MEETING HIGHLIGHTS

Pom Pom Ganguli welcomed the SRC members and the audience to the fourth SRC meeting of 2000. The topics listed below were discussed during the meeting.

1. Minutes from the March SRC meeting
2. Sempra Energy E-Mail
3. New BACT listings
4. Minor Source BACT Guidelines
5. Achieved in Practice Criteria Update

• Regarding the March meeting, I thought I requested that the BACT determination for the Disneyland boiler be placed on the April agenda for further discussion. I think there are still some outstanding issues remaining regarding this BACT determination that need to be discussed (e.g., the boiler has not been source tested yet). (Greg Adams)

Item: Regarding the silk screen press using UV cured inks (A/N 358383), why isn’t this equipment Rule 219 exempt?

Response: The equipment didn’t meet the exemption because they are using cleanup solvent with a VOC content greater than 50 grams/liter.

Item: For SCR systems, has the District seen any actual demonstrations of less than 5 ppm ammonia slip?

Response: This item will be discussed in detail later in the meeting.

Item: Will there be a public meeting to discuss the proposed CAPCOA achieved in practice criteria document?

Response: The document is still under preparation and it is not yet ready for public distribution. Committee members have reviewed the document, and they are currently providing comments prior to sending it to the CAPCOA Board. Regarding achieved in practice criteria, the District’s Part C document is very similar to what is contained in draft CAPCOA document. As for a public meeting, staff contacted ARB (Bob Giorgis) and they will relay this request to CAPCOA. Note that the District has very little influence on the CAPCOA committee. Therefore, staff will wait to see what they develop, then we will reconvene the achieved in practice subcommittee and see what (if any) changes should be made to the District’s criteria. I don’t believe that CAPCOA guidance is binding on the District. (Pom Pom Ganguli)

Given the importance of the CAPCOA guidance document to industry, and since industry is not part of CAPCOA, I’ll try to have WSPA introduce a comment at the next CAPCOA/Industry meeting that this issue deserves very careful consideration. (Ron Wilkniss)

The SRC committee will formally request that ARB bring up the following two issues with CAPCOA: (1) hold a public meeting to discuss the issues, and (2) the SRC would like to review the achieved in practice document before it is finalized. (Pom Pom Ganguli)

Deanna Haines (with Sempra Energy) submitted an e-mail to the District on April 21, 2000, requesting that the District respond to the following issues:

1. regarding the boiler at Corcoran Prison with a 12 ppm NOx permit limit, what data and criteria are the District using to support their "achieved in practice" determination for this operation?
2. regarding the proposed minor source BACT requirements for boilers and gas turbines, what areas in the District are PM10 nonattainment, what technology transfer criteria did the District use to apply 5 ppm ammonia slip to boilers, and has the District seen any actual demonstrations at 5 ppm ammonia slip for boilers or gas turbines?
3. what is the legal authority to restrict public access to data used to establish regulatory requirements, and can the District use other sources of information besides vendor data?
4. regarding the draft minor source BACT requirements for large boilers, why is LTO technology an option since this technology is not achieved in practice?

District legal staff reviewed the e-mail, and although there doesn’t appear to be a violation of Brown Act requirements regarding serial communications, staff does have some concerns regarding possible attempts to gain a consensus on important issues. Therefore, in the future, it is recommended that SRC members go directly to staff with these types of questions rather than sending an e-mail to staff and all the SRC members.

Regarding issue no. 3, staff will attempt to honor these requests to the extent allowed by the Public Records Act. When a public records request is submitted to the District, persons who identify the requested information as confidential are required to demonstrate why the information is confidential and cannot be released to the public. Both parties can take legal action when information is improperly released. Staff plans to contact the vendors again to see what (if any) additional information can be released to the public and will report back to the committee with the results at the next meeting. As to whether the District use other sources of information (besides vendors) in their cost effectiveness analyses, the answer is yes. The District obtained cost information from both vendors and operators of the equipment. Note that a cost effectiveness analysis was not done for the LTO system at Fansteel because this technology is very expensive and has not been deemed reliable (i.e., achieved in practice) by District staff. (Bill Wong/Pom Pom Ganguli)

Regarding issue no. 1, Sempra Energy contends that since the boiler’s firing rate was not documented during the source tests that this isn’t a very good data point because this parameter is always measured during District source tests on boilers. The District agrees that the contractor could have performed more rigorous source tests; however, the subject boiler has been source tested two times and on both occasions it complied with the 12 ppm NOx permit limit. The District (and other experts) have reviewed the source test reports and they feel that there is no reason to believe that the boiler is not complying with the 12 ppm NOx permit limit. District staff contacted San Joaquin Valley permitting staff in order to obtain reliability and compliance information, and staff was informed that the boiler has not received any violation notices and has never required a variance. To the best of their knowledge, there are not any reliability or compliance issues associated with meeting the 12 ppm permit limit. At this time, numerous boiler vendors can achieve 12 ppm on small boilers (and 9 ppm for large boilers), and staff will present several examples at the next SRC meeting. (Pom Pom Ganguli)

Regarding issue no. 2, all areas in the SCAQMD are PM10 nonattainment. As for the technology transfer criteria for large boilers (or possibly small boilers), the basis of the ammonia slip limit is the ARB’s requirement for large gas turbines. The current requirement for large gas turbines is basically 5 ppm ammonia slip at stack conditions (i.e., around 15% stack oxygen). Boilers typically operate with 3% stack oxygen so the requirement for boilers is 5 ppm corrected to 3% oxygen (or stack conditions). Based on the above, it is clear that the requirement for boilers is not more stringent than the requirement for gas turbines. The actual allowable ammonia slip in the stack exhaust for both cases is basically the same. It is easier (and less expensive) to achieve the ammonia limit for boilers because gas turbines produce roughly three times the exhaust volume per given heat input than boilers do. Therefore, assuming a constant space velocity requirement, gas turbines require approximately three times the catalyst volume in comparison to a boiler. Another reason it is easier to achieve the ammonia slip limit for boilers is that the NOx limit for this equipment is higher than the NOx limit for gas turbines (7 ppm in comparison to 2.5 ppm). Less NOx reduction means less chance for ammonia slip because less ammonia is needed to achieve 7 ppm NOx. (Marty Kay)

This issue may not be a problem (for minor sources) because most boiler operators are choosing to install ultra-low-NOx burners instead of SCR equipment. Regarding the ammonia slip issue, EPA recently informed the District that they must give serious consideration to low or zero ammonia technologies when making BACT/LAER determinations for gas turbines. As for actual demonstrations at 5 ppm ammonia slip (particularly at end-of-life), the SCR system at TOSCO was source tested in 1995 and the ammonia slip and NOx emissions were measured at 2.7 ppm (each). This equipment is being source tested again and staff should have the results available in the near future. The same catalyst has been in service for greater than 5 years so this should be a good example of "end of life" ammonia slip. However, this system was designed to meet a 20 ppm NH3 limit, not a 5 ppm NH3 limit. (Pom Pom Ganguli)

Regarding issue no. 4, the District does not consider LTO an achieved in practice technology. However, if a facility chooses to install a LTO system, the BACT limit for NOx would be the same as for a SCR system (i.e., 7 ppm). To avoid further misunderstanding regarding the District’s position on LTO, the minor source BACT guidelines for large boilers will be revised to read "with add-on controls" instead of "with SCR or LTO."

• Regarding Brown Act requirements, it appears that the SRC is being held to a higher standard than other committees, including the Governing Board. Board members routinely call around to get an opinion when critical issues come up. I think it’s a stretch to say that communications such as the subject e-mail could be a violation of the Brown Act, and I’ll check with my legal staff to get an opinion on this. I’d like to see more flexibility regarding Brown Act constraints. (Greg Adams)

• Can 5 ppm ammonia slip be achieved for a reasonable period of time? That is, what is the expected life of a catalyst designed to minimize ammonia slip to 5 ppm? (Ron Wilkniss)

Staff did not receive any written comments regarding the Section I and Section III BACT listings (Application Numbers 364408, 358382, and 358383) that were submitted to the committee at the March meeting. Therefore, staff will proceed to post those listings on the BACT web page.

New Section I BACT listings for a firetube boiler (A/N 362566) and an internal combustion engine (A/N 360419) were submitted to the committee. The boiler rating is 20.9 MMbtu/hour, and the BACT requirements are NOx at < 9 ppm and CO at < 100 ppm. The boiler was relocated then retrofitted with an Alzeta ultra-low-NOx burner. The spark ignited, internal combustion engine is used to drive a standby generator. The engine is equipped with a three way catalyst and an air/fuel ratio controller. The BACT requirement for this source category was revised to the following emission levels (grams/bhp-hr): NOx < 1.5, VOC < 1.5, and CO < 2.0.

A revised Section I listing for a CO2 plant (A/N 358093) was submitted to the committee. The BACT determination was revised as a result of the public comment process. After reviewing the comments and meeting with the applicant, the permit limit for VOC emissions was revised to 0.72 pounds/hour and 10 pounds/day, from 1 pound/day. These emission limits can be achieved without additional add-on controls.

A Section II listing for a boiler (A/N S-3412-12-0) was submitted to the committee. The permit was issued by the San Joaquin Valley Unified APCD. The boiler rating is 6.2 MMbtu/hour, and the BACT requirements are NOx at < 12 ppm and CO at < 100 ppm. The boiler will be equipped with an Alzeta ultra-low-NOx burner.

Written comments regarding these listings are due within two weeks, and staff will respond to any comments at next month’s meeting. Please try not to submit written comments right before the next meeting date because staff needs time to prepare a response to the comments.

The District is actively involved in the source testing of several boilers that have been permitted at 9 or 12 ppm, and staff will provide source test information to the SRC as soon as it becomes available.

• Is the boiler used as the basis of the BACT determination for A/N 362566 listed on the web site? (Greg Adams)

• Why does the firetube boiler have a 100 ppm CO limit when 50 ppm is achieved in practice for these types of boilers? (Audience)

• Could you explain the BACT/LAER determination for the boiler listed in Section II (i.e., box 5A2 on the BACT form)? (Greg Adams)

• When the source test information for the boilers becomes available, will the District publish the executive summary? This information would be helpful to industry. (Steve Hernandez)

• What is the source of the CO2 for the CO2 plant? Is it a hydrogen plant? This type of information should be included in the listing. (Hal Taback)

The proposed minor source BACT requirements are intended to comply with state law as well as all NSR rules. Staff will provide two documents to the Board for approval: a Part C document (Policy and Procedures), and a Part D document (BACT Guidelines for Minor Polluting Facilities). Please review the draft Part C document and provide staff with comments before the next meeting. The first twelve pages of the Part C document are similar to the Part A document (for major sources). Pages 14 and 15 of the Part C document provide the achieved in practice criteria for minor sources, and the criteria are largely based on the efforts of the achieved in practice criteria subcommittee and the CAPCOA Engineering Managers subcommittee. The criteria will closely parallel the current efforts of the CAPCOA subcommittee. There are some policy items included in the Part C document, such as relocations, that are still subject to negotiations with EPA and ARB. The Governing Board hearing will most likely be in August. A full CEQA document will be prepared for the NSR amendments.

Achieved in practice criteria for minor sources are included in the draft Part C document. Staff will also probably revise the Part A document based on the results of the efforts of the CAPCOA Engineering Managers subcommittee and the District’s subcommittee. Both of the documents should be available at the same time.

• What are the issues that EPA does not agree with? (Rita Loof)

• Do any other air districts have minor source BACT Guidelines? (Greg Adams)

There was no further discussion and the meeting was closed. The next meeting is scheduled for May 25, 2000, in Conference Room GB. Note that meeting information is available on the AQMD web page.