• Minutes from the July SRC meeting
• New BACT, Part B listings
• Other Business (Reformatted BACT Guidelines and Small Boiler BACT)

Bob Giorgis commented that he was incorrectly identified as the person who provided the comments (included on page 3 of the minutes) regarding the CO2 plant at BOC Group.

Greg Adams, CSDLAC asked about the format of the minutes. Specifically, will future minutes identify the person who provided the comments, or will the names be grouped together (as was done for the July minutes). Pom Pom responded that it’s sometimes difficult to tell who provided the comments from the audio tapes.

Based on comments received (by Deanna Haines, Sempra Energy) during the July meeting, a sentence in the Part C document concerning achieved in practice criteria was slightly modified in order to provide consistency with the Part A document. The sentence now reads: "A control technology or emission limit found in any of the references above may be considered as AIP if it meets all of the following criteria."

Three new listings for firetube boilers (Application Numbers 364504, 366569, and 366879) were submitted to the SRC for review. Each boiler is natural gas fired and the ratings are as follows: 7.5 MMbtu/hour, 16.3 MMbtu/hour, and 21 MMbtu/hour. The NOx limit for the smaller boilers (i.e., < 20 MMbtu/hour) is 12 ppm, and the NOx limit for the larger boiler is 7 ppm. Ultra-low-NOx burners will be used to achieve the 12 ppm limit and SCR will be used to achieve the 7 ppm limit. The boilers will be source tested to verify compliance with the above limits. (Knut Beruldsen, AQMD)

A new Section I listing for a petroleum solvent dry cleaning machine (Application Number 364307) was submitted to the SRC for review. The operator will be using Exxon 2000 cleaning solvent and the anticipated usage rate is 20 gallons/month. The BACT requirement is use of a dry-to-dry, closed loop system with primary control. The subject unit is manufactured by Renzacci and it is equipped with a refrigerated vapor condenser. (Knut Beruldsen, AQMD)

What is the CO limit for the boiler included in A/N 366569? (Greg Adams, CSDLAC)

The permit does not have a CO limit. (Knut Beruldsen, AQMD)

Has the District received any source testing information regarding the boiler at Coca-Cola (that was permitted last year)? (Deanna Haines, Sempra Energy)

No. As far as I know the boiler has not been installed yet. (Knut Beruldsen, AQMD)

Regarding the Gordon-Piatt burner included in A/N 366879, where is the local Gordon-Piatt office? (Bill Dennison, Dennison & Associates)

Staff will look into this and report back at the next meeting. (Pom Pom Ganguli, AQMD)

What was the cost for the boiler and burner included in A/N 366879? (Deanna Haines, Sempra Energy)

Staff will look into this and report back at the next meeting. (Pom Pom Ganguli, AQMD)

For boiler emissions, does the District look at a 15-minute average or four consecutive 15-minute averages. (Bob Giorgis, CARB)

The averaging time used for BACT purposes is basically the same as what is required by Rule 1146. (Knut Beruldsen, AQMD)

Is there a different CO limit for watertube boilers than for firetube boilers? (Greg Adams, CSDLAC)

Yes. The proposed Part D document specifies a 50 ppm limit for firetube boilers and a 100 ppm limit for watertube boilers. As to why they are different, that goes back to the boiler BACT guidelines adopted by the Governing Board in 1998. Staff will look into this issue in the future. (Pom Pom Ganguli, AQMD)

Regarding the usage of petroleum solvents, the Exxon solvent is a higher flash material that fire departments will only allow in a vacuum or nitrogen inerted machine. There is a problem with this permit, in that items are described in the permit that aren’t on the machine. For example, the permit requires that a temperature gauge be installed and that the door not be opened unless the temperature inside the drum is less than 95 degrees Fahrenheit. These types of machines (and this one in particular) are not equipped with a temperature gauge that measures the temperature in the drum. A surrogate to installing a temperature indicator in the drum would be to install a temperature gauge at the outlet from the refrigerated condenser (as is commonly done with perc machines). (Katy Wolf, IRTA)

Staff will check with the manufacturer regarding your concerns. (Pom Pom Ganguli, AQMD)

What makes the BACT determination for the petroleum solvent dry cleaner unique? (Greg Adams, CSDLAC)

The subject equipment has more advanced emission control technology than what was specified for this equipment category in the 1998 BACT Guidelines. (Marty Kay, AQMD)

The BACT Guidelines were reformatted to consist of one document. The single document will include an overview and Parts A-D. Part B will still be maintained on the AQMD website, and due to its size, Part D will be published as a separate document. Other than the reformatting, there are no other significant changes to the Parts A and C documents. Steven Barhite mentioned that EPA has agreed to approve the LAER/BACT emission threshold levels, but still has some concerns regarding the BACT requirements for relocated minor facilities as reported in the BACT Guidelines. (Pom Pom Ganguli, AQMD/Steven Barhite, U.S. EPA)

The District is currently permitting small boilers at 12 ppm based on the operation of a small boiler at Corcoran State Prison. Several of these newly installed boilers have been source tested and a handout that provides a summary of the results was provided to the audience. Some of the source tests were witnessed by District personnel and in some cases the boilers were being adjusted during the tests. Based on the results of the source tests and the District’s follow-up source tests, the District believes that the 12 ppm NOx limit may have to be raised to 20 ppm to provide an adequate margin of safety. Staff intends to keep the NOx limit for large boilers (i.e., > 20 MMbtu/hr) at 9 ppm.

The Part A document specifies that an emission limit or control technology may be considered achieved in practice (AIP) if it is a BACT/LAER requirement in a NSR permit. The District should add clarifying language that indicates that new emission limits established because of other requirements (such as offsets) or voluntary actions may also at some point in time be considered AIP. (Steven Barhite, U.S. EPA/ Rita Loof, RadTech)

Those situations are covered in the New Technologies/Emission Levels section of Part A, and they are subject to the District’s AIP criteria. Staff will consider adding a sentence to Part A that indicates that these applications may be considered AIP when they meet the District’s AIP criteria. (Pom Pom Ganguli, AQMD)

After new technologies are deemed AIP, will the District consider cost? Some new technologies (e.g., SCONOxÔ for boilers) are very expensive and may not be suitable for many small business applications. (Audience)

For minor sources, cost will be considered and the cost effectiveness methodology is specified in Part C of the BACT Guidelines. Note that for major facilities subject to LAER, cost is not a consideration. (Pom Pom Ganguli, AQMD; Steven Barhite, U.S. EPA)

Is the cost effectiveness methodology in Part C consistent with the ARB’s methodology? For RACT rules the ARB uses a 10% interest rate. (Deanna Haines, Sempra Energy)

For BACT purposes, ARB does not have a published cost effectiveness methodology. If it becomes a major issue, we could work with CAPCOA and address the need for a uniform statewide methodology. (Bob Giorgis, CARB)

There is no mention of small business in the reformatted BACT Guidelines. When did the District remove the small business considerations? (Greg Adams, CSDLAC)

When the District modified the BACT Guidelines to provide consistency with EPA’s LAER policy, cost consideration for small business was removed. (Pom Pom Ganguli, AQMD)

What is the status of CAPCOA’s AIP guidance document? Is their guidance similar to the District’s guidance? (Rita Loof, RadTech)

We have agreed that we will proceed with our document and CAPCOA will proceed with their document. The District’s guidance is more detailed and more consistent with District rules and procedures. Regarding the status of the CAPCOA document, I’m not sure if it’s available to the public yet, or if it will be made available to the public. (Pom Pom Ganguli, AQMD; Mohsen Nazemi, AQMD)

Parker Boiler invested large sums of money to achieve 12 ppm and I believe that our boilers can do it. I don’t believe the data for Parker boilers indicates that the 12 ppm NOx limit should be raised. (Greg Danenhauer, Parker Boiler)

Given that some of the burners (identified in the handout) have malfunctioned, or are otherwise unable to achieve 12 ppm (with an adequate margin of safety), staff feels that more testing is needed before we can say with complete confidence that 12 ppm can be achieved at all times. The Alzeta burner looks promising but more testing (and time of operation) is needed before we can fully support a 12 ppm limit. (Mohsen Nazemi, AQMD)

Some boilers can be tuned to achieve 12 ppm NOx and some cannot. I don’t believe the low-NOx burners will deviate from normal operation (in terms of NOx emissions) any more than the other burners will. Therefore, I cannot understand why the District wants to raise the NOx limit to 20 ppm. (Latif Mahjoob, American Combustion Technologies)

Based on a review of the source test data, the District feels that more time is needed before we can recommend a 12 ppm NOx limit. Additional information is needed regarding emissions during normal operation, and we would like to obtain more information regarding the durability of the burners. (Pom Pom Ganguli, AQMD)

The measuring devices used by the boiler technicians (such as an Enerac) are not very accurate below 12 ppm. Therefore, the initial source test is the perfect opportunity to tune the boiler to lowest emissions while allowing maximum efficiency. After the boiler is adjusted prior to the initial compliance test (using the more accurate analyzer) it should not drift very much after the initial test unless the boiler is not properly maintained. Regarding the source test at Dae Shin (A/N 365335), the boiler was adjusted initially prior to the test and then by the Miura technician during the test in order to maintain high fire for 15-consecutive minutes. It should be noted that the NOx emission was significantly below 12 ppm during this test and the oxygen content was around 5-6%. (Vance Markland, Muira Boiler)

How come the boiler at Packaging Advantage failed the subsequent source tests? (Audience)

The initial source tests were conducted at three fixed conditions: low, medium, and high fire. This is the way the District has always tested boilers. It’s hard to answer that question because I don’t know the operating conditions during the subsequent tests. Perhaps they were run during transient conditions as there is significant variation in load at the Packaging Advantage facility. In order to get an apples-to-apples comparison, all source tests should be run at the same conditions. (Andy Wales, Clayton Industries)

I agree that it’s important to look at an apples-to-apples comparison, but it’s also important to know if these boilers are achieving 12 ppm during all modes of operation. (Mohsen Nazemi, AQMD)

I think the District should adopt a 20 ppm NOx limit for small boilers. This is a reasonable limit that allows us to provide our customers with boilers that operate at high efficiencies and with an adequate margin of safety. (Ed Cancilla, Ajax Boiler)

I have some concerns about a BACT limit that seems to be going up. Last year we were at 5 ppm and now we are talking 20 ppm. I think we need to look at the data in greater detail before we raise the limit, especially since many of the boilers are coming in below 12 ppm. (Steven Barhite, U.S. EPA)

Most of the boilers (included in the handout) have only been operating for one or two months. I would like to know what the sustainability of the emission levels is (i.e., what will the emissions be six months from now). (Bill Dennison, Dennison & Associates)

The data seem to indicate that 12 ppm is too low a limit for this category of equipment. It’s very possible that many boilers will fail to sustain 12 ppm over time and the operators could be subject to enforcement actions. (Deanna Haines, Sempra Energy)

The burner technology used at High Country is the same technology that would be applied to small boilers. The Alzeta burner is relatively simple (there are not very many linkages) and Alzeta feels that the burner is reliable. In the next few months I expect to see ten or twelve source test reports that will document the performance of the Alzeta burner. Therefore, I feel that 12 ppm is a reasonable limit for small boilers. However, customers need to maintain the equipment and we advise them to have the boilers tuned quarterly. (Chris Sentner, RF MacDonald)

If the District raises the BACT limit to 20 ppm, you will open the playing field to all boiler manufacturers and there will be no incentive for anybody to reduce the emissions to lower levels. Nobody will buy 12 ppm burners if they can buy 20 ppm burners that cost less money. (Audience)

I would like to see more source test data before we raise the limit to 20 ppm. Several boiler manufacturers claim that they are achieving 12 ppm and they should be given a chance to prove their claim. Why does the District have to adopt the boiler standard next Friday? (Katy Wolf, IRTA)

There are many permit applications coming in for small boilers and we want to get these permits issued with the appropriate BACT limit. (Pom Pom Ganguli, AQMD)

Is anybody willing to put a CEMS on a boiler for one year so that we can accurately check what is going on with these small boilers? Does the District have the money to do this? (Greg Adams, CSDLAC)

That’s a possible long term solution that doesn’t solve our immediate problem. (Mohsen Nazemi, AQMD)

I think it’s clear that the Clayton boiler at Corcoran (used to establish the 12 ppm limit) wasn’t validated by the testing at Packaging Advantage (on a similar unit). Therefore, the District needs to default to the next level of BACT (for small boilers), which is the 20 ppm limit established in 1998. (Deanna Haines, Sempra Energy)

The District is not prepared to make a final decision on this issue today. Staff intends to meet with our Executive Officer and EPA and we will revisit this issue before next Friday’s Board meeting. (Mohsen Nazemi, AQMD)

Regarding small boilers, I think it’s very important that we separate LAER from minor source BACT. The LAER determination must be consistent with EPA’s LAER policy. I’d like to see something in writing from the District concerning this issue. (Steven Barhite, U.S. EPA)

What kind of data does the District need in order to support a 12 ppm BACT limit? (Vance Markland, Muira Boiler)

One of the problems is that we may not yet have data that is representative of the whole class of small boilers (e.g., hot water , low pressure steam, etc.) and there is still the durability issue. Nevertheless, source tests are coming in below 12 ppm and the Board may adopt this standard. If the Board adopts a higher BACT limit, then you would have to follow the process delineated in Part C of the BACT Guidelines. Most likely this committee would need to review multiple source tests (done at the beginning and end of a twelve months period) and a demonstration of 12 months continuous operation, to make a MSBACT limit more stringent. (Pom Pom Ganguli, AQMD; Mohsen Nazemi, AQMD)

There was no further discussion and the meeting was closed. The next meeting is scheduled for September 28, 2000, in Conference Room GB. Note that meeting information is available on the AQMD web page.