BOARD MEETING DATE: December 3, 2004
AGENDA NO. 27
Best Available Control Technology Guidelines Report and Amendments
SYNOPSIS:
Semiannually, staff reports new listings added to the BACT Guidelines in the last six months in Part B, LAER/BACT Determinations for Major Polluting Facilities. Staff is also proposing several minor amendments to Part D, BACT Guidelines for Non-Major Polluting Facilities.
COMMITTEE:
Stationary Source, October 22, 2004, Reviewed
RECOMMENDED ACTIONS:
- Receive and file updates to BACT Guidelines, Part B.
- Approve proposed amendments to Part D of the BACT Guidelines.
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 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).
This is the second semi-annual progress report for the year 2004 and covers progress made since the previous (July 9, 2004) progress report.
In addition to the usual reporting of the new LAER/BACT determinations for major polluting facilities, staff is proposing several minor amendments to Part D, BACT Guidelines for Non-Major Polluting Facilities.
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, seven new listings have been added to Sections I and II -- five to Section I and two to Section II. Also, two existing listings have been updated with new information – one in Section I and one in Section II. Copies of the new and updated listings are attached.
Section I – AQMD LAER/BACT Determinations
The five new Section I listings are in the following categories of equipment: Boiler; Catalyst Regeneration-Fluidized Catalytic Cracking Unit; Dryer or Oven; I.C. Engine-Stationary, Non-Emergency; and Process Heater-Non-Refinery. The one Section I listing that was updated was in the I.C. Engine-Stationary, Non-Emergency category.
The new Boiler listing is an example of a boiler rated >20 MMBtu/hr meeting the AQMD MSBACT guideline for boilers in this size class without the use of selective catalytic reduction (SCR). Meeting the guideline without using SCR is desirable because SCR causes secondary emissions of ammonia. Four identical boilers rated at 39 MMBtu/hr, which are in RECLAIM, were retrofitted with low-NOx burners and flue gas recirculation. A source test showed the boilers to meet the 9 ppmvd NOx and 100 ppmvd CO limits, corrected to 3% O2, in the MSBACT guidelines.
The new listing for Catalyst Regeneration-Fluidized Catalytic Cracking Unit (FCCU) is the second example of successful application of SCR to an FCCU in the AQMD. The FCCU is a major unit operation present in essentially all large, modern refineries, and the catalyst regeneration section of this process is generally a major source of NOx and ammonia emissions. Passing the flue gas through an SCR catalyst allows the NOx and ammonia to combine to form nitrogen and water, thus reducing emissions of both pollutants.
The new Dryer or Oven listing is a direct-fired makeup air heater. This type of air heater is used in many spray booth operations. AQMD MSBACT guidelines call for 30 ppmvd NOx, corrected to 3% O2 for ovens and dryers, and an ANSI standard requires CO to be 5 ppmvd or less (uncorrected) if a person works in the booth. A low-NOx burner designed for this type of application was selected, and a source test showed that it clearly meets the MSBACT and ANSI requirements. This is the first documented case of a burner meeting both requirements on this type of air heater.
The new I.C. Engine-Stationary, Non-Emergency listing is unusual in that this non-emergency engine is allowed to use diesel fuel. Diesel was allowed in this case because natural gas cannot be reasonably made available at the site, a ski resort. The engine is required to have SCR, oxidation catalyst and a particulate filter. NOx, CO and VOC limits (ppmvd@15%O2) are 50, 89 and 39, respectively. The CO limit is comparable to what would be required on natural gas fuel, while the NOx and VOC limits are significantly higher.
The new Process Heater-Non-Refinery listing is a large heater used for hydrogen reforming. The LAER/BACT determination for this heater was 5 NOx, 5 CO and 10 ammonia, all as ppmvd@3%O2, which is the most stringent LAER/BACT yet required by the AQMD for this type of heater. Emission control technologies include low-NOx burners, SCR and oxidation catalyst. It is recognized in the listing that the low NOx levels achieved on process heaters used for hydrogen reforming may be partially due to their utilization as fuel of by-product pressure-swing adsorption gas, which contains CO2 diluent.
The I.C. Engine-Stationary, Non-Emergency listing that was updated is a large water pump at an oil field, which operates on field gas. Emission control technologies utilized on this engine include reduction of sulfur in the fuel down to about 10 ppm and rich-burn engine technology with an air/fuel ratio controller and three-way catalyst to reduce NOx, CO and VOC. NOx, CO and VOC limits are consistent with MSBACT, which requires 0.15, 0.6 and 0.15 g/bhp-hr, respectively. Since it was first listed in July 2003, the engine had been source tested and had accumulated more than a year of operation with NOx being continuously monitored. The listing was updated with this information. It is noted in the listing that CO2 diluent present in the field gas may be partly responsible for the low emissions achieved on this engine.
Section II – Other LAER/BACT Determinations
The two new Section II listings are in the following equipment categories: Flare-Landfill Gas from Non-Hazardous Waste Landfill and I.C. Engine-Landfill Gas-Fired. The one Section II listing that was updated was in the I.C. Engine-Stationary, Non-Emergency category.
The new Flare-Landfill Gas from Non-Hazardous Waste Landfill listing is an enclosed ground flare, which is the type commonly used on landfills. San Joaquin Valley Unified APCD’s LAER/BACT determination for this flare was 0.048 lb/MMBtu NOx and 0.038 lb/MMBtu VOC as hexane, both of which are more stringent limits than previous AQMD LAER/BACT guidelines or Rule 1150.1.
The new I.C. Engine-Landfill Gas-Fired listing is a 4,231 bhp lean-burn engine driving a generator on a landfill. Emission control is achieved through engine design factors including a turbocharger, intercooled induction air system, air/fuel ratio controller and spark timing/duration controls. NOx and VOC limits are 0.53 and 0.216 g/bhp-hr, respectively, which are more stringent than previous AQMD LAER/BACT guidelines. It is noted in the listing that engines capable of achieving these emission limits may not be available in all sizes.
The I.C. Engine-Stationary, Non-Emergency listing that was updated is based on 16 large natural gas-fired engines used for peaking power production. These engines were originally listed in Part B in September 2003 and provided the basis for more stringent MSBACT for large (>2064 bhp) non-emergency engines, which was adopted June 4, 2004. Due to its importance, this case is being followed, and was updated with the results of the third annual source test at the May 2004 SRC meeting.
Proposed Amendments to Part D of the BACT Guidelines - BACT Guidelines for Non-Major Polluting Facilities
Staff is proposing the following minor amendments to Part D, BACT Guidelines for Non-Major Polluting Facilities (MSBACT). The proposed amended guidelines are attached.
In the guidelines for Gas Turbine, Natural Gas Fired, >3 MW and <50 MW and Gas Turbine, Natural Gas Fired, >50 MW, the NOx limits are multiplied by the turbine efficiency, based on the higher heating value of the fuel, divided by 34%. Staff has found that it was the original intent to limit the efficiency multiplier to a minimum value of 1.0. Staff therefore proposes that this guideline be amended to correct this error.
In the guideline for I.C. Engine, Portable, Compression Ignition, staff proposes to correct a typographical error in the bottom-left cell in the table of California and federal standards --"750 HP" should read ">750 HP".
Rule 1470 – Requirements for Stationary Diesel-Fueled Internal Combustion and Other Compression Ignition Engines, adopted April 2, 2004, implements CARB’s Air Toxics Control Measure, which restricts PM10 emissions from diesel engines. In some cases, depending on the size and location of the engine, Rule 1470 may be more stringent than MSBACT. Staff therefore proposes that the PM10 guidelines for I.C. Engine, Stationary, Emergency and I.C. Engine, Stationary, Non-Emergency be amended to also require compliance with Rule 1470.
Conclusion and Recommendation
This report fulfills the Board’s direction to staff 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 Part 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/Updated Part B LAER/BACT Listings
Part D Amendments
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