BOARD MEETING DATE: July 9, 2004
AGENDA NO. 37

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 to amend Part D, BACT Guidelines for Non-Major Polluting Facilities, in two regards: (1) a number of minor updates and (2) an update of the guideline for stationary, non-emergency I.C. engines rated at or above 2064 bhp reflecting new achieved-in-practice technology.

COMMITTEE:

Stationary Source, May 28, 2004, Reviewed

RECOMMENDED ACTIONS:

1. Receive and file updates to BACT Guidelines, Part B.
    
2. 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 first semi-annual progress report for the year 2004 and covers progress made since the previous (December 5, 2003) progress report.

In addition to the usual reporting of the new LAER/BACT determinations for major polluting facilities, staff is proposing to amend Part D, BACT Guidelines for Non-Major Polluting Facilities, in two regards: (1) a number of minor updates and (2) an update of the guideline for stationary, non-emergency I.C. engines rated at or above 2064 bhp reflecting new achieved-in-practice technology

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, sixteen (16) new listings have been added to Sections I, II and III -- fourteen (14) to Section I, one (1) to Section II, and one (1) to Section III. Two of the new Section I listings were previously listed in Section III, and have now been promoted to Section I. Copies of the new and promoted listings are attached.

Section I – AQMD LAER/BACT Determinations
The fourteen new Section I listings are in the following categories of equipment: Air Start Unit, Asphalt Batch Plant, Boiler, Bulk Solids Storage, Concrete Batch Plant, Dryer or Oven, Fiber Impregnation System, Gas Turbine-Combined Cycle (2), Gas Turbine-Simple Cycle, I.C. Engine-Fire Pump (2), Lithographic Printing-Heatset and Spray Booth.

The new Air Start Unit listing creates a new BACT equipment category. Air start units are used at airports to start aircraft engines. They are basically portable or mobile air compressors, which are used to pressurize the aircraft compressed air system, which enables startup of one of the aircraft engines. Air start units are normally powered by diesel engines. This listing documents a unit that is powered by a diesel fueled gas turbine, which operates with significantly lower emissions than a diesel engine and is now achieved in practice. This sets a cleaner BACT standard for air start units.

The new Asphalt Batch Plant listing documents a BACT determination for a new asphalt batch plant based on existing AQMD BACT guidelines plus a lower-NOx combustion method, which is now achieved in practice.

The new Boiler listing is a 225 MW utility boiler, which was brought back into service after being idle for many years. AQMD determined that BACT consisted of low-NOx burners, flue gas recirculation, selective catalytic reduction of NOx and catalytic oxidation of CO with emission limits of 5 ppm NOx, 5 ppm CO and 5 ppm ammonia, all corrected to 3% O2. This sets a stringent new standard for large boilers, which may also apply to large process heaters in many cases.

The Bulk Solids Storage listing documents a BACT determination requiring enclosed storage of aggregate at an asphalt batch plant. This represents important progress relative to the previous practice of open-pile storage and is also applicable to other processes that include aggregate storage, such as concrete batch plants.

The new Concrete Batch Plant listing documents a BACT determination based on existing AQMD BACT guidelines for this equipment category at the time. Enclosed storage of aggregate had not yet been listed.

The new Dryer or Oven listing documents a new tenter frame dryer meeting existing BACT guidelines. The unit had originally been listed with a much lower NOx limit but was listed in Section III pending a source test. Due to uncertainties introduced by high levels of infiltrated air in the dryer exhaust, the source test proved only that the NOx level was at or below the BACT limit. The listing was therefore promoted to Section I as an example of existing NOx BACT being met in practice for this category.

The new Fiber Impregnation listing sets new VOC BACT in this category. The facility volunteered 98% VOC control, which is a permit condition and has now been achieved in practice.

Two new listings in the Gas Turbine-Combined Cycle category document BACT determinations for large combined cycle power plants based on the stringent NOx, VOC and ammonia emission limits that have been demonstrated on a similar plant in Massachusetts together with a still lower CO limit.

The new listing in the Gas Turbine-Simple Cycle category documents a BACT determination based on existing guidelines for all pollutants and a lower NOx limit, which was offered by the applicant.

The two new listings in the I.C. Engine-Fire Pump category both document fire pumps that comply with USEPA Tier 2 Nonroad emission standards. AQMD BACT guidelines require that Tier 2 engines be used for most emergency purposes, where available, but exempt fire pump engines from this requirement, if necessary. These listings show that Tier 2 fire pump engines are available in at least some sizes.

The new listing in the Printing-Lithographic-Heatset category documents a new facility meeting AQMD’s BACT guidelines for this equipment category while also meeting 98.5% VOC control and a NOx limit on a VOC oxidizer. The 98.5% VOC control and oxidizer NOx limit establish more stringent BACT for this category and are now achieved in practice.

The new Spray Booth listing documents use of powder coating as an inherently low-VOC method of coating metal parts, which can be used in many cases.

Section II – Other LAER/BACT Determinations
The new Section II listing is in the following equipment category: Rotogravure Printing. This listing documents BACT determination for a new publication rotogravure facility in West Virginia requiring 98.25% VOC control based on achieved in practice technology.

Section III – Other Technologies
The new Section III listing is in the following two equipment categories: Lithographic Printing-Heatset and Lithographic Printing-Non-Heatset. This listing establishes 98% control of VOC from the heatset ovens and also includes 90% control of all fugitive VOC from the presses by venting the press rooms to a gas turbine whenever the gas turbine is operating. The listing does not mandate control of fugitive VOC in this way but provides applicants information to encourage them to do so.

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

Staff is proposing to amend Part D, BACT Guidelines for Non-Major Polluting Facilities (MSBACT), in two regards: (1) a number of minor updates and (2) an update of the guideline for stationary, non-emergency I.C. engines rated at or above 2064 bhp reflecting new achieved-in-practice technology.

Minor Updates
Staff is proposing amendments to the following equipment categories: Dry Cleaning; Incinerator-Non-Infectious, Non-Hazardous Waste; Pharmaceutical Manufacturing, and Resin Manufacturing. The proposed amendments are attached, and each amendment is summarized and the need for it explained below.

Dry Cleaning:

Subcategory Petroleum Solvent

• Add a reference to Rule 1102, which applies to petroleum solvent dry cleaning.
• Make the requirement for a refrigerated condenser more flexible by allowing use of an evaporatively cooled condenser as an alternative. This reflects current AQMD permitting practice.

Subcategory Valclene

• Delete this subcategory since manufacture of Valclene was banned in 1996, and Valclene dry cleaning is no longer practiced.

Incinerator-Non-Hazardous, Non-Infectious Waste:

• Delete the words "upon final promulgation of the regulation" from the footnote referring to 40CFR60, Subpart CCCC. This regulation has now been promulgated.

Pharmaceutical Manufacturing:

• Add references to AQMD Rule 1103 and the federal NESHAP that also apply to pharmaceutical manufacturing.

Amendment of Guideline for Stationary, Non-Emergency I.C. Engines
Staff proposes to update the MSBACT guideline for stationary, non-emergency I.C. engines, rated at or above 2064 bhp, making it more stringent based on new technology that has been achieved in practice. To make MSBACT more stringent based on achieved-in-practice technology AQMD must follow procedures and satisfy criteria that are delineated in Part C of its BACT Guidelines and also satisfy additional criteria in California Health and Safety Code Section 40440.11. These requirements include showing that the technology has been successfully applied in a commercial setting for at least 12 months, showing that the technology meets AQMD’s average and incremental cost effectiveness criteria, presentation at an SRC meeting, and presentation at a regular meeting of AQMD’s Governing Board.

The proposed amendment of the MSBACT guideline for stationary, non-emergency I.C. engines rated at or above 2064 bhp is shown in Table 1. The proposed amendment lowers the NOx emission limit, adds emission limits for VOC and ammonia, and deletes the PM emission limit. Staff proposes to leave the MSBACT guideline for CO unchanged since the CO limit in the NEO California Power permit is less stringent than the existing MSBACT guideline.

Technical Basis
The proposed amendments for NOx, VOC and ammonia are based on the low emissions achieved on a set of sixteen 3870 hp engines for three years on a commercial operation in Tehama County, California. These engines constitute a peaking power plant, which was installed in 2001 by NEO California Power. In addition to selection of engines designed for low emissions, emission control is achieved by selective catalytic reduction (SCR) of NOx using ammonia and catalytic oxidation of CO and VOC. The plant was permitted at 9 ppmvd NOx, 25 ppmvd VOC and 10 ppmvd ammonia, all corrected to 15% O₂. The plant was shown to be meeting those emission limits by source tests conducted on all engines in October 2001 and on two engines selected by the Tehama County APCD in January 2003. In September 2003, this case was presented to the SRC and was subsequently listed in Part B of the BACT Guidelines (attached). A source test was conducted in February 2004 on two engines selected by Tehama County APCD, and once again the selected engines were found to be meeting the permit limits.

The existing PM emission limit is recommended for deletion because it was not substantiated by a source test consistent with AQMD test methods. PM emissions should be inherently low with clean fuels such as natural gas. Because PM emissions are rarely tested with natural gas-fired engines, there are not adequate data to establish a PM emission limit.

Cost Effectiveness
Staff has evaluated two control options: the existing MSBACT emission limits and the emission limits applied to the NEO California engines. The emission control technology used on the NEO power plant engines, SCR plus oxidation catalyst, is the same as is currently used on engines in this size range to meet AQMD’s current MSBACT emission limits. However, to meet the proposed new NOx guideline, additional SCR catalyst is needed and usage of injected ammonia (or urea) will increase. Additional oxidation catalyst, which controls both CO and VOC, should not be needed since meeting the current 33 ppm MSBACT guideline for CO is generally a more stringent requirement than meeting the proposed 25 ppm VOC guideline in that CO concentrations produced by this type of engine tend to be substantially higher than VOC concentrations produced. Meeting the proposed 10 ppm guideline for ammonia also should not involve additional cost since this limit is commonly met by SCR systems.

Cost information was obtained from the vendor who supplied the emission control system used on the NEO California Power plant. The cost effectiveness calculations and results for control to 9 ppm are summarized in Table 2. They meet AQMD’s average and incremental cost effectiveness criteria for amending MSBACT.

Presentation to Scientific Review Committee
The proposed MSBACT amendment was presented to the SRC at the January 2003 meeting. Prior to the meeting the meeting package was distributed to the committee and AQMD’s list of other interested parties. Committee members had several comments and suggestions, but no issues were raised suggesting that the proposed amendment should not proceed. No comments were received following the meeting or at the next (March 25, 2004) meeting.

Proposal
Staff proposes to update the MSBACT guideline for stationary, non-emergency I.C. engines rated at or above 2064 bhp as shown in Table 1.

Compliance with Requirements for Updating MSBACT
In developing the proposed amendment to the MSBACT Guideline for stationary, non-emergency I.C. engines rated at or above 2064 bhp, staff has followed the process and criteria required by Part C, Policies and Procedures for Non-Major Polluting Facilities, of the BACT Guidelines. The proposed amendment also complies with additional requirements of California Health and Safety Code Section 40440.11.

Conclusion

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 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.

Attachments

New Part B LAER/BACT Listings
Part D Minor Changes
NEO California Power Part B LAER/BACT Listing

Table 1. Proposed Amendment of MSBACT Guideline for Stationary, Non-Emergency I.C. Engines
 

	10-20-2000 Rev. 0 6-6-2003 Rev. 1 7-9-2004 Rev. 2
Equipment or Process:	I.C. Engine, Stationary

	Criteria Pollutants
Subcategory/ Rating/Size	VOC	NOx	SOx	CO	PM10	Inorganic
Non-Emergency, < 2064 bhp	0.15 grams/bhp-hr (4-10-98)	0.15 grams/bhp-hr (4-10-98)	See Clean Fuels Policy in Part C of the BACT Guidelines (10-20-2000)	0.60 grams/bhp-hr (4-10-98)	See Clean Fuels Policy in Part C of the BACT Guidelines (10-20-2000)
Non-Emergency, > 2064 bhp	25 ppmvd @ 15% O2 (7-9-2004)	219 ppmvd @ 15% O2 x Engine Efficiency (%) 33 (5-8-98) (7-9-2004)	Same as Above (10-20-2000)	33 ppmvd @ 15% O2 (5-8-98)	0.045 grams/bhp-hr (5-8-98) Same as Above (7-9-2004)	Ammonia: 10 ppmvd @ 15% O2 (7-9-2004)

Table 2. Summary of Cost Effectiveness Calculations for Incremental Control of NOx from a Stationary, Non-Emergency I.C. Engine Rated =2064 bhp from 21 ppmvd to 9 ppmvd , corrected to 15% O₂
 

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