SCIENTIFIC REVIEW COMMITTEE MEETING NO. 5

May 25, 2000

MEETING HIGHLIGHTS

 

SRC Members

 

Greg Adams

Deanna Nichols (for Deanna Haines)

Bob Giorgis

Ron Wilkniss (not present)

Martin Ledwitz

Karl Lany (not present)

Russell Greenhouse (not present)

Stan Romelczyk (via telephone)

Larry Felix (not present)

Hal Taback (not present)

Ted Guth

Bill Dennison (not present)

Katy Wolf

Steve Barhite

Ed Camarena (not present)

Robert Zweig (not present)

James Provenzano (not present)

Gary Rubenstein

 

 

 

 

Attendees

 

Lily Trans

David Miyanchi

Peter Moore

Richard David

Todd Paxman

Larry Ashton

Joyce Clark

Lance Brown

Boris Reyes

Bob Soreshsen

Charlie Aarni

Rita Loof

Imran Husain

Wayne Najarm

Greg Danenhauer

Vance Markland

Hank Wedaa

James Manley

Frank Rice

Richard Freet

John Niu

John Clark

Viji Sadasivan

Steve Hernandez

M. Delgards

Bill Pearce

John Clarkson

 

 

 

 

 

AQMD Staff

 

Pom Pom Ganguli

Marty Kay

Knut Beruldsen

Dave Schwien

Rod Millican

Fred Lettice

C.S. Bhatt

Norman Ng

Hemang Desai

Minh Pham

The handouts and audiotapes can be obtained through the Public Records Section of the Chief Prosecutor’s Office. There may be a fee for this service.

Overview

Pom Pom Ganguli welcomed the SRC members and the audience to the fifth SRC meeting of 2000. The topics listed below were discussed during the meeting.

April Meeting Minutes

Minor Source BACT Guidelines

A correction was made that even though several air districts in California do not have minor source BACT Guidelines, they do consider economic, energy and environmental impacts in making BACT determinations for units at low emission threshold levels, and require LAER for units at high emission threshold levels. (Bob Giorgis)

 

Cost for Control Technologies

District staff received permission from vendors to release their quotes for the costs of control equipment. However, the vendors requested the District to withhold names for the quotes. Cost information can be obtained by contacting District staff. (Marty Kay)

 

Permitted Boilers at 12 ppmvd NOx Level

District staff provided a list of 22 small boilers (£ 20 MMBtu/hr) permitted at NOx levels between 5 ppmv and 12 ppmv. Eight of these boilers (bolded on the list) are listed on the AQMD website. There are about 6 different vendors that can provide units meeting the 12 ppmv limit; two vendors claim to meet 9 ppmv and 5 ppmv limits. The list also provides information on large boilers permitted at 7 or 9 ppmv limit.

Since a representative number of small boilers permitted at 12 ppmv are already listed on the web, the District will stop listing every single boiler permitted at this level. The same policy applies to other equipment such as spray booths and internal combustion engines. The District will continue updating the BACT Guidelines on the web to 1) reflect up-to-date operating history of the small units that have been listed; 2) list additional large boilers equipped with ultra low NOx technology; and 3) provide information on new emission levels and emerging technologies. (Marty Kay and Pom Pom Ganguli)

 

Source of CO2 at Refinery

For clarification, staff has added to the BACT listing of a CO2 plant located at BOC Group Inc. (A/N 350893) an explanation that the treated CO2 stream at this facility is coming from a hydrogen plant of a nearby refinery. (Marty Kay)

New BACT, Part B Listings

Section I

New Section I listings that were submitted to the SRC for review include the following:

 

Section II

New Section II listing that was submitted to the committee for review contains information for a permit issued by Massachusetts Department of Environmental Protection to Sithe Mystic Development LLC for Mitsubishi Heavy Industries (MHI) combustion turbine generators. Permit limits are 2 ppmv NOx, 2 ppmv CO, 1 ppmv VOC (unfired), 1.7 ppmvd VOC (duct fired), and 2 ppmv NH3. (Knut Beruldsen)

The following issues were addressed and discussed:

In the past, Region I has issued several permits that contain a 3.5 ppmv NOx limit during duct firing. This permit does not contain such a limit. (Knut Beruldsen, Gary Rubenstein)

District staff highlighted the following information 1) this is the first permit issued that contains a 2 ppmv limit for NH3 slip; 2) NH3 was precursor for PM10. Cost was considered in determining PSD BACT for NH3 slip in Massachusetts. This consideration however is not applicable in PM10 and ozone non-attainment areas; 3) CEMS will be installed and operated to demonstrate compliance with NH3 limit; and 4) parametric monitoring will be used to demonstrate compliance with PM/PM10 limit. (Marty Kay, Pom Pom Ganguli)

EPA and ARB staff informed the committee that ARB and EPA Region IX have been diligently working on the NH3 BACT/LAER issue, and suggested that even though the 2 ppmv NH3 slip has not been demonstrated as LAER at this time, one should evaluate the NH3 slip limit when doing a LAER analysis for this type of equipment. (Bob Giorgis, Steve Barhite)

District staff will verify whether the VOC limits are specified as propane or methane. (Gary Rubenstein, Pom Pom Ganguli)

 

Section III

New Section III listing that was submitted to the committee for review contains information on a Kewanee, fire tube, 4.2 MMBtu/hr steam generator equipped with SCONOX and permitted at 2 ppmv NOx. The cost provided by the supplier for SCONOX is about twice the cost for the Kewanee boiler. This is the first installation of SCONOX technology on a small size boiler. When this technology is proven to be achieved-in-practice, this listing will be moved to Section I. (Knut Beruldsen)

In addition, staff received one written comment from Hal Taback regarding the 50 MMBtu/hr Tulsa Heaters Inc. coker charge heater. Hal suggested that staff revisit the 5 ppmv limit for NH3 slip and consider adjusting the limit after 3 years of operation. Staff will revisit the NH3 slip limit and consider the applicability of technology transfer in context of the Massachusetts gas turbines recently permitted at 2 ppmv. Permit to construct for this heater will be issued after 30-day public review period closes, and the listing will be posted on the web shortly after that. (Pom Pom Ganguli)

Other Business

Draft Parts C and D of BACT Guidelines

So far, staff received only one comment letter from the Gas Co regarding the process of developing the 12 ppmv limit for boilers. Staff received no other comments at this time. The comment period is still open. (Pom Pom Ganguli)

 

Draft Revision to Part A of BACT Guidelines

Staff will revise Part A of the BACT Guidelines to make clear that Part A will address LAER for major sources; and Parts C and D will address BACT for minor sources. (Pom Pom Ganguli)

 

Achieved in Practice (AIP) Criteria Update

The following updated information on AIP was provided to the committee and the audience:

In order to provide applicants and vendors a clear understanding of what can be considered achieved-in-practice, the District would like to reconvene the SRC Subcommittee to focus working on several issues related to the AIP criteria such as

1) 6 months of operation, 2) capacity factor, 3) source testing, and 4) CEMS requirements. (Pom Pom Ganguli)

Copies of the draft guidance on AIP criteria developed by CAPCOA were provided to the committee and the audience. Upon District/ARB's request, CAPCOA may conduct a workshop to discuss this issue, and provide public the opportunities to make comments and participate in the development process. (Bob Giorgis, Pom Pom Ganguli)

Copies of portions of the preamble of the proposed EPA 40 CFR Parts 51 and 52 related to this issue were provided to the committee and the audience. EPA staff informed the committee and the audience that the AIP criteria (6 months operating at 50% capacity) in the preamble were developed to address emerging technologies and not for use as a hurdle for day-to-day permitting activities involving examples of technologies permitted by an air agency. (Steve Barhite)

A separate effort from the District Home Rule Advisory Group to address the issues related to the AIP criteria was acknowledged. Copies of the draft input from this group to CAPCOA on this issue were provided to the committee and the audience. (Pom Pom Ganguli)

There was no further discussion and the meeting was closed. The next meeting is scheduled for June 22, 2000, in Conference Room GB. Note that meeting information is available on the AQMD web page.