BOARD MEETING DATE: July 7, 2006
AGENDA NO. 22
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 amendments to Part D, BACT Guidelines for Non-Major Polluting Facilities.
COMMITTEE:
Stationary Source, June 23, 2006, 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 first semi-annual progress report for the year 2006 and covers progress made since the previous (December 3, 2004) progress report; there was no activity during Calendar Year 2005.
In addition to the usual reporting of the new LAER/BACT determinations for major polluting facilities, staff is proposing several 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 was formed in 1994. CARB and U.S. EPA Region IX were each asked to designate representatives to the committee, and neighboring San Diego APCD was invited to participate. The balance of the committee was created by invitation of recognized experts from industry, consultants to industry, public utilities, suppliers of air pollution control equipment and environmental advocacy groups. The SRC was established as a standing committee by an action of the AQMD Board in September 8, 1995. The current SRC membership is attached. Whenever a committee member resigns, AQMD seeks out an appropriate replacement to join the committee.
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, the following changes have taken place in Part B. In Section I, one new listing has been added and two existing listings have been updated. In Section II, two new listings have been added and one has been updated. The new and updated listings are attached.
Section I – AQMD LAER/BACT Determinations
The one new Section I listing is in the “I.C. Engine-Stationary, Non-Emergency” equipment category. The two Section I listings that were updated are in the “Boiler” and “CO2 Plant” equipment categories.
The new “I.C. Engine, Stationary, Non-Emergency” listing is one of seven 1695 hp I.C. engines located at Big Bear City for which permits to construct were issued in August 2001. These engines are owned by Bear Valley Electric and are used for production of electricity during peak demand periods. To avoid classification as a Title V or RECLAIM source, the applicant offered to meet NOx, VOC and CO limits that are significantly below current LAER/BACT emission limits for stationary, non-emergency engines. The engines were commissioned for regular commercial service in January 2005 and operated a total of 1550 engine-hours in 2005.
The “Boiler” listing that was updated is one of two identical utility boilers operated by AES at Huntington Beach. These boilers are equipped with low-NOx burners, flue gas recirculation and selective catalytic reduction (SCR) systems. The main purpose of updating this listing was to document a change that had occurred in the NOx averaging time—from one-hour to 24-hour averaging. The listing was also updated with regard to the boiler operating history.
The “CO2 Plant” listing that was updated is operated by the BOC Group in El Segundo. The plant processes a waste gas from the adjacent Chevron refinery and produces liquid CO2. The purpose of the update was to clarify the basis of the LAER determination, exactly which streams are vented to the thermal oxidizer, sampling locations used in the source test and the monitoring and recordkeeping requirements and update the operating history and source test results.
Section II – Other LAER/BACT Determinations
The two new Section II listings are both in the “Flare, Landfill Gas from Non-Hazardous Waste Landfill” equipment category, and the Section II listing that was updated is in the “I.C. Engine, Stationary, Emergency” equipment category.
The new “Flare, Landfill Gas from Non-Hazardous Waste Landfill” listings are two John Zink Ultra-Low Emission (ZULE) flares located in New England. These are large, enclosed ground flares. One is located in New Hampshire and operated by Waste Management, and the other is located in Rhode Island and operated by Rhode Island Resource Recovery Corporation. The ZULE flare has guaranteed NOx and CO emission levels that are well below current LAER/BACT for this type of flare, and the guarantee applies to both landfill and digester gases. The New Hampshire flare operates continuously with the exception of scheduled and unplanned outages. It started up and was source tested in mid 2002 and has operated since that time. The Rhode Island flare operated intermittently, to back up a landfill gas-fired power plant, for nearly two years but has recently been switched to continuous operation. It started up early in 2004 and was source tested in mid 2004. The source tests on both flares showed them to readily meet the guaranteed NOx and CO emission limits and to have extremely low VOC emissions.
The “I.C. Engine, Stationary, Emergency” listing that was updated is a 2848 hp engine operated by the Kings County Department of Public Works in Hanford, California. The listing was updated regarding the engine hp rating, the description of the emission control technology (diesel particulate filter) and the operating history.
Proposed Amendments to Part D of the BACT Guidelines, BACT Guidelines for Non-Major Polluting Facilities
Staff is proposing the following amendments of Part D, BACT Guidelines for Non-Major Polluting Facilities (MSBACT). The proposed amended guidelines are attached.
Proposed Amendments of Guidelines for Stationary and Portable Diesel Engines
The guidelines for stationary, emergency, diesel (compression-ignition) engines and portable diesel engines basically reflect the federal emission standards for nonroad engines[1], which began phasing in in 1996 with Tier 1 standards and have continued to phase in with progressively more stringent Tier 2 and Tier 3 standards taking effect in subsequent years (Table 1). The effective dates in Table 1 are dates when manufacturers must begin meeting each standard. In addition to Tiers 1 through 3, Tier 4 standards are presently scheduled to begin phasing in 2008.
Updating the Guidelines to Require Tier 3 Engines As They Become Available
The MSBACT guidelines currently reflect the effective dates for the Tier 1 and Tier 2 standards. As shown in Table 1, Tier 3 engines are now becoming available; and staff proposes to amend the guidelines for stationary and portable diesel engines to reflect the
Table 1. Effective Dates for Nonroad Emission Standards, Tiers 1, 2 and 3
Engine Size, KW (HP)
Tier 1
Tier 2
Tier 3
34 to < 75 (50 to < 100) 1/1/98
1/1/04
1/1/08
75 to < 130 (100 to < 175) 1/1/97
1/1/03
1/1/07
130 to < 224 (175 to < 300) 1/1/96
1/1/03
1/1/06
224 to < 447 (300 to < 600) 1/1/96
1/1/01
1/1/06*
447 to < 559 (600 to < 750) 1/1/96
1/1/02
1/1/06*
≥ 559 (≥ 750) 1/1/00
1/1/06
**
*In a settlement with U.S. EPA, several major manufacturers agreed to move these deadlines back to 1/1/05.
**There are no Tier 3 standards for engines rated at ≥ 559 KW (≥ 750 HP).
Tier 3 effective dates and to remove the Tier 1 and Tier 2 dates wherever they have already passed. The proposed amended guidelines are attached. For the stationary engines, staff proposes to allow a six month grace period after the federal date to allow time for newly manufactured engines to reach vendors who sell the engines. To be consistent with the CARB Air Toxics Control Measure for Portable Engines[2], which requires that on or after January 1, 2006 all portable engines meet the most stringent state or federal emission standards, staff is not proposing a grace period for the portable engines.
Compliance with Health and Safety Code
In amending its BACT guidelines for non-major polluting facilities to be more stringent, AQMD must comply with Section 40440.11 of the California Health and Safety Code. The following paragraphs list the applicable requirements in 40440.11 (italics) and the demonstration of compliance with each:
(c)(1) Identify one or more potential control alternatives that may constitute the best available control technology as defined in section 40405.
Potential control alternatives are use of a Tier 2, Tier 1 or “Tier 0” (manufactured before 1996) engine.
(c)(2) Determine that the proposed emission limitation has been met by production equipment, control equipment, or a process that is commercially available for sale, and has achieved the best available control technology in practice on a comparable commercial operation for at least one year, or a period longer than one year if a longer period is reasonably necessary to demonstrate the operating and maintenance reliability, and costs, for an operating cycle of the production or control equipment, or process.
Major manufacturers produced and certified Tier 3 engines well ahead of the required January 2005 and January 2006 deadlines. Tier 3 engines thus began reaching the market in October 2004 and therefore have been available and in use for more than one year.
(c)(3) Review the information developed to assess the cost-effectiveness (annual cost of control divided by annual emission reduction potential) of each potential control alternative.
See attached Cost Effectiveness Calculations.
(c)(4) Calculate the incremental cost-effectiveness for each potential control option (difference in cost divided by difference in emissions for each progressively more stringent control option)
See attached Cost Effectiveness Calculations.
(c)(5) Place the best available control technology revision on the calendar of a regular meeting agenda of the AQMD board for its acceptance or further action as the board determines.
The item was placed on the agenda of the June 2, 2006 meeting of the AQMD board.
Restructuring the Guidelines to MakeThem Easier to Use
In addition to the above substantive changes to the guidelines for stationary and portable diesel engines, staff proposes to restructure these guidelines to make them easier to use.
Proposed Amendments of Printing and Graphic Arts Guideline
In the “Printing and Graphic Arts” equipment category, staff proposes to add a definition of “VOC composite partial pressure” which is a limit criterion in the guideline for the “Lithographic Printing” subcategories (Heatset and Non-Heatset). When those guidelines were last updated, the definition of VOC composite partial pressure was available in Rule 1171; but it has since been removed from that rule.
Conclusion
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 of 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 (EXE 222.5 KB)
BACT Scientific Review Committee Members
New/Updated Part B LAER/BACT Listings
Part D Amendments
Cost Effectiveness Calculations
[1] 40 CFR Part 89 – Control of Emissions from New and In-use Nonroad Compression-Ignition Engines (http://www.dieselnet.com/standards/us/offroad.html#emistd)
[2]California Code of Regulations, Title 17, Sections 93116, 93116.1, 93116.2, 93116.3, 93116.4, 93116.5 http://www.arb.ca.gov/diesel/peatcm/peatcm.htm