Transcript Air Quality Training for Gas Company Account Executives

New Source Review
in the SCAQMD
November 2, 2005
Judy B. Yorke
Yorke Engineering, LLC
949-248-8490 x25
[email protected]
New Source Review (NSR)
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In the SCAQMD, Regulation XIII
specifies the NSR requirements.
Rule 1301 states:
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“The specific air quality goal of this
regulation is to achieve no net increases
from new or modified permitted sources
of nonattainment air contaminants or
their precursors.”
Applicability of Reg. XIII
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NSR generally applies to New, Modified,
or Relocated Sources
“Modification means any physical
change in equipment, change in method
of operation, or an addition to an
existing facility, which may cause the
issuance of air contaminants.”
“Routine maintenance and/or repair
shall not be considered a physical
change.”
Which Pollutants?
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All Nonattainment air contaminants and their
precursors, plus ammonia and Ozone
Depleting Compounds (ODCs)
Typically, the key pollutants include:
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NOx
VOCs
PM
CO
SOx
When is BACT Applied?
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Best Available Control Technology is
required for any relocation, new, or
modified source which results in an
emission increase [Rule 1303(a)(1)]
Except for a qualifying Relocated Minor
Facility, where there is no net increase in
emissions within two years [Rule
1306(d)(3)]
What Defines an Increase?
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… Or Decrease?
Rule 1306 specifies Increases and
Decreases under NSR:
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Increase = Potential to Emit
Decrease = Actual Emissions (last 2 years)
at current BACT (& discounted if <180
days of use)
When and How is BACT Decided?
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BACT is determined at the time of
permit issuance
BACT is determined on a case-by-case
basis
BACT for Major/Minor Sources
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BACT determination based on whether
the source is classified as “major” or
“minor”
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Major Sources - Must meet Federal LAER
Minor Sources – Use Minor Source BACT
Guidelines
Major Source Definition
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In the South Coast AQMD, a major source has
the Potential to Emit (PTE) greater than these
thresholds:
VOC
10 Tons/Year
NOx
10 Tons/Year
SOx
100 Tons/Year
CO
50 Tons/Year
PM10
70 Tons/Year
Major Source BACT
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Major Source BACT is determined caseby-case
BACT analysis looks at the “best”
emission limits for similar equipment
anywhere in the U.S.
BACT definitions can be constantly
changing and tend to become more
restrictive over time
Major Source BACT Guidelines
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The complete BACT Guidelines can be
downloaded from:
http://www.aqmd.gov/bact/
What is BACT?
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BACT means the most stringent…limit or control
technique which:
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Federal
LAER
State
BACT
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(1) has been achieved in practice for such category
or class of source; or
(2) is contained in any state implementation plan
(SIP)…; or
(3) is any other emission limitation or control
technique, found … to be technologically feasible
for such class or category of sources or for a
specific source, and cost-effective …”
Achieved in Practice, Reg. Documents
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An emission limit or control technology may be
considered AIP if it exists in any of the following
regulatory documents or programs:
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AQMD BACT Guidelines
CAPCOA BACT Clearinghouse
USEPA RACT/BACT/LAER Clearinghouse
Other districts’ and states’ BACT Guidelines
BACT/LAER requirements in New Source
Review permits issued by AQMD or other
agencies
Achieved In Practice, New Technologies
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A control technology may be considered
Achieved in Practice if it meets the following:
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Commercial Availability: At least one vendor
must offer this equipment for regular or full-scale
operation in the United States with a performance
warranty;
Reliability: All control technologies must have
been installed and operated reliably for at least six
months… at a minimum of 50% design
capacity…;
Effectiveness: The control technology must be
verified to perform effectively over the range of
operation expected for that type of equipment…”
Achieved in Practice, Tech. Transfer
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Technology that is determined to be AIP for
one category of source be considered for
transfer to other source categories.
There are two types of potentially
transferable control technologies: 1) exhaust
stream controls for similar exhaust streams,
and 2) process controls and modifications for
similar processes.
Examples of Major Sources BACT
SCAQMD Determinations for Boilers:
Applicant
Disneyland
Liberty/Key
Container
UCI Medical
Center
Coca Cola
Size
(MMBTU/hr)
8.5
16.3
NOx Limit
(ppm)
12
12
Technology
Low NOx burner
Low NOx burner
48.6
9
Low NOx burner
31.5
7
(5 ppm NH3)
Selective Catalytic
Reduction (SCR)
Minor Source BACT
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For minor sources, the SCAQMD has
published Minor Source BACT Guidelines
[Part D - http://www.aqmd.gov/bact/]
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Minor Source BACT may be less stringent
than for major sources
However, not all source types are listed… Be
very careful of using the appropriate
category!
Examples of Minor Source BACT
SCAQMD Determinations for Boilers*:
Size
(MMBTU/hr)
<20 MMBTU/hr
NOx Limit
(ppm)
12
>20 MMBTU/hr
(no add-on controls)
>20 MMBTU/hr
(with controls; i.e. SCR)
9
*Natural gas fired
7
(<5 ppm NH3)
CO Limit
(ppm)
50 (firetube type)
100 (watertube type)
Same as above
Same as above
Examples of Minor Source BACT
SCAQMD Determinations for Dryers and Ovens
Subcategory
NOx
SOx
PM10
Carpet Oven
80 ppmvd, @3% O2
Natural Gas
Natural Gas
Rotary, Spray and Flash
Dryers1)
Natural Gas with Low
NOx Burner
Natural Gas
Natural Gas
w/ Baghouse
Tray, Agitated Pan, and
Rotary Vacuum Dryers
Natural Gas with Low
NOx Burner
Natural Gas
Natural Gas
Tenter Frame Fabric Dryer
60 ppmvd @ 3% 02
Natural Gas
Natural Gas
Other Dryers and Ovens –
Direct and Indirect Fired
30 ppmvd @ 3% 02
Natural Gas
Natural Gas
1. Dryers for foodstuff, pharmaceuticals, aggregate & chemicals.
Typical Permit Conditions
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Emission limits for pollutants released
Monitoring requirements
Maintenance requirements
Source testing requirements
Recordkeeping requirements
BACT Implications
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Remember, once BACT is set for your
source, you must always comply with
that limit… as will all of the sources
after you…