BACT Scientific Review CommitteeDecember 11, 2018
Proposed Updates to BACT Guidelines
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BACT Guidelines updated and approved at February 2, 2018 Board meeting
Overview, Parts A, B, C and D to be updated
Reviewed BACT determinations from SCAQMDand other Air Districts. Gathered cost data andconducted site visits
Maintain consistency with recent changes to SCAQMD rules, State and Federal requirements
Held three BACT SRC public meetings, April 24, October 3 and December 11 with a 30-day comment period.
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Received three comment letters• Part D, Printing- Graphic Arts (Lithographic or Offset, Heatset):
Clarification for PM10 column correction regarding afterburner control efficiency requirement.
• Part B, new proposed Storage Tank and Soil Vapor Extraction LAER Determinations: Throughput limits correction as not LAER limits. For SVE, correction of daily to monthly monitoring not relevant to NOx LAER requirement.
• Part B, proposed update LAER listing for produced gas-fired Simple Cycle Gas Turbine: Question if gas turbine is equipped with gas cleaning/treatment system, if so, should be included in proposed LAER determination.
• Part B, Fiberglass Operations, Application- Hand and Spray Lay Up: Consider updating LAER/BACT based on BAAQMD 9/27/06 BACT determination <34% monomer content and include UV/EB technology as equivalent BACT option.
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• Part D, Spray Booth, other types: Consider updating BACT based on BAAQMD 12/16/03 BACT determination with an overall control efficiency >90% was cost effective for Misc. Metal Parts and Products and include UV/EB technology as equivalent BACT option for 90% emission control.
• Part D, Spray Booth, Wood and Lithographic Printing: Provided examples of UV technology operations to be reflected in BACT Guidelines.
• Part B and D, Various categories including Inkjet Printing, PasticCoatings, 3D Printing, Adhesives, Motor Vehicle coating and Semiconductor manufacturing: Consider as UV/EB technology currently available to be reflected as LAER/BACT determinations.
• Part B, Gas Turbines – Digester gas and Produced Gas-Fired: Inquiry regarding sulfur requirement/limits in LAER determinations.
Comments Letters (cont’d)
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Proposed Updates to Overview Referencing Engineering & Permitting
Policy preventing circumvention of BACT requirement for emission increases ≥ 1 lb/day.
Cumulative emission increases that equal or exceed 1 lb/day (nonattainment air pollutant, O3 depleting compound or ammonia) within a 5-year period will be subject to BACT.
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Proposed Updates to Part A – Policy and Procedures for Major Polluting Facilities SCAQMD Air Quality-Related Energy
Policy established on September 2011
Policy no. 7 of 10 requires new/repowered in-Basin fossil-fueled power plant to incorporate LAER/BACT considering energy efficiency.
Included in BACT Guidelines by reference
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Proposed Updates to Part C– Policy and Procedures for Minor Polluting Facilities SCAQMD Air Quality-Related Energy Policy
established on September 2011
Included in BACT Guidelines by reference
Updated maximum cost-effectiveness values on Table 5 (M&S Index 2nd quarter 2018)
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Proposed deletions of outdated Part B Sections I & II LAER Determinations
Aluminum melting Boiler Oven Dryer, Tenter Frame Gas Turbine Heater
I.C. Engine (Landfill, Digester Gas, Emergency, Non-Emergency & Portable
Lithographic Printer Spray Booth
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External Floating Roof Storage Tank
Installation of dome
New Proposed Part B, Section I, SCAQMDLAER/BACT Determination
Installation of Dome Top Reduces Wind Induced Emission
Throughput limits of the storage tanks should not be included. Removed from Section 4D
Public Comment
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Soil Vapor Extraction –Thermal Oxidizer
Installation of dome
New Proposed Part B, Section I, SCAQMDLAER/BACT Determination
Gasoline Storage facility – Soil remediation 30 ppm NOx - applies to burner only emissions
Needs to show clearly it’s burner only – Added burner only – nat. gas line in Section 4D
Monitoring of VOC not relevant – Removed
SRC Comment
Public Comment
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Gas Turbine – Nat. Gas Combined Cycle &
Simple Cycle
Installation of dome
Proposed Part B, Section I, SCAQMDLAER/BACT Determination Update
Combined: 2 ppm NOx/2 ppm CO/2 ppm VOC/5 ppm NH3
Simple: 2.5 ppm NOx/4 ppm CO/2 ppm VOC/5 ppm NH3
Add Natural Gas to Equipment Category Remove Start-up & Shutdown periods & #s allowed
per year from Section 4B
2 SRC Comments
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Gas Turbine – Simple Cycle
Landfill Gas
Installation of dome
Proposed Part B, Section I, SCAQMDLAER/BACT Determination Update
12.5 ppm NOx, 10.5 ppm VOC, 21.5 ppm CO 100% Landfill Gas No SCR – Ultra Lean Pre-mix combustion Removed Start-up & Shutdown case specific data
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Gas Turbine – Combined Cycle
Digester Gas
Installation of dome
Proposed Part B, Section I, SCAQMDLAER/BACT Determination Update
18.8 ppm NOx, 25 ppm VOC, 60 ppm CO, 10 ppm NH3
Sewage digester – SCR & OxiCat 60% Digester gas/40% Natural gas mixture
Why SOx emissions are not included? - R431.1 Fuel Sulfur limit of 40 ppm not considered a BACT Limit.
Public Comment
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Gas Turbine – Simple Cycle
Produced Gas
Installation of dome
Proposed Part B, Section I, SCAQMDLAER/BACT Determination Update
5 ppm NOx, 2 ppm VOC, 6 ppm CO, 5 ppm NH3 Crude Oil/Gas/Water Separation - SCR, OxiCat Produced Gas/Natural Gas mixture
Gas clean-up system? - Only moisture removal before fed to turbine. Excess gas undergoes clean-up to pipeline spec to sell.
SOx Requirement? - The 150 ppm SOx requirement is from 40CFRSubpart GG. Not considered a BACT Limit
2 Public Comments
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Proposed Part B, Section I, SCAQMDLAER/BACT Determination Update
I.C. Engine Portable
Tier 4 emission standards compliant 123.4 BHP
I.C. Engine Emergency Fire Pump
Tier 3 emission standards compliant 183 BHP
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Gas Turbine – Nat. GasCombined Cycle
Installation of dome
New Proposed Part B, Section II, Other LAER/BACT Determination
Virginia State – Warren County Three natural gas-fired gas turbines generators
(3,227MM Btu/hr ea) with duct-fired HRSG (500MM Btu/hr)
2ppm NOx / 1.5ppm CO w/o duct burner/ 5 ppm NH3
Reviewed 2-3 years continuous CEMS data16
New Proposed Part D, Minor Source, BACT Determinations
Thermal Oxidizer –various applications
Cat Ox / RTO / Direct Fired Afterburner 30ppm NOx @ 3% O2 limit for burner only Since 2014 - Over 30 Achieved in practice with
source tests & emission limit compliance Excludes Tank Degassing/SVE/Vapor
Incinerators Completed two Cost Effective studies – 1 RTO, 1
CatOx ($22k & $54k per ton NOx Reduction)
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Fryer – Deep Fat
Installation of dome
Added sub-category for clarification Non-Integrated Oil Heater (60ppm NOx)
compliance with Rule 1147 Non-Integrated – no longer separating direct &
indirect (steam, thermal fluid heater, etc..) Next Round to update VOC/PM10 for all Next Round - 30 ppm NOx for Integrated
Part D, Minor Source, BACT Update
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Composting
Installation of dome
New Proposed Part D, Minor Source, BACT Determination
Adding new subcategory of GreenwasteComposting
Compliance with Rule 1133.3 for VOC and NH3 emissions
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Boiler
Installation of dome
≥20 MM Btu/hr and <75 MM Btu/hr, (Group 2) Compliance with Rule 1146 for NOx (5ppm) Natural gas or Propane Fired
New Proposed Part D, Minor Source, BACT Determination
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Process HeaterNon-Refinery
Installation of dome
Proposed Part D, Minor Source, BACT Determination Update correction
Subcategory: Natural Gas or Propane Fired ≥20 MM Btu/hr
Correction of Rule 1146.1 applicability in NOx column
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Printing (Graphic Arts)
Installation of dome
Proposed Part D, Minor Source, BACT Determination Update correction
Subcategory: Lithographic or Offset, Heatset -include venting to afterburner in PM10 column which was previously deleted in error
Subcategory: Lithographic or Offset, Non-Heatset-Correction to “Same As Above” for Non-Heatsetshould refer to Low VOC Fountain Solution not venting to afterburner
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Spray Booth
Installation of dome
Subcategory: Automotive, Down-Draft Type Correction of lbs/month to be consistent
with permitted limits; NSR <4 tons/year not requiring offsets
<660 corrected to <667 lbs/month
Proposed Part D, Minor Source, BACT Determination Update correction
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Proposed Part D, Minor Source, BACT Determination Update correction
I.C. Engine, Stat., Emer.CI Other, 100≤HP<175
Outdated PM limit of 0.22 grams/bhp-hr/0.30 grams/kW-hr.
Correction to 0.15 grams/bhp-hr/0.20 grams/kW-hr to be consistent with CARB ATCM regulation and Rule 1470
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Installation of dome
New Proposed Part D, Minor Source, BACT Determination Update
Aluminum melting Furnace (60ppm NOx) Brass Melting Furnace (60ppm NOx) Burnoff Furnace (30ppm/60ppm NOx) Calciner (30ppm/60ppm NOx) Coffee Roasting (30ppmNOx) Crematory (60ppm NOx) Dryer-Kiln (30ppm/60ppm NOx)
Compliance with Rule 1147
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New Proposed Part D, Minor Source, BACT Determination Update
Compliance with Rule 1147
Dryer or Oven tenter frame/carpet(30ppm/60ppm NOx)
Fish Reduction cooker/dryer (30ppm NOx) Fryer- Deep Fat Non-Integrated (60ppm Nox) Lead Melting Furnace (60ppm NOx) Soil Vapor Extraction (Remediation), thermal
oxidation (60ppm NOx) Zinc Melting Furnace (60ppmNOx)
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Installation of dome
Proposed Update/Clarification toBACT SRC Charter
Reporting to Stationary Source Committee
Once proposed amendments to the BACT Guidelines have been presented at a public BACT SRC meeting initiating a 30-day comment period followed by a final public BACT SRC meeting.
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Making BACT Guidelines User Friendly
EQUIPMENT CATEGORY
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Next Steps
Stationary Source Committee on 1/18/19 Governing Board Meeting 2/1/19 Continue developing BACT updates Next BACT SRC meeting
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