MEETING HIGHLIGHTS

	SRC Members
Greg Adams			Steve Simons
Martin Ledwitz			Karl Lany
Russell Greenhouse			Stan Romelczyk (by phone)
Gary Rubenstein			Hal Taback
Ted Guth (not present)			Bill Dennison
Katy Wolf			Nahid Zouestaigh (not present)
Philip Hodgetts (not present)				Ron Joseph (not present)
Grant Chin (by phone)			Ron Wilkniss (not present)
John von Bargen (for Anoosheh Mostafaei)
		Attendees
Hank Wedaa			Steve Hurlock
Carol Kaufman			Damon Erickson
Daniel McGivney			Jerry Kraim
Marty Mutsch			Todd Wong (by phone)
	AQMD Staff
Marty Kay			Howard Lange
Alfonso Baez

 

 

 

 

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

¾    Minutes of January 23rd Meeting

¾    Responses to Comments from January 23rd Meeting

¾    New and Updated BACT - Part B Listings

¾    Update of Part D (Minor Source) BACT Guidelines for Emergency Diesel Engines

¾    Other Business

 

Minutes of the January 23rd Meeting

A committee member pointed out a spelling error in an attendee’s name. (Greg Adams, Los Angeles County Sanitation Districts)

 

Responses to Comments from the January 23^rd Meeting

AQMD stated that changes to the new Part B listings that had been agreed upon at the January 23^rd meeting had been made and committee or audience members could view the updated listings on AQMD’s web site. (Howard Lange, AQMD)

 

I.C. Engine, Landfill Gas Fired – MM San Bernardino Energy (A/N 391009)

It had been noted during the meeting that calculated g/hp-hr figures that had been included in the listing (item 5-B-6) for information, seemed too high.  Staff found a calculation error, and those figures had been corrected. (Howard Lange, AQMD)

 

I.C. Engine, Digester Gas Fired – Inland Empire Utilities Agency (A/N 388050)

An audience member had stated that Rule 1110.2 seemed to be more stringent than Part D BACT for IC Engines.  Staff compared the two rules over a range of engine sizes and had found that Part D BACT for IC Engines was more stringent than Rule 1110.2 in every case. (Howard Lange, AQMD)

 

Lithographic or Offset Printing, Heatset – Madison Graham (A/N 405533) and Quebecor World Publishing (A/N 401090)

With regard to these two listings, committee members had asked how the collection efficiency of the oven in a heatset lithographic printing system is determined for purposes of verifying the overall collection/destruction efficiency required in the permit.  This had been discussed with the permitting team and it was found that applicants are required to follow compliance guidance issued by AQMD in 1997, which contains detailed specifications for two alternative methods—a smoke test or an oven pressure monitor. (Howard Lange, AQMD)

 

Gas Turbine – ANP Blackstone, (MADEP A/N 118969) and Public Notice of New BACT Determination for Combined Cycle and Cogeneration Gas Turbines

A committee member had questioned whether the low utilization that this plant has experienced was really due to the power market situation and expressed concern that it might indicate that the plant was experiencing operational problems.  Staff had investigated and reconfirmed that the low utilization has been due to the power market situation in that area and had verified that there have been very few problems.

A committee member had requested that the listing note that the 15 ppm NOx level achieved by this turbine model is unusually low, and achieving the 2 ppm exit NOx level may be difficult on other turbines in this size class.  AQMD had considered this suggestion and had decided that was not an appropriate LAER issue.  The same committee member had also suggested that the listing note that the low NOx level would be difficult to achieve on smaller, e.g., aero-derivative, turbines and that the 3 ppm CO level would be difficult on turbines requiring steam or water injection for primary NOx control and on systems that include duct burners.  AQMD agreed with those suggestions and those considerations had been added to the listing.

A committee member had suggested that the listing should note that some period of time was required before the plant was able to consistently comply with the NOx limit.  AQMD had considered this suggestion and had decided that mention of a period of time required to bring the plant into compliance was inappropriate but noted that the listing does mention that the CEMS data reported to the EPA indicate more NOx exceedances in the first nine months of operation than in the second nine months. (Howard Lange, AQMD)

Discussion: Some committee members still felt that the listing should mention that a break-in period was required for the plant to develop its capability to consistently meet its emission limits.  AQMD responded that the permit issued to ANP Blackstone had no such provision and the plant had not been issued any warnings or notices of violation so there was apparently no need for a break-in period in this case.  Committee members asked whether Massachusetts may allow for a break-in period in its enforcement policy on extremely low-emission systems.  AQMD had explored this with MADEP and had found that there were specific criteria for warnings and enforcement actions, and those criteria had been applied to ANP Blackstone with no allowance for a break-in period.  It was also learned that the apparent NOx exceedances indicated by the data reported to EPA for the second nine months of operation (first three quarters of 2002) had all been related to excusable events or data reporting errors, and none of those apparent exceedances were considered by MADEP to actually constitute exceedances.  It was noted that this casts doubt on all apparent exceedances based on the EPA data.

However, some committee members continued to argue that BACT should contain some guidance toward allowing a break-in period in cases where extremely low emission limits are involved.  Two committee members felt that the 180-day time period allowed for completion of source testing in federal New Source Performance Standards is intended as a break-in period and thus establishes precedent for a break-in period to be included in permitting.  However, neither AQMD staff nor the committee members who were persent were aware of any example of a permit being issued in California with a break-in period.  AQMD stated that it has a variance procedure which should provide sufficient relief if startup problems are being encountered, and there is therefore no need for BACT to mention a break-in period even for very low emission levels. (Greg Adams, Los Angeles County Sanitation Districts; Gary Rubenstein, Sierra Research; Karl Lany, SCEC; Howard Lange, AQMD; Marty Kay, AQMD)

AQMD updated the committee on the status of the new BACT for combined-cycle or cogeneration gas turbine power plants, for which a public notice had been issued and discussed at the previous meeting.  That public notice had been triggered by an AQMD BACT determination for the Inland Empire Energy Center requiring 2 ppmvd NOx and 3 ppmvd CO (corrected to 15% O2), which was based on the ANP Blackstone permit.  Written comments that had been received as well as comments received at the previous meeting had been considered.  AQMD stated that appropriate concerns that had been raised would be considered as the new BACT is applied on a case-by-case basis.  As an example, many of the concerns that had been raised had been addressed in the draft Inland Empire Energy Center Final Determination of Compliance (FDOC) that had been issued by AQMD.  AQMD noted that the California Energy Commission (CEC) is the lead permitting agency in this case, and the case can be followed on the CEC web site. (Marty Kay, AQMD)

 

New and Updated BACT Part B, Section I Listings

Aluminum Melting Furnace (A/N 379736) and Metal Heating Furnace (A/N 379746), International Extrusion

These listings were based on permit modifications issued to establish RECLAIM concentration limits on two furnaces, both of which had undergone low-NOx burner retrofits.  The burner retrofits had occurred in March of 2001, and the furnaces had operated with no problems since then.  The furnaces had been source tested in September 2001, and Permits to Operate had been issued.  AQMD was therefore listing these cases as examples of achieved-in-practice technologies. (Howard Lange, AQMD)

Discussion:  A committee member suggested that wording be added to the listing stating that the NOx limits achieved in these cases may not be achievable on all furnaces in the same categories, depending on specific design and operating parameters.  AQMD agreed to do so (disclaimer language in Comments sections of Custom Alloy and Superior Industries aluminum furnace listings).  The same committee member stated that the source tests did not seem to conform to the type of test required to establish a RECLAIM concentration limit (Rule 2012, Chapter 5, Section B) in that the rule requires a one-hour continuous test whereas the test performed in this case was at two different load conditions, each tested for less than an hour.  Another committee member responded that operating conditions are allowed to change during the test, and since the total testing time was an hour in each case, the tests did seem to be adequate. (Steve Simons, Southern California Gas Co.; Karl Lany, SCEC; Marty Kay, AQMD; Howard Lange, AQMD)

 

Dryer or Oven, Newellrubbermaid (A/N 385874)

This oven is used to cure molded polyethylene parts in a toy manufacturing process.  This was another permit modification to establish a RECLAIM concentration limit in which a low-NOx burner had been retrofit to the oven.  The burner retrofit had occurred in April 2001, and the oven had operated well with the new burner since that time.  The oven had been source tested in April 2001, and a Permit to Operate had been issued.  This was therefore another listing based on achieved-in-practice technology.  AQMD stated that the disclaimer language that was mentioned in the context of the aluminum furnaces would be added to the Comments section of this listing.  Similar retrofits were done on five other ovens identical to this one, and Permits to Operate had been issued on those ovens with a requirement that they be source tested within 12 months.  The facility contact had reported that those source tests had been done and all five ovens were found to be operating with NOx levels below the RECLAIM concentration limit. (Howard Lange, AQMD)

Discussion: A committee member asked why the Permits to Operate had been issued for the other five ovens prior to the source tests being done.  AQMD responded that this was a new practice that is now being followed in some cases relatively uncomplicated cases for purposes of expediting the permitting process. (Russell Greenhouse, SCFECA; Marty Kay, AQMD)

 

Boiler, LACorr Packaging (A/N 366569)

This was an update of an existing listing of a boiler rated at 21 MMBtu/hr input with an SCR system for NOx control.  The permit limits in this case reflect Part D BACT for firetube boilers rated at and above 20 MMBtu/hr, i.e., 7 ppmvd NOx, 5 ppmvd NH3 and 50 ppmvd CO (all corrected to 3% O2).  The original listing was done at the time of the Permit to Construct, in August 2000.  Since that time, the system had been source tested, the Permit to Operate had been issued and the system had been source tested again. (Howard Lange, AQMD)

Discussion:  A committee member suggested that the terminology used in describing the source test be changed from “SCR In” to SCR Inlet” and from “SCR Out” to “SCR Outlet”.  A committee member suggested that the listing note that there is no CEMS on this boiler and compliance is based on periodic source testing.  A committee member suggested that the CO limit in the permit be added to the listing.  AQMD agreed with all of these suggestions. (Hal Taback, HTC; Gary Rubenstein, Sierra Research; Steve Simons, Southern California Gas Co.; Howard Lange, AQMD; Marty Kay, AQMD)

 

New BACT Part B, Section II Listings

Gas Turbine, UC San Diego (SDAPCD 974481)

This is a gas turbine cogeneration plant with two 12.9 MW gas turbines.  NOx is controlled by low-NOx combustion design, and NOx and CO are controlled by EMx (formerly SCONOx) emission reduction technology.  Emission limits are 2.5 ppmvd NOx and 5 ppmvd CO (corrected to 15% O2).  The plant has been operating since August 2001.  It has been source tested, and the Permit to Operate has been issued.  This was a BACT determination by San Diego Air Pollution Control District (SDAPCD), and the purpose of this listing was to adopt that BACT determination into AQMD’s Part B LAER/BACT Guidelines. (Howard Lange, AQMD)

Discussion: A committee member noted that the EMx system in this case needs to be taken off line and washed two or three times per year, which violated the plant’s economic premises in selecting EMx and may not be feasible in all cases.  AQMD agreed to add the latter consideration to the listing, but felt that the economics should not be considered in a LAER determination.  Committee members asked for more information about the CEMS probe location being optimized for 10.2 MW.  AQMD responded that SDAPCD had indicated that this was a stratification problem, which AQMD understood to mean that at other loads, the CEMS reading was not in agreement with the duct average.  A committee member suggested that this should be noted in the listing.  AQMD responded that the matter would be investigated further before deciding what should be added to the listing in this regard.

An audience member questioned the statement in the listing that the plant did not experience much utilization during its first year due to availability of low-cost power.  AQMD responded that it understood this to mean that the university had a power contract at a good price during the first year.  The audience member suggested that the listing should include information on plant availability.  AQMD agreed to look into these matters.

A committee member asked what chemical is used to wash the EMx sorbent.  Another committee member responded that it is a potassium carbonate solution.  A committee member suggested that the listing note that it is a characteristic of the EMx technology that the NOx level constantly increases as the sorbent gradually becomes sulfated, and washing is required when the NOx level approaches the permit limit too closely.  AQMD agreed to note this in the listing. (Gary Rubenstein, Sierra Research; Bill Dennison, Dennison & Associates; Audience Member; Greg Adams, Los Angeles County Sanitation Districts; Howard Lange, AQMD; Marty Kay, AQMD)

 

Dryer or Oven, Ball Western Can Co. (N-2253-15-2)

This listing represented three identical curing ovens in can metal coating lines, which had been relocated to this facility.  The facility is in the San Joaquin Valley Air Pollution Control District (SJVAPCD).  SJVAPCD had determined that NOx BACT for these ovens was low-NOx burner technology, and this listing was adopting that determination into AQMD’s Part B LAER/BACT Guidelines.  It was noted that the BACT determination also included a thermal oxidizer for VOC control but that the focus of this listing was on NOx.  The permit condition on NOx was 20 ppmvd, corrected to 3% O2.  The ovens had started up in June 2001, had been source tested, and a Permit to Operate was in process. (Howard Lange, AQMD)

Discussion:  A committee member noted that the flue gas O2 contents were 18.8 to 19.3% in the source tests, introducing relatively large uncertainties in the corrected NOx values.  AQMD responded that this was indeed true, but SJVAPCD apparently deemed the corrected values to be of sufficient accuracy to demonstrate compliance with the permit limit.  A committee member asked what was the VOC loading to the thermal oxidizer.  AQMD responded that it did not have this information since the focus of the listing was on the oven NOx emissions and not on the thermal oxidizer.  AQMD stated that it would consider creating another listing based on this same determination but focusing on the thermal oxidizer. (Bill Dennison, Dennison & Associates; Gary Rubenstein, Sierra Research; Marty Kay, AQMD)

 

Updated BACT Part B, Section III Listing

Boiler, Damapong Textiles (A/N 359772)

This was an update to an existing listing of a 16.5 MMBtu/hr firetube boiler with an SCR system for NOx control.  The original listing was dated in December of 1999 at the time of the Permit to Construct.  Since that time, the system had been source tested and a Permit to Operate had been issued.  Unfortunately, the facility had ceased operations and it was not possible to obtain any additional information.  The emission limits were 7 ppm NOx, 5 ppm ammonia and 50 ppm CO, all corrected to 3% O2.  AQMD noted that, based on the size of the boiler, a 12 ppm NOx limit would have met the BACT requirements, but the facility had apparently elected to meet the lower NOx limit.  AQMD also noted that this was an on/off type boiler, making it a less complicated application of SCR than would be the case for a load-following boiler. (Howard Lange, AQMD)

Discussion:  A committee member suggested that the listing be converted from present tense to past tense in that the boiler is no longer operating.  AQMD agreed to do so. (Bill Dennison, Dennison & Associates; Howard Lange, AQMD)

 

Update of Part D (Minor Source) BACT Guidelines for Emergency Diesel Engines

AQMD had presented at two earlier SCR meetings (July 25, 2002 and January 23, 2003) a plan to incorporate U.S. EPA Tier 2 emission standards for nonroad engines into Part D BACT for emergency diesel engines.  This was a progress report on that effort.  At the January 23 meeting, AQMD had presented a plan to additionally require SCR for relatively large emergency diesel engines.  A committee member had commented that the presumption of 200 hours per year operation used in the cost analyses was unrealistic in that emergency generators, which comprise the bulk of emergency engines, typically run little more than the 50 hours per year of maintenance and testing operation that is allowed.

AQMD had investigated the apparent extent of usage of emergency generators, using data on the Southern California Edison Co. web site, and had concluded that emergency generators should be considered in two classes.  For most emergency generators, the maximum probable usage was determined to be approximately 52 hours per year (a presumptive 50 hours of maintenance and testing based on the standard permit limit plus approximately 2 hours for actual power outages).  However, for generators used in interruptible electric service programs (in which the facility receives reduced rates or payments in exchange for an agreement to remove a portion of its load from the grid when requested to do so), it was found probable that the generator might be used for the full 200 hours per year that AQMD allows.  Reducing the amount of operation assumed in the cost analyses from 200 to 52 hours per year resulted in SCR being found not cost effective at any engine size.

Based on these findings, AQMD had decided not to require SCR on emergency diesel engines of any size but to not allow use of new emergency diesel generators for interruptible electric service programs.  (Marty Kay, AQMD)

Discussion: A committee member noted that the air toxics control measures (ACTMs) being drafted by CARB are going in the same direction, i.e., prohibiting use of diesel standby generators for interruptible electric service programs.  An audience member stated that municipal water treatment facilities (“POTWs”) are working with CARB to possibly exempt themselves from those prohibitions.  Whereas the draft ATCMs require increasing amounts of PM reduction based on how much maintenance/testing operation is permitted, the POTWs’ proposal would provide reduction to 0.15 g/bhp-hr PM or 85% control regardless of the permitted hours per year of maintenance/test operation if the generator is allowed to be used in an interruptible program.  The POTWs are pointing out to CARB that it is better to have relatively clean diesel generators run in interruptible programs than to have much dirtier diesel generators come on in blackouts that may otherwise result.  He also noted that Eastern Municipal Water District (EMWD) facilities have been in interruptible programs for a long time and had never been called upon to interrupt until the 2000-2001 power crisis.  He questioned AQMD’s information that many facilities in these programs in 2000-2001 ran their standby generators up to their full 200 hours per year, stating that EMWD facilities did not run their standby generators nearly that much during that time period.

AQMD responded that many facilities came to AQMD in 2000-2001 requesting an increase in the permitted 200 hours per year of standby generator operation.  Increases up to 500 hours per year were, in fact, granted to facilities that qualified as essential public services.  AQMD commented that the POTWs’ proposal to CARB, offering lower PM emissions, does not address NOx or the other pollutants; and AQMD may therefore not support that concept.

A committee member stated that calls to interrupt power should be very few in the future because more power plants are coming on line and more transmission capability is being installed.  Also, some evidence indicates that the power crisis of 2000-2001 may have been in part contrived by independent power producers.

An audience member stated that the interruptible electric service programs are needed to reduce the likelihood of power blackouts.  AQMD responded that the proposed revision of MSBACT does not prevent facilities from participating in these programs.  It just means that some of the savings that the facility realizes should be invested in cleaner technology.  AQMD noted that a staff report would be out soon.

A committee member stated that not all interruptible service agreements require up to 150 hours per year of interruptions as was assumed in the BACT analysis.  Another committee member added that the maximum hours per year is a negotiable item.

A committee member asked how the proposed change would affect facilities that cannot rely on gas for their emergency power.  AQMD responded that diesel will be allowed for blackouts.  It just will not be allowed to fulfill requirements of interruptible programs.  A committee member added that many interruptible customers fulfill their load reduction requirements by turning off some switches.

A committee member asked whether dual-fuel engines would be allowed.  AQMD responded that they should be acceptable if they can meet emission levels that are BACT for spark ignition emergency generators.

A committee member noted that many of the interruptible customers are schools and hospitals, and AQMD should be aware that the proposed change will be taking funds away from those types of institutions.

A committee member asked when the staff report would be available.  AQMD responded that it will go on line on the AQMD web site a few days before the June 6 board meeting, but AQMD would distribute it to the BACT mailing list about a month prior to the meeting.

(Bill Dennision, Dennison & Associates; Martin Ledwitz, Southern California Edison Co.; Daniel McGivney, Eastern Municipal Water District; Karl Lany, SCEC; Greg Adams, Los Angeles County Sanitation Districts; Marty Kay, AQMD)

 

Other Business

The next meeting was scheduled for May 22, 2003 at 1:00 p.m. in AQMD conference room GB.

AQMD staff had been requested by its management to change the date of the September SRC meeting from September 25 to some other date due to a conflict with another event on September 25.  It was decided to change the date of the September meeting from September 25 to September 18, 2003.

There was no further discussion, and the meeting was closed.

 

Attachments