MEETING HIGHLIGHTS

Pom Pom Ganguli welcomed the SRC members and the audience to the first SRC meeting of 2000. Russell Greenhouse was introduced as a new SRC member. The topics listed below were discussed during the meeting.

1. Minutes from the December SRC meeting

4. BACT listings under public review
5. Draft Boiler BACT Guidance
6. Proposed Regulation XIII amendments

Greg Adams provided comments regarding the December meeting minutes. Regarding his comments on page 2 of the December minutes, he said that "LAER can be determined via a simple listing in the RACT/BACT/LAER clearinghouse per the NSR Reform proposal."

Item: There appears to be superfluous information included in the comments section of the Disneyland BACT listing. Much of the information appears to be irrelevant to the BACT determination.

Response: The superfluous information included in the comments section was deleted from the listing.

Item: The District should include language in the comments section for the Children’s Hospital listing that indicates that the CEMS is not certified.

Response: The BACT listing was revised to indicate that the NOx monitoring equipment is not a Rule 218 certified CEMS.

Item: For the boiler at General Dyeing & Finishing, are there any toxics monitoring requirements?

Response: There are not any toxics monitoring requirements for this operation.

A meeting that included several SRC members was held on January 27, 2000, to discuss the role of the SRC. The following topics were discussed during the meeting: the overall purpose of the SRC, the specific SRC role, and the AQMD staff role.

The primary purpose of the SRC is to provide a forum for (1) comment on new (more stringent) BACT determinations that are under 30-day public review, and (2) comment on new BACT listings prior to inclusion in the BACT Guidelines. The SRC is not the proper forum to debate past permitting decisions and related efforts to change a BACT determination.

Regarding new BACT determinations under 30-day public review, SRC members are expected to review and comment on the appropriateness of the proposed BACT determination and respond by e-mail, mail, or fax within the 30-day comment period. For other BACT listings, SRC members will have 30 days to review and comment on the listing. Comments should be submitted to the District by e-mail, mail, or fax and District staff will respond to the comments at the following meeting. SRC members are also expected to review and comment on revisions to Part A of the BACT Guidelines.

The BACT team will present new BACT listings, and they will respond to all written comments (submitted by SRC members and interested parties) at the following SRC meeting. If necessary, Engineering & Compliance staff will be available at the meetings to respond to specific issues.

Bill Wong (District Counsel’s Office) commented that since the SRC is a standing committee established by the Board it could be subject to the Brown Act. The District’s legal staff is currently looking into this issue and will report back to the committee at the next meeting on whether or not the SRC must follow Brown Act requirements.

Damapong Textiles received a permit to construct a 16.5 MMbtu/hour Sellers fire-tube boiler that will be used to supply steam for a dye tank. The NOx emissions from the boiler will be controlled by a Peerless SCR system. The applicant requested a 7 ppm NOx limit in order to minimize the increase to the facility’s potential to emit. The boiler is listed in Section III because at this time 7 ppm NOx is not considered achieved in practice for a boiler rated at 16.5 MMbtu/hour. The boiler will be source tested at three different loads to verify compliance with the 7 ppm NOx permit limit.

Y2K Textiles received permits to construct two identical 16.4 MMbtu/hour Superior boilers that will be used to supply steam for textiles processing operations. The NOx emissions from the boilers will be controlled by Applied Utility Systems SCR systems. The applicant requested an 11 ppm NOx limit in order to minimize the increase to the facility’s potential to emit. The boiler is listed in Section III because at this time 11 ppm NOx is not considered achieved in practice for a boiler rated at 16.4 MMbtu/hour. The boiler will be source tested at three different loads to verify compliance with the 11 ppm NOx permit limit.

Kaiser Permanente received permits to construct four identical 171 horsepower Tecodrive natural gas fired engines. The engines will be used to drive two compressors/chillers that will provide cooling for the facility. The BACT requirement is engine emissions at or below the following amounts (grams/bhp-hr): VOC - 0.15, NOx – 0.15, and CO – 0.60. The emissions will be controlled by Miratech three-way catalytic converters (Model MN-11T-04F) and Tecodrive air/fuel ratio controllers. Source tests will be conducted to verify compliance with BACT limits.

La Paloma Generating Co. received permits to construct four combined cycle gas turbines with a combined output of 1,048 MW electric. The emissions from the fourth unit may be controlled either by a SCO-NOx system, or by SCR and an oxidation catalyst. The emission limits are as follows: PM10 = 17.2 pounds/hour, SOx = 3.73 lbs/hour, NOx = 17.3 pounds/hour and 2.5 ppm, VOC = 2.8 pounds/hour and 0.7 ppm (as propane), CO = 31.4 pounds/hour and either 10 ppm at < 221 MW or 6 ppm at > 221 MW, and NH3 = 10 ppm. All ppm limits are dry basis and corrected to 15% oxygen. The NOx limit is based on a 1-hour rolling average, the NH3 limit is based on a 24-hour rolling average, and the other limits are based on a 3-hour rolling average. Limits exclude up to 3 hours for startup and 1 hour for shutdown. Gary Rubenstein suggested that Section 5B of the listing mention both the SCR & SCO-NOx systems. Staff agreed.

The public notice of intent to establish new BACT requirements for a CO2 plant was distributed on November 19, 1999. One comment was submitted to the District, and the permit condition requiring add-on controls (i.e., a thermal oxidizer) is being appealed by the applicant.

Two public notices regarding new BACT requirements for boilers were distributed on December 16, 1999, and no public comments were submitted to the BACT team during the subsequent 30-day public comment period.

The District is proposing to amend Regulation XIII (New Source Review) to allow different BACT requirements for minor sources. Currently the BACT/LAER requirements for minor and major sources (as defined in Rule 1302) are the same, and cost is basically not considered when determining the BACT requirements for new, modified, and relocated equipment. The District is proposing to establish minor source BACT, and after baseline BACT levels are established, subsequent updates to the BACT Guidelines involving more stringent control technology will include considerations of cost as part of the analysis. The District had its first public workshop regarding the proposed changes to Regulation XIII on January 25, 2000, and the next public workshop is scheduled for March 1, 2000. Staff plans to identify the source categories with economic issues (e.g., boilers, spray booths, etc.) by the March 1 workshop.

A draft boiler BACT implementation guidance document that supercedes and updates the previous guidance documents was discussed during the meeting. The document basically defines large boilers as those that are rated at greater than 20 MMbtu/hr, and the suggested BACT requirement is 7 or 9 ppm NOx, depending on whether or not SCR or an ultra low-NOx burner is used. The suggested BACT requirement for small boilers is 12 ppm NOx based on the 8.1 MMbtu/hr Clayton boiler operating in Corcoran, California. In addition to providing information regarding BACT requirements for small and large boilers, the document also provides information regarding BACT for small process heaters and other external combustion devices, BACT circumvention issues, and the public review process for new (more stringent) BACT determinations.

Ed Cancilla commented on the boiler operation at the Corcoran State Prison. He feels the District should not reference this boiler operation because: (1) the source test report does not provide boiler load information (therefore, you cannot be sure that the boiler can achieve 12 ppm NOx at low, medium, and high fire conditions); (2) the boiler is not operated all year round (i.e., it is a seasonal use application); and (3) the San Joaquin Valley APCD does not consider it BACT. Pom Pom Ganguli responded that the source test report is currently being evaluated by the District’s Monitoring & Source Test Engineering section and that staff would respond to Ed’s comments at the next meeting. Steve Barhite commented that once a permit is listed in the RACT/BACT/LAER clearinghouse it becomes a LAER candidate irrespective of six months continuous operation at 50% load.

Deanna Nichols provided a draft permit advisory for boilers at the last SRC meeting. District staff has reviewed the document and detailed comments will be provided at the next SRC meeting. Generally speaking, staff believes the permit advisory should focus on (1) what are the BACT emission levels that need to be met, (2) what technologies are available to meet these technologies, and (3) what are the advantages and disadvantages of these technologies.

There was no further discussion and the meeting was closed. The next meeting is scheduled for February 24, 2000, in Conference Room GB. Note that meeting information is available on the AQMD web page.