new source review in the scaqmd november 2, 2005 judy b. yorke yorke engineering, llc 949-248-8490...
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New Source Reviewin the SCAQMD
November 2, 2005
Judy B. YorkeYorke Engineering, LLC
949-248-8490 [email protected]
New Source Review (NSR)
In the SCAQMD, Regulation XIII specifies the NSR requirements.
Rule 1301 states: “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
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? All Nonattainment air contaminants and
their precursors, plus ammonia and Ozone Depleting Compounds (ODCs)
Typically, the key pollutants include: NOx VOCs PM CO SOx
When is BACT Applied?
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?
… Or Decrease? Rule 1306 specifies Increases and
Decreases under NSR: 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?
BACT is determined at the time of permit issuance
BACT is determined on a case-by-case basis
BACT for Major/Minor Sources
BACT determination based on whether the source is classified as “major” or “minor” Major Sources - Must meet Federal
LAER Minor Sources – Use Minor Source BACT
Guidelines
Major Source Definition 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 Major Source BACT is determined
case-by-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
The complete BACT Guidelines can be downloaded from: http://www.aqmd.gov/bact/
What is BACT? BACT means the most stringent…limit or
control technique which: (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 …”
Federal LAER
State BACT
Achieved in Practice, Reg. Documents
An emission limit or control technology may be considered AIP if it exists in any of the following regulatory documents or programs:
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
A control technology may be considered Achieved in Practice if it meets the following: 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
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
Applicant Size (MMBTU/hr)
NOx Limit (ppm)
Technology
Disneyland 8.5 12 Low NOx burner Liberty/Key Container
16.3 12 Low NOx burner
UCI Medical Center
48.6 9 Low NOx burner
Coca Cola 31.5 7 (5 ppm NH3)
Selective Catalytic Reduction (SCR)
SCAQMD Determinations for Boilers:
Minor Source BACT
For minor sources, the SCAQMD has published Minor Source BACT Guidelines [Part D - http://www.aqmd.gov/bact/]
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
Size (MMBTU/hr)
NOx Limit (ppm)
CO Limit (ppm)
<20 MMBTU/hr 12 50 (firetube type) 100 (watertube type)
>20 MMBTU/hr (no add-on controls)
9 Same as above
>20 MMBTU/hr (with controls; i.e. SCR)
7 (<5 ppm NH3)
Same as above
*Natural gas fired
SCAQMD Determinations for Boilers*:
Examples of Minor Source BACT
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.
SCAQMD Determinations for Dryers and Ovens
Typical Permit Conditions Emission limits for pollutants
released Monitoring requirements Maintenance requirements Source testing requirements Recordkeeping requirements
BACT Implications Remember, once BACT is set for
your source, you must always comply with that limit… as will all of the sources after you…