MEETING HIGHLIGHTS

	SRC Members
Greg Adams			Steve Simons
Martin Ledwitz			Karl Lany
Russell Greenhouse (not present)			Stan Romelczyk (by phone)
Gary Rubenstein			Hal Taback
Ted Guth			Bill Dennison
Katy Wolf			Nahid Zouestaigh (by phone)
Philip Hodgetts (not present)				Ron Joseph (not present)
Grant Chin (by phone)			Ron Wilkniss (not present)
Anoosheh Mostafaei
		Attendees
Greg Gentry			Richard Davis
Tom Girdlestone			Jerry Day
Todd Paxman			Mark Simon
Viji Sadasivan			Alfred Tong
Mark Abramowitz			Curtis Taipale (by phone)
Hugh Dean (by phone)			Steven Kato (by phone)
Hafizur Chowdhury (by phone)			Russ Goerlich
John Clarkson			Steve Hernandez
Hank Wedda			John Billheimer
Millie Yamada			Damon Erickson
George Tracy			Judy York
Vlad Kogan
	AQMD Staff
Marty Kay			Howard Lange
Alfonso Baez			William Wong
Sawsan Andrawis

 

 

 

 

Marty Kay welcomed the SRC members and the audience to the meeting.  The topics listed below were discussed during the meeting.

¾    Minutes of November 21st Meeting

¾    Responses to Comments from November 21st Meeting

¾    Warranty Requirements for Achieved-in-Practice BACT

¾    New and Updated BACT - Part B Listings

¾    Public Notice of New BACT Determination for Combined Cycle and Cogeneration Gas Turbines

¾    Update of Part D (Minor Source) BACT Guidelines for Emergency Diesel Engines

¾    Other Business

 

Minutes of the November 21st Meeting

The minutes of the November 21^st meeting were approved as written.

 

Responses to Comments from the November 21st Meeting

Brake Pad Grinder – Covina Brake Bonding (A/N 391524)

Committee members had asked why the collection efficiency was not included as a permit condition.  Members of the AQMD permitting team that had issued the permit inspected the brake grinders to assess whether there had been a permitting deficiency.  They observed that each grinder had a separate hood with a small work opening and high inlet velocity and concluded that collection efficiency was inherently as high as possible, thus not requiring a permit condition. (Howard Lange, AQMD; Marty Kay, AQMD)

Boiler – Cosmetics Laboratories (A/N 385770)

AQMD was to inquire whether an emissions guarantee had been provided by the manufacturer.  It was found that there was no emissions guarantee given because it was a first-of-a-kind, but this product is now guaranteed to meet AQMD BACT emission limits.  This information was added to the listing. (Howard Lange, AQMD)

Heater, Other Process – Southern California Gas Co. (A/N 347641)

A committee member had pointed out that the source test results for these three identical heaters indicated significant differences in recorded levels of O2 and FGR although measured emissions were about the same.  In a discussion with a knowledgeable person at the facility, the differences were attributed to differences in ambient conditions and differences in “personalities” of the heaters.  This information was added to the listing. (Howard Lange, AQMD)

 

Warranty Requirements for Achieved-in-Practice BACT

The issue of whether an emissions performance warranty should be a requirement for an achieved-in-practice BACT determination had been raised at prior meetings.  Bill Wong of the AQMD Counsel’s office had researched this issue and explained AQMD’s position as follows.

There is no requirement in state or federal law or in the California Health & Safety Code that a warranty be a requirement for a BACT determination.  The only mention of a warranty in the context of BACT is in AQMD’s achieved-in-practice guidelines, which require as one of the criteria for “Commercial Availability” that a warranty be offered.  It is significant that the warranty requirement is included under “Commercial Availability” and not under “Effectiveness” as this implies that the intent is for a basic commercial warranty and not necessarily an emissions performance warranty.  Furthermore, requiring an emissions performance warranty would be inconsistent with the intent of the LAER/BACT process in that it would allow manufacturers of control equipment to unduly influence the process.  Health & Safety Code section 40723 does provide that if a BACT determination is based partially on a performance warranty and the performance warranty is not met (and subject to certain other conditions), AQMD is to reconsider the BACT determination.

Discussion:  Committee members offered various opinions and experiences relating to warranty issues, but overall seemed to understand and accept AQMD position as stated above.  However, some committee members expressed concern that achieved-in-practice BACT determinations in many cases base the determination of effectiveness on the results of a single source test. (Hal Taback, HTC; Martin Ledwitz, Southern California Edison Co.; Katy Wolf, IRTA; Anoosheh Mostafaei, Ship & Shore Environmental; Gary Rubenstein, Sierra Research; Steve Simons, Southern California Gas Co.)

 

New and Updated BACT Part B, Section I Listings

I.C. Engine, Landfill Gas Fired – MM San Bernardino Energy (A/N 391009)

This new listing is a landfill gas-fired I.C. Engine rated at 1850 bhp.  A Permit to Construct has been issued for this engine, and the engine will be source tested prior to issuance of the Permit to Operate.  The permit conditions reflect the NOx, CO and HC g/hp-hr limits that are in Part D of the BACT Guidelines.  The purpose of this listing is to document in Part B an example of a landfill gas-fired engine permitted according to Part D of the BACT Guidelines.    (Marty Kay, AQMD; Howard Lange, AQMD)

Discussion:  It was pointed out that in section 5B6 of the listing, the guaranteed ppm limits, when converted to g/hp-hr, do not meet the limits required in the permit (the Part D BACT limits).  AQMD responded that this did indeed seem to be the case, and AQMD was to check the calculation and report back. (Greg Adams, Los Angeles County Sanitation Districts; Gary Rubenstein, Sierra Research; Vlad Kosan; Orange County Sanitation District; Marty Kay, AQMD; Howard Lange, AQMD)

I.C. Engine, Digester Gas Fired – Inland Empire Utilities Agency (A/N 388050)

This new listing is a digester gas-fired I.C. Engine rated at 1408 bhp.  A Permit to Construct has been issued for this engine, and the engine will be source tested prior to issuance of the Permit to Operate.  The permit conditions reflect the NOx, CO and HC g/hp-hr limits that are in Part D of the BACT Guidelines.  The purpose of this listing is to document in Part B an example of a digester gas-fired engine permitted according to Part D of the BACT Guidelines.  This case is somewhat unusual in that the digester gas is being produced by a cow manure digester. It is also unusual in that the permit conditions included ppm limits that are based on Rule 1110.2 rather than on Part D, and the ppm limits are thus not consistent with the g/hp-hr limits.  The permitting team intends to resolve this inconsistency in the Permit to Operate. (Marty Kay, AQMD; Howard Lange, AQMD)

Discussion:  An audience member stated that for this type of engine, Rule 1110.2 is actually more stringent than Part D BACT.  AQMD responded that it did not believe this to be the case, but would look into it. (Vlad Kosan; Orange County Sanitation District; Marty Kay, AQMD; Howard Lange, AQMD)

Lithographic or Offset Printing, Heatset – Madison Graham (A/N 405533)

This new listing is a heatset lithographic printing press, i.e., the printed material moves from the press into an oven for drying and curing the ink.  Most of the ink volatiles are driven off in the oven, as opposed to the more common air-dry systems, in which the ink volatiles evolve more slowly and are therefore less amenable to control.  Part D BACT for heatset lithographic printing systems requires <8% VOC in the fountain solution and blanket and roller washes with vapor pressure <10 mm Hg and that the oven be vented to a control device with chamber temperature of at least 1400F and achieving at least 95% overall control efficiency.  In this case the control device is a regenerative thermal oxidizer.  VOC from the blanket and roller washes are not vented to the control device.  The purpose of this listing is to document in Part B of the BACT Guidelines a heatset lithographic printing system permitted according to Part D.  A Permit to Construct has been issued, and the control device is to be source tested prior to issuance of the Permit to Operate. (Marty Kay, AQMD)

Discussion:  A committee member expressed concern that the listing did not state that the permit required compliance with Rule 1171.  AQMD responded that the permit actually does require compliance with Rule 1171, and this information would be added to this listing and also to the Quebecor (Section III) listing to be discussed later in the meeting.  This committee member also commented that the permit includes a limit on vapor pressure of the blanket and roller washes whereas Rule 1171 no longer requires vapor pressure limits.  AQMD responded that the vapor pressure limits are still in Part D BACT, and permit engineers therefore still include them.  Another committee member requested that information be added to the listing regarding the VOC concentration in the inlet air to the control device, and AQMD agreed to do so.  Another committee member asked how the 95% overall control efficiency is determined.  AQMD responded that the permit indicates that the source test will determine destruction and collection efficiency and the permit engineer’s evaluation indicates that the collection efficiency will be presumed to be 99.5% if the oven has negative internal pressure.  The latter presumption is based on AQMD guidance issued in June of 1997.  AQMD was to look further into this and report back. (Katy Wolf, IRTA; Marty Kay, AQMD; Gary Rubenstein, Sierra Research; Anoosheh Mostafaei, Ship & Shore Environmental; Marty Kay, AQMD; Howard Lange, AQMD)

Boiler – Bumble Bee Seafoods (A/N 365228)

This existing listing was updated with information that had become available since its last update (June 2001).  The new information consisted mainly of the results of a Rule 1146 source test that had been performed in October of 2002 and the fact that a Permit to Operate had been issued.  The facility contact information and boiler operating history were also updated. (Howard Lange, AQMD)

Discussion: An audience member noted that of four source tests that have been performed on this boiler only one was unannounced and the NOx exceeded the permit limit in that test.  Another audience member, who was familiar with the circumstances of that test, responded that there were specific technical problems at the site that he believed caused the NOx to be higher than normal.  A committee member asked whether there was a pattern of NOx being found to be exceeding the permit limit in unannounced tests.  AQMD responded that the data indicate that the BACT NOx limits can be achieved and are being achieved where the boilers are given proper attention. (Steve Hernandez, Parsons; John Clarkson, Southern California Boiler; Steve Simons, Southern California Gas Co.; Marty Kay, AQMD)

 

New BACT Part B, Section III Listing

Lithographic or Offset Printing, Heatset – Quebecor World Publishing (A/N 401090)

This new listing is one of seven new heatset lithographic presses, all of which vent to a new regenerative thermal oxidizer (RTO).  At the applicant’s request, permit conditions exceed the requirements of Part D BACT in several regards.  The vapor pressure of blanket and roller washes are limited to 6 mm Hg whereas BACT requires 10 MM Hg.  The overall VOC control efficiency must be at least 98.5% whereas BACT requires 95%.  The NOx level in the RTO exhaust is limited to 78 ppmvd (corrected to 3% O2) whereas BACT does not require any NOx limit on the RTO.  The elevated VOC control efficiency was desired by the applicant to make it easier to meet a facility VOC cap.  The NOx limit on the RTO was desired in order to keep the facility NOx emissions below 4 tons per year and thus avoid offset requirements.  The RTO will be source tested prior to issuance of the Permit to Operate.  At that time, the listing should qualify to be moved to Section I. (Howard Lange, AQMD)

Discussion:  A committee member commented that the vapor pressure limit on the wash solutions is ineffectual in that all VOC in those solutions are emitted anyway.  AQMD responded that, at least theoretically, the VOC emissions should be lower for lower-vapor pressure solutions.  The same committee member asked whether the source test would include a verification that the oven pressures are negative.  AQMD responded that this requirement was not included in the permit.  AQMD was to find out what the permitting team policy is on this matter and report back.  Another committee member commented that it might be better to defer this listing until after the source test was completed and the Permit to Operate issued.  AQMD responded that this listing, in being placed in Section III, does not constitute a BACT requirement and that the purpose of Section III listings is to provide information on new technologies before they are fully proven. (Katy Wolf, IRTA; Anoosheh Mostafaei, Ship & Shore Environmental; Marty Kay, AQMD)

 

New BACT Part B, Section II Listing

and

Public Notice of New BACT Determination for Combined Cycle and Cogeneration Gas Turbines

Gas Turbine – ANP Blackstone, (MADEP A/N 118969)

This new gas turbine combined cycle power plant is located in Massachusetts.  The plant consists of two 180 MW gas turbines, each with an unfired heat recovery steam generator (HRSG).  Each HRSG supplies steam to a 95 MW steam turbine.  Both power trains are capable of operating in a steam augmentation mode, in which part of the HRSG steam is injected into the gas turbine, which increases overall power output.  In negotiations with the Massachusetts Department of Environmental Protection (MADEP), the NOx, CO and ammonia limits were set at 2.0, 3.0 and 2.0 ppmvd@15%O2, respectively, on a one-hour block average basis at full load.  Higher emission limits are allowed for some pollutants at reduced loads and during operation in steam augmentation mode.

The plant started up in the spring of 2001 but has experienced low utilization due to low power demand in the area.  However, 183 days of operation have now been logged.  NOx data from the CEMS on each unit is posted quarterly on U.S. EPA’s Acid Rain web site.  While some difficulties in maintaining good NOx compliance were experienced in 2001, the data from 2002 have shown very good compliance.

A public notice was issued January 16, 2003 stating that AQMD had determined the 2.0 ppm NOx limit and 3.0 ppm CO limit to be BACT for new combined-cycle and cogeneration gas turbine power plants. (Howard Lange, AQMD)

Discussion:  A committee member commented that he presumed the gas turbine to employ oil as a back up fuel and doubted that the 2.0 ppm NOx limit could be achieved when operating on oil fuel.  AQMD responded that it would look into the matter and report back.

Another committee member asked that AQMD verify that the low utilization that the plant has experienced is indeed due to low power demand in the area and not an indication of numerous problems being experienced with the equipment.  AQMD agreed to do so and report back.

Another Committee member asked whether the 2.0 ppmvd (corrected to 15% O2) limit on ammonia would be required on future gas turbines permitted by AQMD.  AQMD responded that it was not AQMD’s intention to do so at this time.  An audience member asked why AQMD did not plan to require the 2 ppm limit on ammonia since the area is in nonattainment for PM10.  AQMD responded that methods used to measure ammonia emissions are unsettled at this time, which makes it more difficult to justify lower limits on the basis of source test data and also makes it more difficult to enforce lower limits.

A committee member made the following comments: (1) the listing should reflect that the turbine NOx emissions are 15 ppm rather than 7 ppm, (2) the listing should note that there are very few gas turbines that can achieve a 15 ppm NOx level, (3) in the aero-derivative class of gas turbines, 25 ppm is the lowest NOx guarantee available, (4) the public notice omits important details that are in the listing such as that emission limits on some pollutants are higher at reduced loads and during steam augmentation and that the units are not duct-fired, (5) the listing should note that some period of time was required before the plant was achieving consistent emission control performance and (6) the listing should note the number of exceedances per period of time that are being experienced by this plant.  This committee member stated that he would submit these written comments to AQMD.

Several committee members suggested that the listing should be specific to a certain gas turbine size range.  AQMD responded that the turbine size range to which these emission limits should be applied will be clarified in the final listing.

A committee member asked what is the accuracy with which these low levels of NOx can be measured.  AQMD responded that CEMS accuracy for NOx in this ppm range is about 1 ppm, and added that 1.5 plus/minus 1 ppm is till considered lower than 2.5 plus/minus 1 ppm.

(Martin Ledwitz, Southern California Edison Co.; Karl Lany, SCEC; Steve Simons, Southern California Gas Co.; Richard Davis, Emerachem; Gary Rubenstein, Sierra Research; Bill Dennison, Dennison & Associates; Steve Simons, Southern California Gas Co.; Greg Adams, Los Angeles County Sanitation Disticts; Marty Kay, AQMD; Howard Lange, AQMD)

Update of Part D (Minor Source) BACT Guidelines for Emergency Diesel Engines

AQMD had presented at an earlier SCR meeting a plan to incorporate U.S. EPA Tier 2 standards for nonroad engines into Part D BACT for emergency diesel engines.  This was a progress report on that effort.  Since the previous review with the committee, AQMD Counsel had advised AQMD that State law requires consideration of alternative control technologies as well.  AQMD had therefore investigated alternative technologies that might be applied and had determined that diesel particulate filter (DPF), diesel oxidation catalyst (DOC) and selective catalytic reduction (SRC) technologies are commercially available for diesel engines.  DPF and SCR were found to have been achieved in practice for emergency diesel engines.  However, DPF was found not to meet the AQMD cost-effectiveness criteria for changing Part D BACT, largely because the achieved-in-practice case showed a small increase in NOx emissions from the engine.  SCR was found to meet the cost-effectiveness criteria, but only for its application to relatively large engines.  AQMD planned to allow applicants to accept reduced operating hours as an alternative to installing SCR.  The staff report was still being revised, and AQMD stated that the committee would be kept advised on this matter. (Marty Kay, AQMD)

Discussion: A committee member questioned whether the relatively short engine runs involved in engine tests, which normally comprise the bulk of operation, would afford sufficient time for the SCR or DPF catalyst to warm up to the minimum temperature required for effective emission control.  Another committee member questioned whether DPF technology had been achieved in practice on an emergency engine in that his information was that the first CARB verification for an emergency engine was still in progress.

A committee member questioned whether the SCR case that AQMD had used as the basis for SCR being achieved in practice was really an emergency engine.  AQMD responded that it was restricted to 250 hours per year.  The committee member responded that this still may not be a true emergency engine, i.e., AQMD allows only 50 hours per year discretionary operation with another 150 being allowed only for actual emergencies.  This committee member strongly recommended that AQMD revise the cost analysis to include only the 50 hours per year since the remaining 150 hours per year operation is very unlikely to actually occur.  AQMD responded that it would consider this.

A committee member asked to what extent the air toxics control measure (ATCM) being developed by CARB is reflected in the proposed Part D update.  AQMD responded that the update is based on AQMD’s determination of what is BACT for this source category and meets the AQMD cost-effectiveness criteria for updating Part D and has no relationship to CARB’s ATCM.  The committee member then asked whether the negative effect of DPFs on engine NOx emissions was being considered in the AQMD program to retrofit DPFs to school buses.  AQMD staff who were present were not sufficiently familiar with that program to comment. (Gary Rubenstein, Sierra Research; Martin Ledwitz , Southern California Edison Co.; Karl Lany, SCEC; Greg Adams, Los Angeles County Sanitation Districts; Marty Kay, AQMD)

Other Business

The next meeting was scheduled for March 27, 2003 at 1:00 p.m. in AQMD conference room GB.

There was no further discussion, and the meeting was closed.

Status of EMx Technology

The meeting was followed by a presentation by Tom Girdlestone of Emerachem on the status of the EMx (formerly SCONOx) technology.

 

Attachments