New Source Reviewin the SCAQMD

November 2, 2005

Judy B. YorkeYorke Engineering, LLC

949-248-8490 x25JYorke@YorkeEngr.com

New Source Review (NSR)

In the SCAQMD, Regulation XIII specifies the NSR requirements.

Rule 1301 states: “The specific air quality goal of this

regulation is to achieve no net increases from new or modified permitted sources of nonattainment air contaminants or their precursors.”

Applicability of Reg. XIII

NSR generally applies to New, Modified, or Relocated Sources

“Modification means any physical change in equipment, change in method of operation, or an addition to an existing facility, which may cause the issuance of air contaminants.”

“Routine maintenance and/or repair shall not be considered a physical change.”

Which Pollutants? All Nonattainment air contaminants and

their precursors, plus ammonia and Ozone Depleting Compounds (ODCs)

Typically, the key pollutants include: NOx VOCs PM CO SOx

When is BACT Applied?

Best Available Control Technology is required for any relocation, new, or modified source which results in an emission increase [Rule 1303(a)(1)]

Except for a qualifying Relocated Minor Facility, where there is no net increase in emissions within two years [Rule 1306(d)(3)]

What Defines an Increase?

… Or Decrease? Rule 1306 specifies Increases and

Decreases under NSR: Increase = Potential to Emit Decrease = Actual Emissions (last 2

years) at current BACT (& discounted if <180 days of use)

When and How is BACT Decided?

BACT is determined at the time of permit issuance

BACT is determined on a case-by-case basis

BACT for Major/Minor Sources

BACT determination based on whether the source is classified as “major” or “minor” Major Sources - Must meet Federal

LAER Minor Sources – Use Minor Source BACT

Guidelines

Major Source Definition In the South Coast AQMD, a major source

has the Potential to Emit (PTE) greater than these thresholds:

VOC 10 Tons/Year

NOx 10 Tons/Year

SOx 100 Tons/Year

CO 50 Tons/Year

PM10 70 Tons/Year

Major Source BACT Major Source BACT is determined

case-by-case BACT analysis looks at the “best”

emission limits for similar equipment anywhere in the U.S.

BACT definitions can be constantly changing and tend to become more restrictive over time

Major Source BACT Guidelines

The complete BACT Guidelines can be downloaded from: http://www.aqmd.gov/bact/

What is BACT? BACT means the most stringent…limit or

control technique which: (1) has been achieved in practice for such

category or class of source; or (2) is contained in any state

implementation plan (SIP)…; or (3) is any other emission limitation or

control technique, found … to be technologically feasible for such class or category of sources or for a specific source, and cost-effective …”

Federal LAER

State BACT

Achieved in Practice, Reg. Documents

An emission limit or control technology may be considered AIP if it exists in any of the following regulatory documents or programs:

AQMD BACT Guidelines CAPCOA BACT Clearinghouse USEPA RACT/BACT/LAER Clearinghouse Other districts’ and states’ BACT Guidelines BACT/LAER requirements in New Source

Review permits issued by AQMD or other agencies

Achieved In Practice, New Technologies

A control technology may be considered Achieved in Practice if it meets the following: Commercial Availability: At least one vendor

must offer this equipment for regular or full-scale operation in the United States with a performance warranty;

Reliability: All control technologies must have been installed and operated reliably for at least six months… at a minimum of 50% design capacity…;

Effectiveness: The control technology must be verified to perform effectively over the range of operation expected for that type of equipment…”

Achieved in Practice, Tech. Transfer

Technology that is determined to be AIP for one category of source be considered for transfer to other source categories.

There are two types of potentially transferable control technologies: 1) exhaust stream controls for similar exhaust streams, and 2) process controls and modifications for similar processes.

Examples of Major Sources BACT

Applicant Size (MMBTU/hr)

NOx Limit (ppm)

Technology

Disneyland 8.5 12 Low NOx burner Liberty/Key Container

16.3 12 Low NOx burner

UCI Medical Center

48.6 9 Low NOx burner

Coca Cola 31.5 7 (5 ppm NH3)

Selective Catalytic Reduction (SCR)

SCAQMD Determinations for Boilers:

Minor Source BACT

For minor sources, the SCAQMD has published Minor Source BACT Guidelines [Part D - http://www.aqmd.gov/bact/]

Minor Source BACT may be less stringent than for major sources

However, not all source types are listed… Be very careful of using the appropriate category!

Examples of Minor Source BACT

Size (MMBTU/hr)

NOx Limit (ppm)

CO Limit (ppm)

<20 MMBTU/hr 12 50 (firetube type) 100 (watertube type)

>20 MMBTU/hr (no add-on controls)

9 Same as above

>20 MMBTU/hr (with controls; i.e. SCR)

7 (<5 ppm NH3)

Same as above

*Natural gas fired

SCAQMD Determinations for Boilers*:

Examples of Minor Source BACT

Subcategory NOx SOx PM10

 Carpet Oven 80 ppmvd, @3% O2

 

Natural Gas Natural Gas

Rotary, Spray and Flash Dryers1)

Natural Gas with Low NOx Burner

 

Natural Gas  

Natural Gas w/ Baghouse

Tray, Agitated Pan, and Rotary Vacuum Dryers

Natural Gas with Low NOx Burner

Natural Gas 

Natural Gas

Tenter Frame Fabric Dryer 60 ppmvd @ 3% 02 

Natural Gas Natural Gas

Other Dryers and Ovens – Direct and Indirect Fired

30 ppmvd @ 3% 02 

Natural Gas 

Natural Gas

1. Dryers for foodstuff, pharmaceuticals, aggregate & chemicals.

SCAQMD Determinations for Dryers and Ovens

Typical Permit Conditions Emission limits for pollutants

released Monitoring requirements Maintenance requirements Source testing requirements Recordkeeping requirements

BACT Implications Remember, once BACT is set for

your source, you must always comply with that limit… as will all of the sources after you…