New Source Review in the SCAQMD

1. New Source Reviewin the SCAQMD November 2, 2005 Judy B. Yorke Yorke Engineering, LLC 949-248-8490 x25 JYorke@YorkeEngr.com

2. 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.”

3. 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.”

4. 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

5. 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)]

6. 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)

7. When and How is BACT Decided? • BACT is determined at the time of permit issuance • BACT is determined on a case-by-case basis

8. 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

9. Major Source Definition • In the South Coast AQMD, a major source has the Potential to Emit (PTE) greater than these thresholds:

10. 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

11. Major Source BACT Guidelines • The complete BACT Guidelines can be downloaded from: http://www.aqmd.gov/bact/

12. 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 …” What is BACT? Federal LAER State BACT

13. 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

14. 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…”

15. 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.

16. Examples of Major Sources BACT SCAQMD Determinations for Boilers:

17. 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!

18. Examples of Minor Source BACT SCAQMD Determinations for Boilers*: *Natural gas fired

19. 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 Examples of Minor Source BACT SCAQMD Determinations for Dryers and Ovens 1. Dryers for foodstuff, pharmaceuticals, aggregate & chemicals.

20. Typical Permit Conditions • Emission limits for pollutants released • Monitoring requirements • Maintenance requirements • Source testing requirements • Recordkeeping requirements

21. 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…