate the BACT requirements into federal LAER/BACT for major polluting facilities and minor source BACT (MSBACT) for non-major polluting facilities. As a result of that amendment, Parts A and B of the BACT Guidelines now assist staff and the public to determine LAER/BACT for major polluting facilities, and Parts C and D are for non-major polluting facilities. Parts C and D are also referred to as minor source BACT (MSBACT).

On December 15, 2000, the Board changed the reporting frequency for updates to the BACT Guidelines from quarterly to semi-annually. This is the second semi-annual progress report for the year 2003 and covers the six months since the previous (June 6, 2003) progress report.

In addition to the usual reporting of the new LAER/BACT determinations for major polluting facilities, staff is also proposing amendments to Parts C and D. These proposed amendments update the MSBACT guidelines in two regards: (1) update the MSBACT cost-effectiveness criteria in Part C for inflation and (2) update the MSBACT technology guidelines in Part D to cross reference to rules that, through recent amendments, have become more stringent than the current MSBACT guidelines.

This work has been carried out 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.

New and Updated Listings, Part B of the BACT Guidelines - LAER/BACT Determinations for Major Polluting Facilities

Part B of the BACT Guidelines consists of three sections: Section I contains listings of LAER/BACT determinations made by AQMD, Section II contains listings of LAER/BACT determinations for equipment in other air districts, and Section III contains listings of emerging control technologies.

Since the last report to the board, fourteen (14) new listings have been added to Sections I and II: ten (10) to Section I, and four (4) to Section II. Copies of the new listings are attached.

The ten new Section I listings are in the following categories of equipment: Aluminum Melting Furnace, Boiler, Dryer or Oven, Fluidized Catalytic Cracking Unit, Gas Turbine, I.C. Engine-Emergency, I.C. Engine-Stationary (Non-Emergency), Polyester Resin Operation (2), and Tunnel Washer.

The new listing for an Aluminum Melting Furnace documents a low-NOx burner that also conserves fuel. This burner achieves NOx mass emissions that are equivalent to other low-NOx burners that have already been established as achieved-in-practice LAER/BACT for this equipment category, while also reducing fuel consumption by 30 to 40%.

The new Boiler listing is another example of an ultra low-NOx burner meeting AQMD’s 12 ppm NOx BACT guideline for boilers rated at less than 20 MMBtu/hr. The ultra low-NOx burner used in this case was developed by the Gas Technology Institute with partial funding from the Southern California Gas Company.

The new listing in the Dryer or Oven category is another example of low-NOx burner technology meeting AQMD’s BACT guideline of 30 ppm NOx for this equipment category. This is an example of a powder coating curing oven meeting the limit.

The Fluidized Catalytic Cracking Unit (FCCU) listing establishes selective catalytic reduction (SCR) achieving more than 90% NOx control as achieved-in-practice LAER/BACT for this equipment category. FCCUs are major NOx sources in virtually all refineries. This represents the first proven application of this technology to an FCCU in the U.S., and thus may be of nationwide significance.

The new listing in the Gas Turbine category is an example of a combined cycle gas turbine power plant fired on digester gas meeting the BACT limit of 25 ppm NOx using water injection. This permit also established a lower CO limit (60 ppm) as LAER/BACT for a gas turbine operated on digester gas.

The new listing in the I.C. Engine-Emergency, category is the first example of an AQMD permit requiring a diesel particulate filter on an emergency diesel engine and establishes this technology as achieved-in-practice LAER/BACT for this equipment category.

The new listing in the I.C. Engine-Stationary (Non-Emergency) category is an example of a stationary engine firing waste gas from an oil well achieving AQMD’s NOx, CO and VOC BACT limits.

Two new listings in the Polyester Resin Operation equipment category document two VOC control technologies, achieving 85% and 90% control, respectively, as achieved-in-practice LAER/BACT for this equipment category. Polyester resin operations include the numerous facilities that manufacture fiberglass-resin reinforced plastic products such as tubs/showers, spas, boats, etc. These sources are usually significant VOC and hazardous air pollutant emitters and have heretofore not been controlled with add-on control devices.

The new Tunnel Washer listing establishes a new equipment category in the Part B LAER/BACT listings. Tunnel washers are large commercial washing machines. This listing applies to a tunnel washer being used to strip solvents from dirty textiles such as shop towels. It establishes VOC control technology achieving 90% overall control as achieved-in-practice LAER/BACT for this equipment category.

The four new Section II listings are in the following equipment categories: Flow Coater (2), I.C. Engine-Emergency, and I.C. Engine-Stationary (Non-Emergency).

The two new Flow Coater listings document BACT determinations by the San Joaquin Valley Unified APCD (SJUAPCD). These BACT determinations were based on available technologies for controlling VOC emissions from flow coaters used to apply coatings to three-part cans (e.g., food cans). One applies to application of the internal coating and requires 95% control. The other was for application of exterior coatings and required use of UV-curable coating materials, which emit virtually no VOCs.

The new listing in the I.C. Engine-Emergency category is another BACT determination by the SJVUAPCD. This determination was based on an existing BACT guideline, which required use of a diesel particulate filter and ultra low-sulfur diesel fuel (maximum of .0015 wt.% sulfur).

The new listing in the I.C. Engine-Stationary (Non-Emergency) category is based on a BACT determination made by the Tehama County APCD. In this determination, a set of engines rated at 3870 BHP each were required to meet 9 ppm NOx and 56 ppm CO (CARB’s permitting guidance for distributed generation). These limits are more stringent than AQMD’s existing NOx and CO BACT guidelines for engines in this class.

Proposed Amendment of Part C of the BACT Guidelines, Policies and Procedures for Non-Major Polluting Facilities

To change Part D, BACT Guidelines for Non-Major Polluting Facilities, in a manner requiring more stringent pollution control, it must be shown that the cost effectiveness of the proposed change in terms of cost of control per ton of pollutant controlled is less than certain pollutant-specific cost effectiveness criteria. Those criteria are listed in Part C. They were last updated in 2000 based on a 1999 cost index. It is proposed that they be updated again to reflect cost increases that have occurred since 1999, based on the Marshall & Swift Equipment Cost Index, which is published monthly in Chemical Engineering.

Proposed Amendment of Part D of the BACT Guidelines, BACT Guidelines for Non-Major Polluting Facilities

Since the last update of Part D of the BACT Guidelines, several of AQMD’s Regulation XI equipment-specific rules have been amended with more stringent requirements, making them more stringent than the earlier BACT Part D requirements for the corresponding equipment categories. Staff proposes that the Part D Guidelines for these equipment categories be updated to remove outdated requirements and cross-reference to rules that have become more stringent than Part D BACT. This action is consistent with the principle that all equipment must comply with AQMD rule requirements, even if the BACT Guidelines have not yet been updated to reflect those requirements. Therefore, BACT will always include, at minimum, the requirements of applicable AQMD rules.

The proposed amendments to Part D are attached. Eight existing equipment categories are affected, and it is proposed that four new equipment categories be added. The eight existing equipment categories that are affected will be discussed first, followed by a presentation of the four new equipment categories.

Fugitive Emission Sources at Bulk Terminals, Natural Gas Plants and Oil and Gas Production Fields—Rule 1173, Control of Volatile Organic Compound Leaks and Releases from Components at Petroleum Facilities and Chemical Plants, inspection and maintenance (I&M) requirements for natural gas plants and oil and gas production fields have become more stringent in some regards than the Part D guidelines for these types of facilities. However, bulk terminals are not affected by the rule. Therefore, it is proposed that this equipment category be divided into two equipment categories: (1) Fugitive Emission Sources at Bulk Loading Terminals and (2) Fugitive Emission Sources at Natural Gas Plants and Oil and Gas Production Fields. The Part D guideline for Fugitive Emission Sources at Bulk Loading Terminals will remain the same, although it is proposed that the name of this category be changed to "Fugitive Emission Sources at Organic Liquid Bulk Loading Facilities" for better clarity. The guideline for Fugitive Emissions from Natural Gas Plants and Oil and Gas Production Fields will reference Rule 1173 wherever the I&M requirements in Rule 1173 are more stringent than the existing guideline.

Fugitive Emission Sources, Other Facilities—Rule 1173 I&M requirements have become more stringent than the Part D guideline for this equipment category. It is therefore proposed that the guideline reference Rule 1173 wherever the I&M requirements in Rule 1173 are more stringent than the existing guideline.

Lithographic, Flexographic, Rotogravure and Screen Printing—These four types of printing presently comprise four separate equipment categories. VOC control requirements in Rule 1171, Solvent Cleaning Operations, have become more stringent than the corresponding Part D guidelines for several of these types of printing. It is therefore proposed that Rule 1171 be referenced in each of these equipment categories wherever it is more stringent than the existing guideline. Also, several additional "housekeeping" changes are proposed to improve the organization, clarity and utility of these guidelines:

Reactor with Atmospheric Vent—It is proposed that this equipment category cross-reference to two of the new equipment categories that are presented below, "Resin Manufacturing" and "Surfactant Manufacturing". Processes in these categories are likely to contain reactors with atmospheric vents, and the BACT guidelines for these categories include requirements that may be more stringent than those in "Reactor with Atmospheric Vent".

Water Treating – Oil/Water Separator—Since drafting of this guideline in 1988, Rule 1176, Sumps and Wastewater Separators, has been amended with more stringent VOC control requirements for wastewater systems, which include Oil/Water Separators and also Process Drains. Process Drains is presently a sub-category under Fugitive Emission Sources at Bulk Terminals, Natural Gas Plants and Oil and Gas Production Fields. It is proposed that this equipment category be replaced with, "Wastewater Systems", and have two sub-categories: (1) Oil/Water Separator and (2) Other Equipment, with both sub-categories referencing Rule 1176. It is also proposed that sub-category Process Drains be removed from Fugitive Emission Sources at Bulk Terminals, Natural Gas Plants and Oil and Gas Production Fields since it will now be covered under Wastewater Systems, Other Equipment.

The four new equipment categories to be added and the rule to which each will refer are as follows:

Co-Composting	Rule 1133.2
Resin Manufacturing	Rule 1141
Surfactant Manufacturing	Rule 1141.2
Woodworking	Rule 1137

This report fulfills staff’s obligation to report semi-annually to the Board on changes that have occurred in Part B of the BACT Guidelines. Those changes have been made and are available at the AQMD website at http://www.aqmd.gov/bact.

Staff recommends that the Board approve the proposed amendments to Parts C and D.

All of the new listings and guideline amendments have been reviewed by the BACT SRC. 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.

New Part B LAER/BACT Listings
Proposed Part C Amendment
Proposed Part D Amendments