Pom Pom Ganguli welcomed the SRC members and the audience to the tenth SRC meeting of 1999. The topics listed below were discussed during the meeting.

1. New BACT determinations for the following categories of equipment: I.C. Engine – Portable, Compression Ignition; I.C. Engine – Emergency, Compression Ignition; I.C. Engine – Emergency, Spark Ignition; Storage Tank – Fixed Roof; Mixer/Blender – Wet; Liquid Transfer and Handling – Container Filling (new category); Liquid Transfer and Handling – Tank Truck and/or Rail Car Bulk Loading, Class A; Screen Printing and Drying; Dryer/Oven – Others, Direct and Indirect Fired; and Direct Injection Polystyrene Manufacturing, Using Blowing Agent
2. Semiannual SRC Status Report
3. Review of boiler BACT/LAER
4. Proposed revisions to Part A achieved in practice criteria

No comments were received regarding the minutes from the September SRC meeting.

Item: Why was use of a solvent-based photoresist developer (A/N 352219) deemed BACT when water based developers are available?

Response: The equipment operator is using a newly developed dielectric coating for printed circuit boards and the supplier of the coating is not aware of any water based developers that could be used to develop the photoresist coating.

Item: For the lithographic printing operation (A/N 356664), what percentage of the VOC emissions are due to cleanup solvent usage?

Response: The average VOC emissions are 6.5 pounds/day from the inks and 13 pounds/day from the cleanup solvents.

Item: Are the boilers at Kal Kan Foods (A/N 181183) and Darling International (A/N 186624) base loaded or variable loaded?

Response: Both boilers could be characterized as variable loaded, and the SCR equipment keeps up with the load changes. So far, the facilities have not had any problems meeting their permit limits. One of the facilities has been operating with the same catalyst for eight years and it is still doing a good job.

District staff recently upgraded the BACT web page to include SRC meeting information, both for future and past meetings. Also, in the future, SRC members and interested parties will receive information regarding upcoming SRC meetings via e-mail or fax. Persons interested in getting on the District’s BACT mailing list can contact Knut Beruldsen at (909) 396-3136.

Kiewit Pacific Co. is operating a 755 horsepower diesel engine at various locations in the District. The BACT requirement for the engine is emissions at or below the following amounts (grams/bhp-hr): VOC - 1.0, NOx – 7.0, CO – 8.5, and PM10 – 0.38. The applicant provided emissions information that was generated by the engine manufacturer (for a similar engine), and the information indicates compliance with BACT requirements. The engine is not an EPA Part 89 certified engine (even though it meets the Part 89 emission limits), and it is not operating with add-on controls.

Cummins Cal Pacific applied for a Certified Equipment Permit for a 68 horsepower diesel engine. The certification is for emergency electrical power. The BACT requirement is engine emissions at or below the following amounts (grams/bhp-hr): VOC - 1.0, NOx – 6.9, CO – 8.5, and PM10 – 0.38. The engine manufacturer (i.e., Cummins) supplied emissions information, and the information indicates compliance with BACT requirements. A diesel oxidation catalyst (DOC) will be used to achieve the required PM10 emission limit. The assumed PM10 control efficiency (of the DOC) is 25%. The DOC cost approximately $600.

The Coachella Valley Water District will operate three identical Perkins diesel engines (325 horsepower each). The engines will be used to drive emergency electrical generators. The BACT requirement is engine emissions at or below the following amounts (grams/bhp-hr): VOC - 1.0, NOx – 6.9, CO – 8.5, and PM10 – 0.38. The engines have been certified to comply with US EPA and CARB mobile off-highway emissions levels per ISO 8178 D2, and no add-on controls will be necessary in order to comply with BACT requirements.

The Orange County Flood Control District will operate a 750 horsepower natural gas fired engine (with LPG backup fuel). The engine will be used to drive an emergency flood control pump. 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. A three-way catalyst and air/fuel ratio controller will control the emissions from the engine in order to comply with the BACT requirements. The cost of the air pollution control equipment is approximately $24,000.

Van Waters and Rogers is planning to operate a new chemical distribution facility in Commerce, CA. The VOC emissions from the equipment will be vented to a thermal oxidizer. The assumed overall VOC control efficiency of the thermal oxidizer is 95%.

Solutions Unlimited is using UV coatings (and one water based coating) for their screen printing operations. The UV coatings contain a maximum of 0.5 pounds/gallon VOC. The water based coating is a scratch-off ink that contains 4.9 pounds/gallon VOC. The BACT determination for this operation is use of UV coatings and a water based scratch-off coating. Due to the low quantity of VOC emissions, add-on controls are not required.

Dart Container Corp. received permits to construct a polystyrene foam extrusion operation. They will be using a VOC blowing agent, and the VOC emissions will be vented to a thermal oxidizer with a minimum VOC destruction efficiency of 98%. The facility has an existing cap of 3,281 pounds/day of VOC, and that cap will not increase as a result of this project.

A 4 MMbtu/hour oven will be used to soften the polystyrene plastic prior to molding operations. The oven will be fired with Maxon (Model 408) burners, and the BACT requirements are NOx and CO emissions at or below 30 and 2000 ppm, respectively. A source test will be performed in order to ensure compliance with BACT requirements.

• What is the BACT trigger for emergency engines? (Karl Lany)

• Is the Cummins engine an EPA Part 89 certified engine. If so, why do they need a DOC? (Greg Adams)

• For the spark-ignited engine with a 3-way catalyst, how will you get any reductions when the engine only operates for 30 minutes a week? Also, how much did the control equipment cost? (Deanna Haines)

• By requiring sophisticated add-on controls for the clean-fueled engines, the District is creating a disincentive for equipment operators to use clean fuels. Since the District generally encourages operators to use clean fuels, this issue needs to be reviewed. A more appropriate standard would be NOx at 6.9 and CO at 8.5 grams/bhp-hr. (Karl Lany)

• What types of containers are they filling, for example, spray cans? (Greg Adams)

• Is the 95% overall VOC control efficiency a permit requirement? (Gary Rubenstein)

• What are the NOx emissions from the thermal oxidizer? (Audience)

• Is the non volatile organic liquids definition specified in the BACT Determination Form a standard definition that could be applied to other permit units? (Charlie Aarni)

• For the container filling operation, what’s happening to the HCl emissions created when perc is vented to the thermal oxidizer? (Ed Camarena)

• The facility has a 152 pounds/day VOC emissions limit. This seems high given that they are using UV coatings. Is this a new facility? (Audience)

• Printing equipment that uses UV coatings is exempt from written permit. How come permits were required at Solutions Unlimited? (Greg Adams)

• What is the overall control efficiency of the thermal oxidizer? (Katy Wolf)

• Given the earlier BACT determination at Elm Packaging, why was Dart Container allowed to use a VOC blowing agent? (Gary Rubenstein)

• The Maxon 408 burner is not a low-NOx burner and it will not meet the 30 ppm NOx limit. (Jim Waggoner)

The written status report provides an overview of the accomplishments of the SRC and BACT staff for the first six months of 1999, and it includes (among other things) a brief description of the new Part B BACT listings, the BACT website, and the revised Part A BACT Guidelines document.

At the request of the Boiler Working Group and the SRC, District staff committed to performing a detailed evaluation of the BACT determination for the LTO system at Alta Dena Dairy. The evaluation has been completed and it has been determined that there is insufficient data to support the achieved in practice designation at Alta Dena Dairy. Therefore, staff will add language to the BACT listings for Alta Dena Dairy and Fansteel that indicate that this technology (although effective) has not yet met the achieved in practice criteria specified in Part A of the BACT Guidelines. In light of the developments regarding the BACT determination at Alta Dena Dairy, revised boiler BACT guidance was provided to permitting staff on October 5, 1999. The guidance document recommends a case-by-case analysis that considers (at a minimum) use of SCR or ultra low-NOx burners for all boilers subject to BACT. SCR and ultra low-NOx burners are considered achieved in practice technologies for controlling the NOx emissions from boilers, and examples of several operations (that meet the District’s achieved in practice criteria) are referenced in the October 5, 1999, BACT guidance document.

Based on a review of the EPA’s achieved in practice guidance, staff is proposing to amend the list of sources (included on Page 9 of the District’s Part A document) used to identify achieved in practice BACT. The revised list includes any New Source Review permits (issued by the District or other agencies) that contain BACT/LAER related permit limits. Note that this does not include cases where someone volunteers to accept a permit limit below current achieved in practice BACT. When those situations arise in the District, the BACT listing will contain a note that states that the permit limit is not currently achieved in practice. Staff is also proposing to amend the achieved in practice criteria for reliability as follows: "All control technologies must have been installed and operated reliably for at least six months. If the operator did not require the basic equipment to operate daily, then the equipment must have at least 183 cumulative days of operation. During this period, the basic equipment must have operated: 1) at a minimum of 50% design capacity; or 2) in a manner that is typical of the equipment in order to provide an expectation of continued reliability of the control technology."

• The District’s LTO report states in the conclusion that there were not any sodium hydroxide emissions at the Alta Dena demonstration site. The statement should be revised to indicate the following: (1) sodium hydroxide was not used (in the scrubbing solution) at Alta Dena, and (2) when used, there is a potential for sodium hydroxide emissions in the scrubber exhaust. (Gary Rubenstein)

• The District’s LTO report states in the conclusion that ozone slip was measured at below 1 ppm. You should add language that indicates that they used a non reference test method to measure the ozone emissions. (Deana Haines)

• BACT for small boilers changed significantly as a result of the October 5, 1999, guidance document. As a result of this new BACT guidance, the District rejected many recently submitted permit applications because the boilers were designed to meet the old BACT limit (i.e., 20 ppm). Since projects often go several months from design to when an actual permit application is submitted, industry needs to be alerted to potential BACT changes (in advance) in order to avoid this situation in the future. (Audience)

• How can we get information on the burners that meet 9 ppm? (Audience)

• More guidance regarding the implementation of "technology transfer" would be helpful. For example, how do you define similar exhaust streams? Also, although technically feasible, SCRs are not cost effective and achieved in practice for small boilers. (Audience)

• The District should consider boiler efficiency when applying BACT to a specific unit. Some burners may achieve 9 ppm NOx but the efficiency could be well below 80%. Perhaps the District could allow an alternative unit of measurement (instead of ppm) that is based on NOx emissions per unit of output. (Audience).

So noted. (Pom Pom Ganguli)

• I recommend that we reconvene the Boiler Working Group (chaired by Deanna Haines) and let them summarize the issues that have arisen during this meeting. After summarizing and reviewing the issues, we can discuss them again at the next meeting. (Greg Adams)

• I feel that ultra low-NOx burners and SCR are not achieved in practice for small boilers and that the appropriate BACT limit should be 20 ppm. Will permit applications that reflect this be accepted by the District? (Ed Cancilla)

• In addition to recognizing the performance of the equipment, the achieved in practice reliability criteria should recognize the setting (i.e., industry) in which the equipment is operated. For example, a gas turbine operating without heat recovery equipment cannot meet the same emission limits as a combined cycle gas turbine. (Gary Rubenstein)

• If the District is going to lower the bar regarding the reliability criteria, then we need to clarify what is meant by effectiveness. I would suggest source test requirements at the beginning and end of the demonstration period in order to demonstrate compliance with permit limits. Also, when CEMS are required, the equipment should be required to achieve 100% compliance with the permit limits during the entire demonstration period (including breakdowns). For enforcement purposes, the EPA does not recognize exceedances from permit limits due to equipment breakdowns. (Gary Rubenstein)

• The reliability criteria should specify that the control equipment must operate 100% of the time that the underlying basic equipment operates. Also, the criteria should specify a maximum allowable period to achieve 183 days of cumulative operation. Interested parties need assurance that the equipment did not experience frequent breakdowns and needed several years to achieve 183 days of cumulative operation. (Greg Adams)

• How will the proposed Part A revisions get approved? Also, I would recommend a minimum of 365 days of cumulative operation. (Greg Danenhauer)

• I feel that the new reliability criteria lowers the bar, and that vendors may prematurely introduce technologies that are not necessarily reliable. I think that the minimum 50% load criteria is appropriate. (Deanna Haines)

People interested in getting involved with the Boiler Working Group should contact Ms. Deanna Haines at 213-244-5819 (e-mail dhaines@sempra.com).

There was no further discussion and the meeting was closed. The next meeting is scheduled for November 18, 1999, at the same location. Note that meeting information is available on the AQMD web page. In addition to the next SRC meeting, there will be a boiler BACT meeting at an earlier date .