MEETING HIGHLIGHTS

	SRC Members
Greg Adams			Deanna Haines (represented by Darrell Johnson)
Martin Ledwitz (represented by George Williams)			Karl Lany (not present)
Russell Greenhouse  (not present)			Stan Romelczyk (by phone)
Gary Rubenstein (not present)			Hal Taback
Ted Guth			Bill Dennison (not present)
Katy Wolf			Nahid Zouestaigh (not present)
Philip Hodgetts (not present)				Ron Joseph (not present)
Grant Chin (by phone)			Ron Wilkniss (not present)
Anoosheh Mostafaei
		Attendees
Steve Hurlock			Vance Markland
Judy York			Imran Husain
Deanna Freund			Mark Simon
Wayne Tanaka			Rob Larson
Terry Crowley			Viji Sadasivan
Hafizur Chowdhury
	AQMD Staff
Marty Kay			Howard Lange
Al 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 July 25th Meeting

¾    Responses to Comments from July 25th Meeting

¾    New and Updated BACT - Part B Listings

¾    Other Business

 

Minutes of the July 25thMeeting

The minutes of the July 25^th meeting were approved as written.

 

Responses to Comments from the July 25th Meeting

Minutes of May 23^rd Meeting

In the July 25^th meeting, during discussion of the minutes of the May 23^rd meeting, committee members requested more information on the VOC monitor being used on the Sunoco water treatment air stripper.  Committee members felt that it may be a combustibles monitor rather than a VOC monitor.  Staff found that it is Rosemount 400 THC monitor, capable of being ranged from ppm to percentage levels.  (Howard Lange, AQMD).

Aluminum Melting Furnaces – Custom Alloy Sales (A/N 385864) and Superior Industries (A/N 308982)

AQMD stated that these new listings had been modified to reflect comments made by the committee at the last meeting and that the modified listings could be viewed on the AQMD BACT web site.  A committee member stated that his organization objected to these listings and was in the process of submitting a letter to AQMD stating this objection and explaining the reasoning behind the objection. (Howard Lange, AQMD; Darrell Johnson, SEMPRA)

Spray Booth – Lippert Components (A/N 369278)

A committee member had requested more information on the portable VOC analyzer used to make daily checks on the VOC concentration in the exhaust from this spray-coating facility.  It was learned that the analyzer is a Thermo Environmental Century TVA-1000 flame ionization detector (FID).  A specification sheet for this instrument was handed out to the committee.  It was also learned that AQMD generally approves portable analyzers that are of the FID type but frequently questions the use of portable analyzers that are of the photo ionization detector (PID) type because the latter type responds to fewer hydrocarbon species than the former type.  A committee member stated that PID analyzers are generally more responsive than FID analyzers to cyclic and chlorinated hydrocarbons. (Howard Lange, AQMD, Hal Taback, HTC)

Gas Turbine – Los Medanos (BAAQMD A/N 1272)

AQMD stated that this new listing had been modified to reflect comments made by the committee at the last meeting and that the modified listings could be viewed on the AQMD BACT web site. (Howard Lange, AQMD)

Boiler – Allstyle Dyeing & Finishing (A/N 376152)

AQMD stated that this new listing had been modified to reflect comments made by the committee at the last meeting and that the modified listings could be viewed on the AQMD BACT web site. (Howard Lange, AQMD)

 

New BACT Part B, Section I Listings

Dryer or Oven – Aramark Uniform Services (A/N 391633)

This large commercial laundry installed a new clothes dryer as part of a facility expansion.  In the permitting of the new dryer, BACT was deemed to be 30 ppm NOx (corrected to 3% O2) based on AQMD BACT Guidelines.  The facility met this requirement by having the dryer equipped with a low-NOx burner with a 30 ppm guarantee.  (Howard Lange, AQMD)

Discussion:  It was noted in the listing that the facility had been cited with regard to a Rule 1146 violation involving a water heater.  Committee members felt that this information was inappropriate, and it was agreed to delete it. (Greg Adams, Los Angeles County Sanitation Districts; Hal Taback, HTC; Marty Kay, AQMD)

A committee member and an audience member commented that the dryer may not have had sufficient operation to qualify the control technology as “achieved in practice”.  AQMD responded that “achieved in practice” was not an issue since the BACT determination in this case was based on pre-existing BACT Guidelines. (Darrell Johnson, SEMPRA; Deanna Freund, Southern California Gas Co.; Marty Kay, AQMD)

Dryer or Oven – BMCA Insulation (A/N 322398)

This facility, which closed in November 1998, manufactured insulating board used primarily in roofing.  As part of an effort to achieve super compliance in RECLAIM, the facility chose to retrofit a drying oven with low-NOx burners.  The oven was a large, complex piece of equipment.  Rated at 96 million Btu/hr input, the oven had three heating zones, each with two burners.  The low-NOx burners enabled the facility to accept a RECLAIM NOx concentration limit of 6 ppm corrected to 15% O2, which is equivalent to 18 ppm corrected to 3% O2.  A source test, which was accepted by AQMD Monitoring & Source Test Engineering, showed the oven to be in compliance with the concentration limit.  The expected startup date and the date when the facility notified AQMD that it ceased operation indicated that the oven had operated with the new burners for nearly two years. (Marty Kay, AQMD; Howard Lange, AQMD)

Discussion:  A committee member asked whether the burner manufacturer had guaranteed that the new burners would meet the 6 ppm NOx level and commented that the length of time that the oven operated with the new burners did not seem to be precisely known.  AQMD responded that (1) it would look into what the burner manufacturer had guaranteed and also what type of guarantee is required to qualify a technology as LAER/BACT and (2) the dates of burner installation and source testing, which are documented in the permit file, establish sufficient operating time.  An audience member commented that it had not been established that the oven had operated at at least 50% of its rated capacity for at least six months as required to qualify for achieved in practice.  AQMD responded that (1) achieved in practice does not required operation at 50% of capacity for six months, but only requires operation at 50% part of the time during the six month period, (2) there is an exception if it is normal for the equipment to always operate below 50% and (3) the fact that there was an approved source test proves that the oven operated at its normal operating rate at that time or the test would not have been considered valid. (Darrell Johnson, SEMPRA; Deanna Freund, Southern California Gas Co.; Judy York, York Engineering; Marty Kay, AQMD)

Spray Booth – Stewart Filmscreen (A/N 349220)

This facility manufactures projection screens and screens used in the defense industry, for projection televisions, and for other purposes.  The screens are prepared in spray rooms in which automated sprayers apply multiple coatings of resin materials to large molds suspended overhead.  Application of the coatings requires approximately a day, and the product remains in the spray room for another two days for curing.  To enable addition of a new spray room, the applicant accepted permit conditions requiring that the new spray room as well as two existing spray rooms be vented to a baghouse and then to a regenerative thermal oxidizer with a minimum chamber temperature of 1450F and a minimum overall VOC control efficiency of 98%.  The VOC control system has been operating since January 2001.  The system was source tested and found to be achieving 100% collection efficiency (permanent-total-enclosure criteria were met) and 99.2% destruction efficiency.  The source test was reviewed and accepted by AQMD’s Monitoring & Source Test Engineering group. (Howard Lange, AQMD)

Discussion:  An audience member asked why the coating materials used in this facility are not subject to any limits on their VOC contents.  AQMD and a committee member responded that this type of operation is not subject to any Regulation XI rule. (Audience Member; Marty Kay, AQMD; Katy Wolf, IRTA)

 

Updated BACT Part B, Section II Listing

Gas Turbine – Silicon Valley Power (BAAQMD A/N 18547)

Catalytica owns and operates this 1.5 MW Kawasaki gas turbine generator, located at a power plant owned by Silicon Valley Power (SVP).  Catalytica sells the power to SVP.  The purpose of this small power plant is to test and demonstrate the Kawasaki low-NOx gas turbine, which is based on Catalytica’s “flameless” combustion system.  This is a catalytic gas turbine combustor that enables combustion to occur at relatively low temperature thus almost eliminating NOx formation.  This was an existing Section II listing, and AQMD had obtained new information and planned to update the listing.  The plant owner had changed from Genxon, which had been a joint venture between Catalytica and SVP, to Catalytica.  There was updated contact information for both Catalytica and the permitting agency.  Most importantly, the emissions performance of the technology had been certified by both the USEPA and CARB.  The certification test results from both agencies had been added to the listing, including some deficiencies that AQMD’s Monitoring & Source Test Engineering group found in the USEPA test methodology.  Summaries of the USEPA and CARB certifications were included in the meeting materials, and AQMD noted that the listing update included web site addresses where the full certification reports can be found.  AQMD had also discussed the product offering with Kawasaki, and information regarding the commercial emissions guarantee had been added to the listing. (Howard Lange, AQMD)

Discussion:  A committee member asked, in regard to AQMD’s concerns about the USEPA test methodology, whether the combustor temperature had been monitored and whether this information could be used as a check on the validity of the NOx results.  AQMD responded that the Monitoring & Source Test Engineering group’s evaluation of the data was limited to the test methodology. (Hal Taback, HTC; Marty Kay, AQMD)

A committee member asked whether the configuration of the catalytic combustor was compatible with retrofitting it to common gas turbine geometries.  AQMD and a committee member responded that the technology was not available separately as a retrofit but was only available in the Kawasaki gas turbine product. (Greg Adams, Los Angeles County Sanitation Districts; Marty Kay, AQMD; Hal Taback, HTC)

 

Updated BACT Part B, Section III Listing

Boiler – Y2K Textiles (A/N 362616)

This is an existing Section III listing for which AQMD had obtained additional information to be added to the listing.  This listing concerns a boiler that is equipped with a low-NOx burner, flue gas recirculation and a selective catalytic reduction (SCR) system for NOx control.  At the time of the original listing, only a Permit to Construct had been issued.  Since that time, two source tests have occurred and the Permit to Operate has been issued.  The first source test, in December 2000, was the compliance test required for the Permit to Operate.  The second, in April 2001, was an AQMD test.  AQMD noted that, in the April test, the ammonia concentration in the flue gas exceeded the permit limit.  AQMD also noted that the boiler is subject to annual ammonia tests as well as annual Rule 1146 compliance tests, and the AQMD BACT team will review those test results for 2002. (Marty Kay, AQMD)

Discussion:  An audience member pointed out that the source tests did not included test conditions at low-fire, which is normally required, and asked why the permit had been approved.  AQMD responded that it was the permit team’s judgement that the permit should be issued.  AQMD also noted that the facility manager has informed AQMD that the boiler is being operated in an on/off mode and therefore does not operate at low or medium fire.  The audience member stated that he is familiar with this boiler and this type of boiler cannot operate on/off.  AQMD responded that it would look into the matter. (Imran Husain, Global Equipment Sales; Marty Kay, AQMD)

 

Other Business

AQMD updated the Committee regarding changes that had been made in the proposed update of the Part D BACT Guidelines for emergency diesel engines.  In addition to rearrangement of some of the tabular information, the most significant change occurred in footnote 2.  This footnote had been changed from requiring compliance with USEPA Tier 2 emission limits to requiring that engines either meet these limits or be certified by USEPA or CARB to meet the limits.  This change was pursuant to comments made by the Committee at the last meeting. (Howard Lange, AQMD)

An audience member made a statement regarding the new Section III listing of the boiler at Allstyle Dyeing, which had been presented at the last meeting.  This individual objected to AQMD’s statement at the last meeting that there was insufficient technical evidence to merit a Section I listing in this case, and pointed out that there had been several source tests submitted to AQMD.  AQMD responded that some of those source tests were still being reviewed by the Monitoring & Source Test Engineering group and would be considered if and when they are approved by that group. (Terry Crowley, Sellers Engineering; Marty Kay, AQMD)

The next meeting was scheduled for November 21, 2002 at 1:00 p.m. in AQMD conference room GB.

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

 

 

Attachments