# BAYAREAAIR QUALITY MANAGEMENT DISTRICT

BACT/TBACTWORKBOOK GUIDELINES FOR BESTAVAILABLE CONTROL TECHNOLOGY INCLUDING



# . BESTAV AIIABLE CONTROLTECHNOLOGYFORTOXICS (rBACT)Cost-effectiveness = ---------------- 

# - criteria, the permit applicant can petition the 

### Air Pollution Control Officer for consideration ofothermitigationmeasures. In conclusion, while TBACT is driven by risk reduction and there are no specific cost effectiveness triggers, the economic impact of achieving the toxic emission reductions necessary to reduce the risks must be taken into consideration, as discussed 

### in Section 12. The fact that TBACT generally "embraces" 

### BACT, whenever feasible and risk reduction criteria are satisfied, demonstrates these implicit cost considerations. Similarly, the criteria of commercial availability, reliability, and demonstrated full scale operation and performance apply to TBACT as well as 

### BACT. Finally, in seeking references for additional 

### TBACTcandidates, in addition to the data sources cited 

### in Section 3.1, EPA's 

### MACT Database and CARB's Air Toxic Control Measures (ATCMS) guidance documents can be searched. Specific 

### TBACT determinations that have been made by the Bay Area Air Quality ManagementDistrict for commonly permitted source categories and equipment are identified in Section 5. 3.3 Cost-Effectiveness Detennination for BACT For the purpose of calculating emission control cost-effectiveness for 

### BACT, the Bay Area 

### Air Quality Management District has adopted the "levelized cash flow method", otherwise commonly referred to as the annualized cost method. The annualized method is simple to use and appropriate for the kinds of abatement projects proposed in the great majority ofthe District's permit applications. It has been approved for use by the California Air Resources Board's Office of Air Quality Planning and Liaison and the U. S. Environmental Protection Agency's Office of

### AirPlanning and Standards. The cost-effectiveness ofan abatement system or strategy is defined as the ratio of the annualized cost ofthat abatement system over the reduction in annual pollutant emissions achieved by the system for the pollutant in question. Cost-effectiveness canbe estimated as follows:

Annualized CostofAbatementSystem ($Iyr) Reduction in Annual PollutantEmissions (tonlyr)

The reduction 

### in annual pollutant emissions is the expected decrease 

### in the source's pollutant emissions from its baseline uncontrolled level, achieved by the installation ofthe abatement system under review. This annual reduction can be calculated as the difference in emissions with and without the abatement system, using Districtapproved standard emission factors or source test data and the permitted annual usage orthroughputlimits expectedin theoperatingpermit. Simplyput,

7Reduction inAnnual PollutantEmissions (to*) 

### = BaselineUncontrolledEmissions

- Control OptionEmissions As noted above, the emissions reductions are calculated using realistic upper boundary operating assumptions (permitlimitconditions). The annualized cost of the abatement system can be estimated from the installed costofthecontrol and its expected annual operating and maintenance costs. 

# -

Annualizedcost DirectCosts 

### + IndirectCosts where

and DirectCosts (Sum ofthe Following): Labor Raw Materials ReplacementParts Utilities Indirect Costs (Sum oftheFollowing): Overhead 

### (80% ofLaborCosts) PropertyTax 

### (1 % ofTotal Capital Cost) Insurance 

### (1 % ofTotal Capital Cost) General & Administrative (2% ofTotal Capital Cost) Capital Recovery 

### (CRF

### xTotal Capital Cost) 

# ...... where Total Capital Cost 

# =- InstalledEquipment Cost The capital recovery factor (CRF) recognizes the time value ofmoney and converts the upfrontcapital cost (the installed equipmentcost) to an annualized cost. The capital RecoveryFactor (CRF) is givenby: 

### i(l 

### + i)n CRF

- 

## HI + i)n_l}

where and 

# . 1

n interestrate (assume i

# =0.10) lifetime of abatement system (assume n = 10 years unless shown to be different) For example, when i 

# = 0.10 and n 

# = 10, the capital recovery factor CRF 

## = 0.163. CurrentDistrictpolicy is to use a flat interest rate of 10 percent; over the years this rate has proven to be relatively conservative (actual rates generally less than 10 percent). The 10 percent rate is also consistent with accepted CARR and 

### EPA guidelines.

8

# ......



# - Forsimple cases ofcost-effectiveness determinations where the details ofoperating and maintenance costs, etc. are not readily available, a rough estimate of costeffectiveness canbe obtained as follows: Annualized Cost = InstalledEquipment Cost 

### x [Capital RecoveryFactor 

### + TaxFactor

### + Insur. Factor

### + G & A Factor 

### + Annual OperatinglMaintenance Factor] where CFR 

## = 0.163 Tax 

## = 0.01 Insur. 

## = 0.01 G&A 

## = 0.02 O&M 

## = 0.05 It should be reiterated that this estimation method is to be used as a first cut projectionwhen case or site specific information is not available and not necessarily as a 

### .final cost-effectiveness determination. However, it 

### can be useful for eliminating extreme control options or identifying control strategies worthy of further consideration. Finally, is clear that cost-effectiveness needs to be determined or reviewed on a case-by-case basis. Inherent physical constraints on the source or at the site can significantly increase the cost of the abatement system under review. Similarly, operational constraints can affect the cost-effectiveness figure by increasing or decreasing the potential annual emissions reduction. However, these operational constraints should be reflected in enforceable conditions 

### in the permit to operate (e.g., throughput orusage limits). An example ofa cost-effectiveness calculation is giveninAppendix C. 3.4 Maximum Cost Guidelines for BACf As noted above, for BACT determinations based on the "achieved in practice" category, no cost analysis is necessary. For the "technologically feasible/costeffective" BACT determinations, the District has adopted guidelines for the maximum cost per ton of

### air pollutants controlled that would be considered costeffective. These guideline cost maximums are consistentwith the broad guidelines provided by the California Air Resources Board's Office of 

### Air Quality Planning and Uaison. The BayArea Air Quality Management District's guideline cost limits are as follows: Pollutant 

## poe 

## NOx 

# S02 CO PMI0 Maximum Cost ($/ton) 17,500 17,500 18,300 nld 5,300

9

### NPOC 17,500



### B. Note that the cost·effectiveness trigger for NOx has been lowered to 17,500 dollars per ton, down from the 24,500 figure of an earlier BACT Workbook 

### draft. This brings the cost-effectiveness trigger for NOx 

### in line with that for precursor organic emissions, and consistentwith Regulation 2, 

### Rule 2, Section 302, which allows the interchangeabilityofNOx andPOCemission offsets. 

### Forspray booth coating operatkJns, thefollowing cost limits

### applyfor controlling

## poe orNPOe

### emissions: A Maximum cost.of 17,500 $/ton for the following spray booth coating operations: 

### i) Aerospace parts coating operations complyingwith Regulation 8, Rule 29. ii) Motorvehicle, rework/body shop coating operations complying with Regulation 8, Rule45. 

### iii) Motor vehicle, assembly plant coating operations complying with Regulation 8, Rule 13. iv) 

### Coating operations which have reduced VOC emissions by 

### < 35% through the use oflow VOCcoatings and/orhigh transfer efficiencymethods. Maximum cost of 13,750 $/ton for the following spray booth coating operations: i) Wood products coating operations complying with Regulation 8, Rule 32. 

### ii) Coating operations which have reduced VOC emissions by 

### > 35% to 

### < 80% through the use of low VOC coatings and/or high transferefficiencymethods. C. Maximum cost of 10,000 $/ton for the following spray booth coating operations: i) Flat wood coating operations complying with Regulation 8, Rule 23. ii) Metal coating operations complying with Regulation 8, Rule 19. 

### iii) Plastic coating operations complying with Regulation 8, Rule 31. iv) 

### Coating operations which have reduced VOC emissions by 80% through the use oflow VOCcoatings and/orhigh transfer efficiencymethods. The lower maximum cost allowed for specific spray booth coating operations is 

### a recognition that these specific operations have already significantly reduced their VOC emissions through the use of lower VOC coatings and/or higher transfer -.. efficiency methods. These emission reductions are reflected in the more stringent requirements required undertheir applicable Regulation 8 rules. The high costs of

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