Jack Broadbent welcomed the SRC members and the audience to the eleventh SRC meeting of 1999. The topics listed below were discussed during the meeting.

1. New BACT determinations for the following categories of equipment: Mixer/Blender – Wet; Polyurethane Tube Manufacturing (new category); Degreaser – Batch Vapor Cleaning; I.C. Engine – Fire Pump, Spark Ignition; I.C. Engine – Emergency, Compression Ignition; and I.C. Engine – Stationary, Non-Emergency
2. 30-day Public Review for a CO2 Plant
3. Review of boiler BACT/LAER
4. Proposed revisions to Part A of the BACT Guidelines (achieved in practice criteria)
5. Proposed revisions to Regulation XIII

The minutes from the October SRC meeting will be provided with the mail out for the next SRC meeting.

Item: Is the non volatile organic liquids definition specified in the BACT determinations for the storage tanks, mixing tanks, and liquid handling and transfer operations at the new Van Waters & Rogers facility (A/Ns 353730, 353756, 353759, and 353762) a standard definition that can be applied to other permit units?

Response: No, the boiling point and organic vapor pressure cutoffs specified in section 5A1 of the BACT determinations are specific to these permits. These cutoffs are identical to the boiling point and organic vapor pressure cutoffs specified in Rule 219(m)(3).

Item: What are the impacts associated with venting the perc emissions to the thermal oxidizer (A/N 353759)?

Response: The total perc emissions that will be vented to the thermal oxidizer will be a maximum of 2.75 pounds/hour and 25 pounds/year. Assuming 80% overall control for the container filling operations, the cancer risk associated with the perc emissions will be below Rule 1401 significance thresholds. In addition, the HCl emissions created by the combustion of perc will be below Rule 1401 significance thresholds.

Item: For the polystyrene foam sheet manufacturing operation at Dart Container (A/N 347406), why were they allowed to use a VOC blowing agent?

Response: Dart experimented with non-VOC blowing agents at the Pennsylvania facility, and they were not able to produce a product that meets their specifications for strength and appearance. In lieu of a non-VOC blowing agent, the VOC emissions from their operation will be vented to a thermal oxidizer.

Item: For the polystyrene foam sheet manufacturing operation at Dart Container (A/N 347406), what is the anticipated collection efficiency of the air pollution control system?

Response: The collection efficiency must be adequate to ensure compliance with the Rule 1175 limit of 2.4 pounds VOC per 100 pounds of raw material processed. Assuming the average amount of blowing agent injected in the polystyrene is 4.5 pounds per 100, the collection system must capture at least 2.2 pounds VOC per 100 in order to comply with Rule 1175. Dart is required to source test the system and determine compliance with the Rule 1175 limit.

Item: The Maxon 408 burners proposed for the oven at Dart Container (A/N 347376) will not achieve 30 ppm NOx. Also, when the oven is source tested make sure that the NO2 fraction of the NOx is accounted for in the reported results. For this type of operation the NO2 fraction could be as high as 20-25%.

Response: The Maxon 408 is not a low-NOx burner, but for this application Dart feels that the burners will achieve at or below 30 ppm. Dart will perform some preliminary testing and if 30 ppm is not achieved, then they will replace the burners with low-NOx burners that can achieve 30 ppm.

Item: By requiring sophisticated add-on controls for clean-fueled standby engines (A/N 359876), the District is creating an additional hurdle for applicants who may want to use this type of equipment because the clean fueled engines already cost more (and are more difficult to certify for standby applications) than similarly sized diesel engines. The BACT limits for standby engines should be based on what is achieved in practice for diesel engines.

Response: The District is sensitive to these concerns and staff is currently looking at a 1.5 grams/bhp-hr NOx standard instead of a 0.15 grams/bhp-hr standard for the standby applications. Note that the NOx emissions from an uncontrolled rich burn engine are typically higher than the NOx emissions from a similarly sized diesel engine so some degree of NOx control will be required for the clean-fueled engines.

Item: Why does Solutions Unlimited have such a large VOC facility cap (A/N 341072)?

Response: The permit applications were submitted to reflect a change of location, and the facility cap was transferred from the old location to the new location. The actual VOC emissions resulting from the usage of the UV coatings should be well below the facility cap. Also, the reason permits were required for this operation (in light of the Rule 219 amendments that exempt UV coatings) is because VOC-containing cleanup solvents are used at this facility.

The District is required to distribute a public notice with a 30-day public comment period prior to issuing a permit with a new, more stringent BACT emissions limit. In accordance with this requirement (specified in Part A of the BACT Guidelines), staff prepared a draft public notice that provides details regarding the new BACT requirement for a CO2 plant that will be located at the Chevron refinery in El Segundo. The proposed BACT requirement is venting the VOC emissions from the CO2 plant vent to a thermal oxidizer that provides at least 98% VOC control. The thermal oxidizer will reduce the VOC emissions from the CO2 plant by approximately 10 pounds/day. The public notice will be sent to everyone on the BACT and Proposed Rule 1189 mailing lists.

• Should SB456 apply to this BACT determination? (Greg Adams)

• Does this project set a standard for all regenerative thermal oxidizers? (Greg Adams)

• The characteristics of the inlet stream to the thermal oxidizer from the CO2 plant are different from those of a spray booth (or other exhaust stream typically controlled by a thermal oxidizer) for the following reasons: (1) there is very little oxygen in the exhaust stream, and (2) there is significant variation in the temperature of the exhaust stream (estimated at -75 to 250 degrees Fahrenheit). For these reasons, I don’t think technology transfer should be applied to this permit application. In any case, the applicant did not want to control the emissions from the CO2 vent, but only agreed to do so in order to avoid further delays in getting the project started. (Joseph Hower)

• Doesn’t the thermal oxidizer need to operate for six months at 50% capacity before it can be considered as BACT for a CO2 plant? (Hal Taback)

• Since SB456 does not apply, why is the District required to provide a 30-day public comment period? (Deanna Nichols)

The applicant will be preparing 250-2000 gallon batches of hair spray in a mixing tank, and the VOC emissions will be controlled by a passive carbon adsorption system. The uncontrolled VOC emissions (ethyl alcohol) will be approximately 1.9 pounds/batch.

The equipment will be used to manufacture polyurethane tubes and the emissions from the process (a mixture of VOCs and Rule 102 exempt compounds) will be vented to a non-regenerative carbon adsorption system. The uncontrolled TOG emissions from the equipment will be approximately 63 pounds/day, and the minimum overall control efficiency of the carbon adsorption system will be 95% (based on the manufacturer’s guarantee).

The same facility will operate a batch vapor degreaser that will use isopropyl alcohol as the cleaning solvent. The degreaser is designed to operate in accordance with Rule 1122 equipment and operating requirements, and in addition, the degreaser will be vented to the carbon adsorption system common to the polyurethane tube manufacturing equipment.

The applicant received a permit to operate a 193 horsepower fire pump engine at Disneyland resort. The engine is gasoline fired, and the BACT requirement is VOC, NOx, and CO emissions at 0.15, 0.15, and 0.6 grams/bhp-hr, respectively. The emissions are controlled by a three-way catalyst and air/fuel ratio controller. The manufacturer of the control equipment is Carsound Exhaust Systems, and the cost of the equipment was approximately $750.

The Santa Clarita Valley School Food Service received a permit to operate a 480 horsepower Cummins (Model NTA855-G3) diesel engine, the US Naval Air Station received permits to operate two 100 horsepower John Deere (Model 4045TF) diesel engines, and the Running Springs Water District received a permit to operate a 86 horsepower Caterpillar (Model 3054 DIT) diesel engine. The engines are used to drive emergency electrical generators. For each engine, 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. Emissions data was provided by the engine manufacturers, and each of the engines is able to achieve the BACT limits without use of add-on controls.

Ingram Book Co. received a permit to operate a 1448 horsepower Mitsubishi (Model 37ODTA) diesel engine. The engine is used to drive an emergency electrical generator. The BACT requirement is use of a turbocharger and aftercooler along with retarding the timing by at least four degrees relative to standard timing, or a NOx limit of 7.0 grams/bhp-hr. Emissions data was provided by the engine manufacturer, and the emissions are at or below the following amounts (grams/bhp-hr): VOC - 1.0, NOx – 6.9, CO – 8.5, and PM10 – 0.38. The engine achieves compliance with BACT requirements without add-on controls.

The Crestline Village Water District received a permit to construct a 93 horsepower Ford natural gas fired engine. The engine will be used to drive a non-emergency electrical generator. 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 a Miratech three-way catalyst (Model MN-09-04F-D2) and a Miratech air/fuel ratio controller (Model MEC-2001). The cost of the add-on control equipment was approximately $8,000. A source test will be conducted to verify compliance with BACT limits.

• Why wasn’t an airless degreaser required? Is the vapor degreaser equivalent to an airless system? (Katy Wolf)

• Did the fire pump engine have aftercontrol when it went in for UL certification? If not, the addition of add-on controls could void the certification. (Karl Lany)

• Edison Company has performed retrofits on numerous gasoline and LPG fueled engines, and the cost of the control equipment was around $200-300 per engine. My experience is that it is cost effective to control the emissions from spark ignited internal combustion engines. (Martin Ledwitz)

• Why does the District have a separate category for fire pump engines? Why not just group the engines with the emergency standby units. (Greg Adams)

A separate meeting to discuss boiler BACT issues was held on November 9, 1999, and during the meeting several issues were raised regarding the District’s October 5, 1999, boiler BACT guidance document. Staff is in the process of reviewing the issues and new guidance regarding boiler BACT will be prepared in the near future.

At the request of EPA, this discussion was postponed until the December SRC meeting.

The District’s time frame for the Regulation XIII revisions is sometime in early spring next year. At the request of EPA, further discussion of this topic was postponed until the December SRC meeting.

• Sempra Energy would like more "certainty" in the BACT process so that permit applicants will have a more concrete idea of what current BACT requirements are, along with some assurance that BACT requirements won’t change midstream in a project. Along this line, we recommend that BACT determinations be fixed for one year, and that manufacturers receive 12 months notice prior to a BACT/LAER change. (Deanna Nichols)

• The recent boiler BACT guidance documents have been interpreted by many permit engineers and others to be to be hard and fast guidelines. The District needs to remind everyone that BACT is still determined on a case-by-case basis. Also, further BACT implementation guidance documents should not be issued prior to review by the SRC and interested parties. (Deana Nichols)

• I think the regulated community needs technical guidance (in addition to procedural guidance) for critical groups of equipment (e.g., boilers) especially regarding new and emerging technologies. Whether this guidance is through top sheets or some other means, industry needs more technical information regarding the applicability, limitations, and costs of the new technologies. Not enough of this information is contained in the BACT determination forms. (Karl Lany)

• I think that the boiler BACT guidance documents blindsided people, and I strongly feel that future guidance documents should be reviewed by the SRC prior to issuance to permitting staff. That way the SRC and interested parties have a chance to comment on the proposed guidance before it is implemented. (Greg Adams)

• I think it would be a good idea if the BACT implementation guidance documents were made available on the internet. (Audience)

So noted. (Jack Broadbent)

• I think we need further discussion regarding the criteria for technology transfer, and we would like the District to develop a checklist that defines the parameters that should be considered. For example, more clearly define what constitutes a similar flue gas stream. (Deanna Nichols)

• What is the current BACT for boilers? (Ed Cancilla)

• Is the 12-ppm NOx limit achieved in practice? (Ed Cancilla)

• Is the BACT trigger 1 pound/day or 30 pounds/month? (Audience)

• Is the District currently issuing boiler permits? (Deanna Nichols)

• Are the LTO examples at Alta Dena Dairy and Fansteel included in the EPA’s RACT/BACT/LAER clearinghouse? The District should look into this since these BACT determinations have been rescinded. (Audience)

There was no further discussion and the meeting was closed. The next meeting is scheduled for December 16, 1999, at the same location. Note that meeting information is available on the AQMD web page.