South Coast Air Quality Management District

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.

• Minutes from the May SRC meeting
• New BACT, Part B listings
• Other Business

Greg Adams commented that it would be beneficial to SRC members to have advance copies of all the handouts prior to the meetings. Currently, additional documents are usually provided at the meetings (and there is no time to review them). Pom Pom Ganguli responded that staff would try to satisfy this request.

No comments were received regarding the May minutes.

Are the VOC limits specified as propane or methane? (Gary Rubenstein)

Methane. (Knut Beruldsen)

Is the District familiar with the protocol for continuously monitoring the ammonia slip? (Deanna Haines)

No. Staff will look into this and report back at the next meeting. (Pom Pom Ganguli)

The District received written comments from Hal Taback (consultant) and CENCO, and staff will respond to the comments at the next SRC meeting.

Five new Section I listings for emergency internal combustion engines were submitted to the SRC for review. The application numbers are as follows: 366730, 364327, 363918, 363589, and 365785. Each engine is diesel fired and rated at > 750 bhp, and the BACT emission limits (in grams/bhp-hr) are as follows: NOx = 6.9, CO = 8.5, ROG = 1.0, and PM10 = 0.38. Compliance with the emission limits was demonstrated by reviewing engine manufacturer’s data and CARB emissions data. Test method ISO 8178-4 (D2 test cycle) was used to measure the emissions from the engines. (Knut Beruldsen)

A new Section II listing for a gas turbine using a catalytic combustor (Application Number 1219) was submitted to the SRC for review. The gas turbine is located in Santa Clara, CA, rated at 1.55 MWe, and equipped with a XONONÔ catalytic combustor. At this point, the XONONÔ combustor is still classified as an emerging technology due to limited commercial availability and pending data review. The operator recently submitted CEMS certification tests and 4,000 hours of CEMS data to the District, and this information is currently being reviewed by District source testing staff. This permit is relevant to the District because the 5 ppm NOx limit is lower than what the District requires for gas turbines rated at < 3 MWe. If this technology is deemed achieved in practice and becomes commercially available, then the District will have to consider a lower BACT limit for the smallest gas turbines. (Knut Beruldsen)

Why is the District considering this option? (Greg Adams)

Operators have informed the District that most emergency engines are used for < 50 hours/year for maintenance testing purposes. The District is concerned about peak shaving and in the absence of limits the engines could be used for up to 200 hours/year for peak shaving purposes. The District wants to minimize the emissions from these engines because they emit significantly higher NOx and PM10 emissions than comparably sized (controlled) natural gas fired engines. (Pom Pom Ganguli)

Does the District have documentation that these engines are being used for peak shaving? (Greg Adams)

Yes. Some applicants have indicated that they want to use the engines for peak shaving purposes. (Pom Pom Ganguli)

The BACT form indicates that emergency ICEs are exempt from all parts of Rule 1110.2. I thought some parts of the rule apply to emergency ICEs. (Deanna Haines)

Staff will look into this and report back at the next meeting. (Pom Pom Ganguli)

Can the XONONÔ technology achieve =< 5 ppm NOx for combined cycle applications? (Bill Dennison)

Yes. The performance of the combustor is not affected by application of heat recovery equipment. (Chuck Solt)

Is it an annular combustor or a can combustor? (Greg Adams)

A can combustor. (Chuck Solt)

The BACT form should indicate when the initial permit was issued? (Bill Dennison)

Staff will update the form to include this information. (Pom Pom Ganguli)

The BACT form indicates $36,299/year direct annual operating costs. What does this include? (Deanna Haines)

That is the cost for catalyst replacement based on a one year catalyst lifetime (the guaranty is for 8,000 hours operation). (Chuck Solt)

What averaging time was used for the initial compliance test? (Deanna Haines)

I believe the Bay Area AQMD required a 3-hour averaging time to determine permit compliance. (Chuck Solt)

Staff will check with the Bay Area AQMD and report back at the next meeting. (Pom Pom Ganguli)

What are the four firing rates listed in section 5D7 of the form? (Greg Adams)

Staff will provide the four different firing rates (% load) at the next meeting. (Pom Pom Ganguli)

If the District determines that the XONONÔ technology is achieved in practice, then will the lower emission levels be applied to new permit applications for this category of equipment? (Richard Davis)

Assuming the technology is deemed achieved in practice, LAER policy requires that the new BACT levels be applied to permit applications up to the time the permit is issued. For minor sources, the District looks at the date the application is deemed complete. (Pom Pom Ganguli)

The gas turbine has been operating for greater than 12 months and the XONONÔ technology appears to be cost effective. Therefore, if the performance data is deemed acceptable, will staff recommend a lower BACT limit for the small gas turbine category (i.e., < 3 MWe)? (Richard Davis)

Staff is currently evaluating the data, and if everything is deemed acceptable, then the next step is to initiate the SB456 process and update the Minor Source BACT Guidelines. As to whether staff can complete the data analysis prior to initializing the Guidelines, we will look into this. (Pom Pom Ganguli)

Handouts were provided to SRC members and the audience. Staff plans to take these documents to the Board in September. The CEQA document should be available in the near future. Written comments (from Greg Adams and the Gas Company) have been received and the June 7, 2000, Part D document includes changes based on the submitted comments. The comment period is still open. (Pom Pom Ganguli)

A document containing proposed AIP BACT criteria was provided to SRC members and the audience. The AIP subcommittee met recently and they agreed that for LAER purposes, AIP BACT will be based on two different sets of requirements. The first type of requirement includes emissions/BACT information found in a regulatory document. Applicable regulatory documents include BACT Guidelines, CAPCOA BACT Guidelines, the U.S. EPA’s RACT/BACT/LAER clearinghouse, and permits issued by South Coast or any other air district. Permitting staff will check with the permitting authority to confirm that the control technology or emission limit is recognized as BACT. BACT determinations based on information included in regulatory documents are not subject to the following AIP criteria. Emerging technologies not included in a regulatory document must be commercially available, reliable, and effective in order to be considered AIP. Staff modified the reliability criteria to allow for cases where the equipment does not operate continuously for six months, or where the equipment normally operates at less than 50% design capacity. Staff believes the revised AIP criteria is acceptable to both ARB and EPA as well as the AIP subcommittee.

Regarding the CAPCOA AIP document, staff will prepare a strikeout/underlined version of their document for discussion at next week’s CAPCOA Engineering Managers Committee meeting. The document will basically reflect the AIP language contained in the District’s document.

How come the cost effectiveness analysis for the small boiler at Y2K (that is equipped with SCR) uses 20 ppm as the next level of BACT and not 12 ppm? (Deanna Haines)

The applicant volunteered to accept an 11 ppm permit limit. Since the District does not require 11 ppm for the small boilers, the analysis looked at 20 ppm to 12 ppm instead of 12 ppm to 11 ppm. 20 ppm is the BACT limit established for boilers in this size range back in April 1998. Details regarding the District’s cost effectiveness methodology for minor sources are included on page 17 of the Part C document. (Knut Beruldsen/Pom Pom Ganguli)

Does cost effectiveness play a role when determining AIP BACT? (Rita Loof)

For major sources, cost is not an issue. For minor sources, however, cost effectiveness is analyzed when determining BACT requirements. (Pom Pom Ganguli)

Is the AIP criteria for emerging technologies the same for major and minor sources? (Richard Davis)

No. For minor sources, the reliability requirement is more stringent. For example, twelve months of reliable operation is needed instead of six months. (Pom Pom Ganguli)

For the reliability criteria, is the 50% design capacity requirement based on an average minimum or an absolute minimum? (Richard Davis)

This criterion is primarily for base loaded, high capacity operations. Operations with frequent load swings below 50% design capacity do not need to satisfy this requirement. This equipment just needs to be operated in a manner that is typical of the equipment. (Pom Pom Ganguli)

Will the initial Minor Source BACT Guidelines reflect cost effectiveness? (Rita Loof)

Cost effectiveness will not be a factor for the initial Minor Source BACT Guidelines. However, for future changes, cost effectiveness will be evaluated. (Pom Pom Ganguli)

Page 15 of the Part C document states that a control technology found in any regulatory document will be considered as AIP if it meets all of the AIP criteria. Do you mean will or may be considered? (Deanna Haines)

Good point. This wording should be consistent with the Part A document. Staff will look into this. (Pom Pom Ganguli)

I think the may in the Part A document should be switched to will. Permitting engineers should consider emission limits contained in regulatory documents as AIP. If subsequent contact with the permitting authority reveals that the emission limit is not considered achieved in practice, then they do not have to consider this source. (Steve Barhite)

After much discussion, the committee decided that no changes are needed.

There was no further discussion and the meeting was closed. The next meeting is scheduled for July 27, 2000, in Conference Room GB. Note that meeting information is available on the AQMD web page.

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This page updated: August 10, 2000
URL: http://www.aqmd.gov/minutes6-22-00.htm