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.

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

• Responses to Comments from September 6^th Meeting
• New BACT - Part B Listings
• Other Business

There were no comments on the September 6^th meeting

Following are the responses to comments presented at the September 6^th meeting.

The applicant did not know exactly how much the burner cost. He paid one price for the cost of the boiler, burner and some additional boiler room remodification. (Marty Kay, AQMD)

Steve Hernandez of Pacific Environmental Services, a consultant for the project, said that the cost was about $30,000.

There are several issues associated with this application (a petroleum solvent drycleaner) that need to be resolved. The answer to this issue will be provided in the next meeting. (Marty Kay, AQMD)

This listing is for a 110 H.P. internal combustion engine that is used in case of emergency. The engine is not designed nor certified to meet the nonroad standards such as 6.9 g/bhp-hr NOx. The applicant is proposing to install a catalytic control system offered by Ceryx Incorporated. This control system consists of two catalysts in series 1) a lean NOx catalyst, which acts as a reducing catalyst to selectively reduce NOx to N2, and 2) an oxidation catalyst which reduces CO, ROG and PM. Diesel fuel is injected to the exhaust stream prior to the lean NOx catalyst. September 30, 2000 is the start up date for this engine.

Discussion: There were questions about how the technology works, so staff will report back to the SRC committee on the operation and regeneration of the catalysts. (Marty Kay, Pompom Ganguli, AQMD)

This equipment is designed to use UV inks inclusively in printing labels. The press is operated under a facility's cap of 1,200 lbs in any one calendar-month. This facility operates several other flexographic presses that use water-based inks so that they can provide their customers the type of printing they want. (Marty Kay, Pompom Ganguli, AQMD)

Discussion: Katy Wolf (IRTA) asked why one of the permit conditions required compliance with Rule 1401 – New Source Review of Toxic Air Contaminants, and if the equipment used materials subject to Rule 1401. Staff said that the equipment did have to comply with rule, but that they would look into the second question and report back.

This equipment is used to print container lids with UV inks. The press has six printing units and one curing system. This facility operates several lid and pail printers that use UV inks exclusively. The equipment was permitted recently in June 2000. (Marty Kay, AQMD)

The recent BACT listings for printing presses prompted the following discussion on the process of determining BACT/LAER for printing presses between the SRC members and the District staff.

What percentage of new, modified or relocated permits in printing have to use UV-cured inks before the District can start considering UV as BACT/LAER? (Katy Wolf, IRTA))

AQMD does not have the data to answer this question. (Pom Pom Ganguli, AQMD)

Couldn't UV be BACT for certain types of printing, label printing, for example? (Katy Wolf, IRTA)

Depending on the job, depending on the characteristics, UV inks have some characteristics that do not always meet the customers' needs. (Bill Dennison, Dennison & Assoc.)

The majority of VOC emissions is not from inks. Applicability of UV inks depends on substrates, products type and product quality. (Gerry Bonetto, Printing Industries Assn.)

Solvents are used to clean up both water-based and UV inks presses. Some printers claim that they use less solvent to clean a water-based ink press than a UV ink press. Some printers claim that they use more. (Pompom Ganguli, AQMD; Kathy Wolf, IRTA; Bill Dennison, Dennison & Assoc.)

Separating out a source category is contrary to EPA position because that gets into the questions of transfer technology and costs. The source category should be kept broad, and BACT/LAER will be determined on a case-by-case basis. However, in the minor source guidelines, we have the ability to do that under state law. (Pom Pom Ganguli, AQMD)

USEPA does want to have transfer of technology flexibility in broad categories; we do not want to go down to smaller and smaller categories. However, I have not seen a lot of effort in incorporating UV technologies or control technologies in the printing industries. That is something that the group should look at. (Steven Barhite, EPA)

Best Labels (a facility reviewed last month) have some presses that use water-based inks and others that use UV inks. They use the press that best fits their customer needs. The permitting staff is unable to specify UV ink for an entire category or sub category. (Marty Kay, Pompom Ganguli, AQMD)

What data can be presented to the committee to show that it is not possible to do that? (Katy Wolf, IRTA)

That is not the purpose of the committee. The purpose of the committee is to review the BACT Determination, and not assist the permitting staff in making BACT Determinations. We are here to get examples and input from you for discussion. (Pom Pom Ganguli, AQMD)

I'm concerned that AQMD is only requiring compliance with Rule 1130 as BACT for printing equipment, unless the applicant proposes more stringent emissions levels. (Katy Wolf, IRTA))

I have no proof of that. There are processes for appeal of permits. Committee members can (and have) point out when they think a more stringent BACT is appropriate. (Pom Pom Ganguli, AQMD)

Based on our permitting experience with the District, if permitting engineers felt that something was superior to what we were proposing, they would ask for a demonstration on why we could not use that. I would think that if the permitting engineers truly felt that UV was more appropriate for a particular application when water based was being proposed, they would ask for that. (Karl Lany, SCEC)

How many sources are coming through with either a control device or UV ink requirement, as opposed to no control required? (Steven Barhite, EPA)

In many cases, BACT and source specific rule requirements for printing industries are the same because the requirements in specific rules are tightened with time. We can pull some data and see what is the status of technology in printing industry, and get back to you two months from now. I will discuss this with our Executive Management and get back to you with recommendations. If we do this research project, we may distract ourselves from the main purpose of this committee, which is reviewing the listings. (Pom Pom Ganguli, AQMD)

Some source specific rules are at BACT level, and others are above BACT level. BACT is never less stringent than the requirements in source specific rule; for example the NOx standard in Rule 1134 is 9 ppmv while the BACT standard is about 2 ppmv. (Greg Adams, SDLAC)

At the last meeting, District staff informed the committee that the District was leaning towards a 20 ppmv NOx standard in the minor source BACT guidelines for boilers under 20 mmbtu/hr. Since then, District staff met and discussed the issues with EPA/ARB, public, boiler manufacturers, and our technical staff. If the District set NOx limit back up to 20 ppmv, it would not be fair to the boiler manufacturers that had spent their resources to develop new technology in order to achieve the 12 ppmv limit. Because of the above concerns, the District has decided that it is premature at this time to raise the standard to 20 ppmv, and recommended a 12 ppmv NOx limit for boiler under 20 mmbtu/hr. (Pom Pom Ganguli, AQMD)

We disagree with the 12 ppm BACT standard and disagree more testing is needed. (Imran Husain, Gobal Equipment Sales, Larry Ashton, Raypack Boiler)

Current source test data are inconclusive. Approximately 80% of the source test data collected up to now were under 12 ppmv. But the 12 ppmv limit may not be sustainable. To assure sustainability, accuracy, representative, and completeness 1) tests that were done six or eight months ago need to be repeated; 2) additional tests on different boilers need to be performed; 3) equipment need to be tested at three loads; 4) testing need to be observed; and test protocols and results need to be reviewed by AQMD technical staff. It is expected that all above requirements would be completed by December of this year. (Pom Pom Ganguli, AQMD)

USEPA has also reviewed the data and agrees with AQMD's recommendation. The data could even support a lower LAER determination. (Steve Barhite, USEPA)

AQMD has not required much periodic testing of small boilers in the past. What will be required for the new limits? (Vance Markland, Muira Boiler)

Enforcing the BACT standards for small boilers (2-20 mmbtu/hr) can be done by either 1) requiring source testing at a two or three-year interval; 2) offering a registration program for boiler manufacturers; or 3) requiring alternative surrogate monitoring. For boilers larger than 20 mmbtu/hr, the District may require testing at 1-year interval or less. We will discuss this with AQMD permitting staff and return to the SRC for discussion. (Pom Pom Ganguli, AQMD

Proposed amendments to Rule 1146 include a testing requirement every two years. (Karl Lany, SCEC)

The following minor changes in the Overview and Part A of the BACT Guideline have been made, and can be found in the Board package:

• A footnote has been added in the Overview section of the BACT Guideline to indicate that EPA has not approved the minor source relocation concept.
• Part A has been revised to indicate that technologies reflected in permits may be there for reasons other than BACT (e.g. facility may install control device to avoid offset.)

Since the Governing Board was short of time in September Board Hearing, the agenda item related to NSR/BACT Guidelines was postponed to October 20^th meeting. (Pompom Ganguli, AQMD)

In response to questions, District staff provided the following information:

• Minor source BACT Guidelines reflects current LAER.
• Cost analyses for four source categories 1) spray booths, 2) boilers, 3) degreasers, and 4) gas turbines are provided in the Board package for information only. The procedures for cost effective analysis are in Part C of the Guidelines. These procedures must be followed in case the District needs to make BACT standards more stringent in the future.
• AQMD will ask for SRC input on when the MSBACT guidelines should be updated.
• If the District through its investigation finds that the 12 ppmv limit cannot be achieved, the District will revise the limit at the time of issuing permits to operate

The marginal cost criteria are so high that MSBACT will likely remain the same as LAER in the future. (Greg Adams, CSDLA)

Is it correct that there is a District policy to avoid NH3 use and emissions for NOx control projects? (Hal Taback)

The District does not have a policy on what is BACT/LAER for ammonia slip. Ammonia is a pollutant regulated under NSR and is subject to BACT. The ammonia slip is a case-by-case determination. (Pompom Ganguli, AQMD)

There was no further discussion and the meeting was closed. The next SRC meeting is scheduled for October 26, 2000, in Conference Room GB. Meeting information is available on the AQMD web page.

AQMD Home Page
This page updated: 10/20/00
URL: http://www.aqmd.gov/bact/Minutes09-28-00.htm