Pom Pom Ganguli welcomed the SRC members and the audience to the eighth SRC meeting of 1999. The following topics were on the agenda for the meeting: (1) new BACT determinations for spray booths, a gas turbine, and a laminator, (2) a report on the new BACT process and format, and (3) an update on the Alta Dena Dairy Boiler BACT determination. No comments were received regarding the minutes from the July SRC meeting.

Issue: Staff should prepare a formal report to the SRC (every six months) that describes the BACT Guidelines update process. The report should include operating data for new types of controls so that the SRC can get some feedback on how well these technologies are functioning.

Response: Staff is working on this item, and the status report should be available in the near future. Regarding the purpose of the report, staff invites comments from SRC members regarding what information should be included in the report.

Knut Beruldsen presented a Section II BACT determination for a large power plant project consisting of two gas turbines and a steam turbine. The combined electrical output of the project will be 500 MW. The power plant will be located in Yuba City, California, and start-up is estimated for late 2000. A SCR system and an oxidation catalyst will control the emissions from the equipment. The NOx permit limit is 2.5 ppm based on a 1-hour rolling average, the VOC permit limit is 1 ppm based on a calendar day average, the CO permit limit is 4 ppm based on a calendar day average, and the ammonia slip limit is 10 ppm. The ppm limits are dry, by volume, and corrected to 15% O₂. The above limits exclude up to 3 hours per startup and 1 hour per shutdown (various hourly mass emission limits apply during these periods). EPA (Region IX) is going to be issuing a PSD permit for this facility. The Feather River AQMD and EPA permit limits are basically the same with the exception that the CO emission limit for the EPA permit uses an hourly basis rather than a calendar day basis..

Knut Beruldsen presented three Section I BACT determinations for automotive spraying operations to be located at Wondries Collision Center in Alhambra, California. The new facility will be adjacent to a residential area and there was significant public opposition to the proposed location of the facility. Application Number 352922 is for an open, downdraft preparation station. The permit limits facility-wide VOC emissions to 667 pounds/month, and the BACT requirement is compliance with Rule 1151 VOC limits and transfer efficiency requirements. Application Number 352925 is for an open face, crossdraft, floor-type spray booth. The permit limits equipment VOC emissions to 15 pounds/day and facility-wide VOC emissions to 667 pounds/month. The BACT requirements are compliance with the daily mass cap, and compliance with the VOC limits and transfer efficiency requirements specified in Rule 1151. Application Number 354640 is for an enclosed, downdraft, automotive spray booth. The permit limits facility-wide VOC emissions to 667 pounds/month, and the BACT requirement is 85% overall VOC control from this spray booth. The VOC emissions will be controlled by a Blowtherm (Model No. Envirocure) adsorption/catalytic oxidation system. The control system will consist of an air make-up system, two Haptite adsorption beds, and a catalytic oxidizer. The Envirocure system is relatively inexpensive, and currently work is being done to see if this technology can be used to control the VOC emissions from open face spray booths, such as those used in wood furniture and metal coating operations.

Knut Beruldsen presented a Section III BACT determination for a laminator. The laminator is included in Section III because the ozone control equipment has not yet met AQMD achieved in practice criteria (as specified in the Part A document). The laminator will be used to bind two plastic films together, and the finished product will be used as food packaging material. The laminating equipment basically consists of a laminator, two corona treaters, and a 800,000 btu/hour drying/curing oven. VOC will be emitted from the adhesives, ozone will be emitted from the corona treaters, and a small amount of NOx and CO will be emitted from the drying/curing oven. BACT is required for the VOC and ozone emissions because these emissions will exceed 1 pound/day. The BACT requirement for the VOC emissions is usage of adhesives with a VOC content that does not exceed 250 grams/liter. For the ozone emissions, the applicant will install an ozone destructor that will reduce these emissions by 90%. The ozone destructor is basically a catalyst bed where a metal oxide catalyst will facilitate the reduction of ozone to oxygen. The ozone control equipment will be tested after startup and this BACT determination will be updated with the performance data.

Discussion of issues

Calpine Gas/Steam Turbines

• What pollutants are covered in the PSD permit? (Greg Adams)

• What is the averaging period for the VOC emissions? (Audience)

• Why is the ammonia slip limit allowed to be so much higher than the NOx limit? (Audience)

• What test methods will be used to determine the VOC emissions, and are there any outstanding issues? (Robert Zweig)

• How is the overall VOC control efficiency broken down between capture and control efficiency? (Steve Barhite)

• The NOx emissions from the catalytic oxidizer will be 1.68 pounds/day based on 24 hour/day operation. It seems like you are trading off VOC emissions for NOx emissions. (Greg Danenhauer)

• Did Wondries actually purchase the control equipment? (Steve Walters)

• Are the NOx and CO emissions from the catalytic oxidizer subject to NSR? (Greg Adams)

• Are Wondries and Arbek Title V facilities? If so, what do they do for periodic monitoring regarding the 85% overall efficiency requirement? (Greg Adams)

• Regarding spray booth operations, what are the significance of the 22 pounds/day and 39 pounds/day cutoffs? (Greg Adams)

• The emissions from the automotive spray booth will be less than the BACT cutoff (i.e., 22 pounds/day). With this in mind, why did Wondries decide to install the Envirocure system? (Bill Pearce)

Pom Pom Ganguli presented a status report on the new BACT process. Staff will make these reports to the SRC every six months. The report basically covered the following items: (1) a summary of the new BACT process and the new format of the BACT Guidelines, (2) SRC accomplishments, and (3) staff accomplishments. The report recommended no changes to the BACT process. Major accomplishments during the first half of the year included the following: the completion of the BACT Guidelines Part A document, the formation of a BACT Guidelines web site, the formation of a BACT docket in the library, and the review and analysis of numerous Part B BACT listings.

In response to the Boiler Working Group’s report, staff is currently reviewing the information used to support the BACT determination at Alta Dena Dairy, and a report will be provided before the next SRC meeting. Hard data (such as fuel usage records) that provides a direct indication of boiler load during the achieved in practice period is not available. However, information that indicates that the boiler was operated for more than 180 days total (at various loads) is available and this information will be included in staff’s report. The final report will be submitted to top management (and EPA) and a decision will be made regarding whether or not the LTO system at Alta Dena satisfied achieved in practice criteria. Deanna Haines passed out a handout that describes the EPA’s Environmental Technology Verification Program. The purpose of the program is to verify the performance of innovative technologies, and their web site (www.epa.gov/etvprgrm) contains a list of verified technologies as well as technologies undergoing evaluation. Deanna Haines commented that this program could be of value to the District and the SRC because there is a need to standardize the protocols used verify the reliability and performance of new control technologies.

Discussion of issues

• How much of the BACT information generated in South Coast is ending up in the EPA’s RACT/BACT/LAER clearinghouse? (Greg Adams)

• I think the Alta Dena LTO experience demonstrates the importance of getting the SRC and interested parties involved in the BACT determination process at the earliest stages. (Karl Lany)

• How does someone get information included in the BACT docket? (Audience)

• Are the SRC meeting minutes included in the BACT docket? (Deanna Haines)

• I thought the BACT docket was supposed to be like an EPA docket, and that it would contain all documentation used to support a BACT determination, including comments from the SRC meetings. (Greg Adams)

• Maybe staff could include the SRC meeting agendas in the docket. (Karl Lany)

• San Joaquin Valley APCD took an action about three months ago where they said that the LTO technology was only achieved in practice for a very narrow application. Has District staff looked into this? (Bob Giorgis)

• Did the Alta Dena installation use sodium hydroxide? (Greg Adams)

• Is the Fansteel LTO system operating yet? (Deanna Haines)

• Given the Boiler Working Group’s recommendations, is the 5 ppm NOx limit still in effect for new applications for boilers? (Audience)

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