BOARD MEETING DATE: October 3, 2008
AGENDA NO. 24

PROPOSAL:

Best Available Control Technology Guidelines Report and Amendments

SYNOPSIS:

Staff proposes amendments to Part D, BACT Guidelines for Non-Major Polluting Facilities, to make them consistent with AQMD Rules 431.2, 1146 and 1146.1 and CARB’s Air Toxic Control Measure (ATCM) for stationary diesel engines. These changes do not result in more stringent requirements and are intended simply as notification to applicants and stakeholders of future regulatory requirements.

COMMITTEE:

Stationary Source, September 19, 2008, Reviewed

RECOMMENDED ACTION:

Authorize the Executive Officer to update the minor source BACT (MSBACT) guidelines to be consistent with Rules 431.2, 1146 and 1146.1 for boilers and non-refinery process heaters and with the state Air Toxics Control Measure for stationary emergency engines driving fire pumps.
 

Barry R. Wallerstein, D.Env.
Executive Officer

Background

The AQMD Regulation XIII – New Source Review (NSR) and Regulation XX – RECLAIM require applicants to use Best Available Control Technology (BACT) for new sources, relocated sources and for modifications to existing sources that may result in an emission increase of any nonattainment air contaminant, any ozone depleting compound (ODC), or ammonia. Additionally, Regulation XIII requires the Executive Officer to periodically publish BACT Guidelines that establish the procedures and the BACT requirements for commonly permitted equipment.

As a result of amendments to AQMD’s NSR regulations in October 2000, the BACT Guidelines were separated into major polluting facilities and non-major (minor) polluting facilities. A facility is a major polluting facility if it emits, or has the potential to emit, a criteria air pollutant at a level that equals or exceeds the Regulation XXX Title V emission thresholds. For major polluting facilities, BACT is determined at the time the permit is issued, and is generally the most stringent degree of control that is contained in a SIP-approved rule or regulation or that has been achieved in practice. For non-major polluting facilities, minor source BACT (MSBACT) is as specified in Part D of the BACT Guidelines at the time an application is deemed complete. In updating Part D with new or more stringent MSBACT, AQMD must follow a more rigorous process than for major polluting facilities, including a cost effectiveness analysis, notification of the public, presentation at a BACT Scientific Review Committee (SRC) meeting and Governing Board approval. AQMD also follows the criteria and process specified in California Health & Safety Code Section 40440.11.

The proposed amendments to the MSBACT Guidelines are to maintain consistency with recent changes to AQMD rules and state law and alert applicants to future requirements of these changes. The proposed amendments will not result in more stringent requirements than would otherwise occur. Therefore, it was not necessary for staff to evaluate the achieved-in-practice status, cost effectiveness of the underlying technologies or assemble the BACT SRC to discuss these proposed amendments.
 

Boilers and Non-Refinery Process Heaters

Background

Amendments of Rule 1146 and Rule 1146.1, both of which are titled “Emissions of Oxides of Nitrogen from Commercial Industrial and Institutional Boilers, Steam Generators and Process Heaters,” were approved by the Governing Board on September 5, 2008. These rules apply to most gaseous fuel-fired boilers, steam generators and process heaters rated at greater than two million Btu/hr with the exception of utility boilers, refinery boilers and process heaters rated at greater than 40 million Btu/hr, thermal fluid heaters and sulfur plant reaction boilers. The new requirements are phased in for some size categories over two or three years. Table 1 compares the amended NOx limits of the two rules to AQMD’s MSBACT guidelines for boilers (or steam generators) fired on natural gas, propane or biogas (landfill or digester gas) and non-refinery process heaters.
 

Table 1. Comparison of Rules 1146 and 1146.1 Requirements to MSBACT Guidelines for Boilers and Non-Refinery Process Heaters

^a Rules 1146 and 1146.1 do not apply to electric utility boilers, refinery boilers and process heaters rated >40 MMBtu/hr, sulfur plant reaction boilers rated ≥5 MMBtu/hr or thermal fluid heaters rated ≥5 MMBtu/hr.

^b Except atmospheric units. For purposes of these rules, an atmospheric unit is defined as a natural-draft boiler or process heater that is rated at >2 and ≤10 MMBtu/hr input and has an unsealed combustion chamber.

Proposal

Prior to their being amended, Rules 1146 and 1146.1 had a NOx limit of 30 ppm @ 3% O2 on gaseous fuels. As shown in Table 1, the amended rules have future requirements that are more stringent than AQMD’s NOx MSBACT guidelines for units in some size/fuel categories. Staff is proposing that these future requirements be noted in the MSBACT Guidelines so that applicants will be aware of them and can make plans to comply.

Staff also recommends that the MSBACT guidelines for control of SOx emissions from boilers and non-refinery process heaters be updated at this time to be consistent with Rule 431.2, “Sulfur Content of Liquid Fuels.” Rule 431.2 requires that fuel oil purchased on or after June 1, 2004 contain no more than 0.0015% sulfur by weight.

Finally, staff recommends that a previously omitted footnote be included in the guideline for non-refinery process heaters. The footnote is similar to that in the boiler guideline allowing a higher NOx limit for the case in which use of a clean standby fuel is not possible and an ultra-low NOx burner (ULNB) cannot be applied.

The first and second attachments show, in strikeout/underline format, the specific changes that are being proposed to the guidelines for boilers and process heaters.
 

Fire Pump Engines

Background

New diesel engines that drive fire pumps must meet MSBACT for Stationary, Emergency I.C. Engine, Compression Ignition (CI). MSBACT for this equipment category generally requires that new engines be certified to meet Tier 2 or Tier 3 (depending on the date and the size of the engine) of the USEPA emission standards for nonroad engines (40CFR Part 89, “Control of Emissions from New and In-Use Compression-Ignition Engines”). However, the MSBACT guideline has a special provision for fire pump engines that allows the Tier 2 or 3 requirement to be waived if there is no Tier 2 or Tier 3 CI engine that has been certified by Underwriters Laboratories (UL™) for fire pump service.

The most recent amendment of the state California Air Resources Board (CARB) Air Toxics Control Measure (ATCM) for stationary diesel engines now requires that a new fire pump engine be certified to at least Tier 2 standards [California Code, Title 17, Section 93115.6(a)(4)]. Over the next few years, new engines will have to be certified to
Tier 3 if it is three years or more after the date that the Tier 3 requirement takes effect for the engine size.
 

Proposal

Staff is proposing to amend the MSBACT guideline for stationary, emergency fire pump engines to be consistent with the ATCM. The proposed amendment to the MSBACT guideline for Stationary, Emergency I.C. Engines is shown in the third attachment. The proposed guideline adds a new subcategory for fire pump engines and changes the old compression-ignition category to apply to other emergency compression ignition engines. Also, obsolete dates are removed from the guidelines.
 

Attachments (PDF, 104k)

Proposed Amended MSBACT Guideline for Boilers
Proposed Amended MSBACT Guidelines for Process Heaters – Non-Refinery
Proposed Amended MSBACT Guideline for I.C. Engines, Stationary, Emergency