BACT Scientific Review Committee December 11, 2018 · 2018. 12. 11. · BACT SRC Charter Reporting...

BACT Scientific Review CommitteeDecember 11, 2018

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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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101010

Soil Vapor Extraction –Thermal Oxidizer


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


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



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



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



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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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


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


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


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


≥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


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)



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


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


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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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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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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

SEARCH

BACT SRC Membership

List

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Equipment Category Search

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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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BACT Scientific Review Committee December 11, 2018 · 2018. 12. 11. · BACT SRC Charter Reporting...

Documents

Transcript of BACT Scientific Review Committee December 11, 2018 · 2018. 12. 11. · BACT SRC Charter Reporting...