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OAR Box 1787 

Prepped by Ollie Stewart 

Document Number: 

27) ll-B-12 

Docket Number: 

A-90-37 

Printed 11/4/2008 10:22:19 AM Sheet 27 of 147 
N S S File C 

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• _ » 

v.€0 ST<. 

USEZJ A-P 

MEMORANDUM 

UNITED STATES ENVIRONMENTAL PROTECTI 

Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina ^[7RiV 

o,,i 2 ii l J p 

_. „ •_ * ».fc 4 ___-**_*<V*« *__» I i 

.-__« _._M, ,_,.!_..-. I -J l 

SUBJECT: Implementation of North Co 

FROM: Gerald A. Emison, Direct 

Office of Air Quality 

Recovery PSD Remand 

rung"*and'Standards (MD-10) 

TO: Director, Air Management Division, Regions I , III , V, and IX 

Director, Air and Waste Management Division , Region I I 

Director, Air, Pesticides, and Toxics Division, Regions IV and 

Director, Air and Toxics Division, Regions VII , VIII , and X 

VI 

On June 3, 1986, the Administrator remanded a prevention of significant 

deterioration (PSD) pennit decision, involving the North County Resource 

Recovery project, to Region IX for their reconsideration. The permit was 

for a 33-megawatt, 1000 tons-per-day facility to be located in San Marcos, 

California. At issue was whether appropriate consideration had been given, 

within the best available control technology (BACT) determination, to the 

environmental effects of pollutants not subject to regulation under the 

Clean Air Act (Act).* The remand strongly affirms that the permitting 

authority should take the toxic effects of unregulated pollutants into 

account in making BACT decisions for regulated pollutants. This obligation 

arises from section 169(3) of the Act, which defines BACT as the maximum 

degree of emissions decrease which the permitting authority determines is 

achievable, taking into account "environmental .. . impacts." Essential 

to this process is the notification to the public of how the effects of 

toxic air pollutants, including those that are unregulated, have been 

considered in the PSD review and the subsequent consideration of the comments 

in making the final BACT decision. The purpose of this memorandum is to 

advise you of the impact of the remand on PSD permitting and to provide 

implementation guidance. This document builds upon and makes final the 

draft guidance of August 1986. 

Coverage 

Although the Act has given us the authority to review directly the 

considerable range of regulated pollutants, the remand clearly indicates 

that the Environmental Protection Agency (EPA) should incorporate consideration of all pollutants within its PSD determinations for all sources subject 

to PSD. This result is consistent with the fact that the PSD permitting 

process is charged ". . . to protect public health and welfare from any 

*A "regulated pollutant," or "pollutant subject to regulation under the 

Clean Air Act," is one which is addressed by a national ambient air 

quality standard, a new source performance standard, or is listed pursuant 

to the national emission standards for hazardous air pollutants program. 
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actual or potential adverse effect . . . from air pollution . . . ." and that 

increases in air pollution should be permitted ". . . only after careful 

evaluation of all the consequences . . . ." [section 160(1) and (2)]. 

Revisions to State implementation plans (SIP's), to comport with the 

Administrator's decision, should not be necessary. State or local agencies 

with delegated PSD programs automatically track this change in policy. 

Agencies implementing their own SIP-apDroved programs are also unlikely to 

need any regulatory changes. This: is oecause the remand is based on an 

interpretation of Act language, notably the definition of BACT, that is in 

most cases already contained in the plan. I ask that you confirm this with 

your States and applicable local Agencies. 

! 

Transition j 

As with any change in the way EPA does business, we have developed a 

transition plan for its implementation. The situations can be addressed 

most logically by dividing all PSD sources into three groups based on phase 

of permitting activity: those sources for which permit applications had 

not been filed, those for which permits had already been granted, and those 

for which applications had been filed but permits not yet granted. 

First, all PSD sources for which complete applications had not been 

filed as of the Administrator's June 3, 1986, decision are fully subject to 

the remand's requirements. Earlier applications present more complex 

policy considerations. 

One could argue, since the Administrator's decision is an interpretation 

of existing Act provisions, rather than a new requirement, that all PSD 

permits issued under the terms of the 1977 Amendments to the Act should be 

subject to the remand. However, program stability and equity to sources, in 

this second group, that have relied upon properly issued PSD permits militate 

strongly against such an approach. For these reasons, I have decided to 

exempt from the requirements of the remand all sources holding finally 

issued permits as of June 3, 1986. (Subsequent major modifications to such 

existing sources are, of course, subject to PSD review, including the 

application of the requirements of this remand.) 

The third group of sources consists of those for which PSD permits 

were in the pipeline (i.e., complete application filed but permits not yet 

issued) as of the date of the remand. It is appropriate that these sources 

also be subject to the terms of the remand. However, for permit applications 

which have successfully passed through the public comment period without 

environmental effects concerns being raised, the Regional Office may, at its 

discretion, issue these in final without further delay. 

The above enunciated transition policy applies directly to all EPA 

permit issuance procedures and also to those used by State agencies issuing 

PSD permits under a delegation of authority agreement pursuant to 40 CFR 

52.21(u). This transition policy does not automatically apply to PSD 
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permit decisions by States under SIP-approved PSD programs, except to the 

extent that environmental effects issues are raised by commenters. The 

policy does apply prospectively in a uniform fashion to all applications 

filed after June 3, 1986. States with SIP-approved PSD programs are, of 

course, responsible for enunciating reasonable transition schemes and I ask 

that you encourage them to adopt policies consistent with this one. These 

transition schemes, as with the substantive program itself, are unlikely to 

require rulemaking; however, the policies should be set forth in formal 

statements so as to further the goals of public awareness and consistent 

application. These policies and their implementation will be reviewed 

within the National Air Audit System to assess the need to require greater 

conformance. 

Required Analyses 

The BACT requirement outlined in section 169(3) of the Act contemplates 

a decision process in which the best available controls are defined for 

each regulated pollutant that a PSD source would emit in significant amounts. 

This case-by-case process is to take into account energy, environmental, and 

economic impacts and other costs. The toxic effects of unregulated pollutants 

are to be accounted for in deciding if the BACT otherwise being prescribed 

for regulated pollutants.still represents the appropriate level and type of 

control. If the reviewing authority judges the potential environmental 

effects of such unregulated pollutants to be of possible concern to the 

public, then the final BACT decision for regulated pollutants should in all 

cases address these effects and reflect, as appropriate, control beyond what 

might otherwise have been chosen. 

A recent remand determination made by the Administrator in another case 

provides further elucidation of the BACT process. In that case, Honolulu 

Program of Waste Energy Recovery (H-Power), PSD Appeal No. 86-6, Remand 

Order (June 23, 1987), the Administrator ruled that a PSD permitting 

authority has the burden of demonstrating that adverse economic impacts are 

so significant as to justify the failure to require the most effective 

pollution controls technologically achievable as BACT. 

The broad mandate with respect to toxics that is presented by the 

remand is not readily amenable to highly detailed national guidance that 

provides the appropriate permitting requirement in each case. There is no 

specific formula for making BACT decisions; this is a case-by-case process 

involving the judgment of the reviewing authority. While it may be possible 

to develop a framework of guidance based upon such factors as risk assessment 

and reference doses, this would entail a large effort that seems inappropriate 

at this time. It is more practical, however, for EPA to develop guidance 

for specific source categories that are of particular importance. The EPA 

has recently provided such BACT guidance with respect to municipal waste 

combustors. See memorandum entitled "Operational Guidance on Control 

TechTology for New and Modified Municipal Waste Combustors," from Gerald A. 

Emison, Director, Office of Air Quality Planning and Standards, dated 

June 26, 1987. Guidance on other source categories may be issued from time 

to i:ime as appropriate. 
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p 

a 

Today's policy charges the PSD review authority with analyzing at the 

outset the environmental impacts of proposed construction projects with 

respect tb air toxics which might be of concern, even 1f such matters are 

not initially raised by the public. Other types of environmental effects 

should also be addressed in response to public concerns, within the limits 

of the ability to do so. For PSD reviews consistent with this policy, each 

applicable permitting authority should initiate an evaluation of toxic air 

pollutants (unregulated as well as regulated) which the proposed project 

would emit in amounts potentially of concern to the public. The review 

authority!should evaluate unregulated pollutants for both carcinogenic and 

noncarcinpgenic effects. The National Air Toxics Information Clearinghouse 

(NATICH) data base contains considerable Information relevant to evaluating 

the effect, sources, and control techniques available for unregulated 

pollutants. I encourage you to urge permitting authorities to use NATICH 

as a sourjce of information as they conduct the analyses. Further information 

may be obtained by calling the NATICH staff at 629-5519. 

i 

The jresponse to the Administrator made by EPA Region IX in its analysis 

of the Nojrth County permitting decision is attached. Although this example 

illustrates only one of several acceptable approaches, it 1s a well thought 

out analysis that provides a useful example to consider for future permitting 

exercises. 

Headquarters has several other mechanisms 1n effect to support analyses 

with respect to toxics. These include a recent report which helps to 

estimate toxic air emissions from various sources (Compiling Air Toxics 

Emission Inventories, EPA-450/4-86-010). The burden of proof regarding 

emissions estimates, of course, rests with the applicant, but the techniques 

discussed in the document should be useful in determining if the applicant's 

estimates are reasonable and address appropriate pollutants. In addition, 

the Office of Research and Development (ORD) has released a control technology 

manual which is valuable in evaluating how control devices for particulate 

matter and volatile organic compounds differ 1n their abilities to control 

various toxic species of these criteria pollutants (Control Technologies 

for Hazardous Air Pollutants, EPA-625/6-86/014). 

Support will also be available on a case-by-case basis from the Office 

of Air Quality Planning and Standards (OAQPS) and ORD. In particular, we 

have formed a control technology center to provide assistance to the review 

authority in determining BACT. This center can offer a range of activities, 

including evaluation of source emissions, identification of control techniques, 

development of control cost estimates, identification of operation and 

maintenance procedures, and, in a few situations, in-depth engineering 

assistance on individual problems. Other planned activities include the 

publication of technical guidance to assist in the evaluation of selected 

types of sources. Contact points for the control technology center are 

Lee Beck in OAQPS (629-0800) and Sharon Nolen in ORD (629-7607). We expect 

this support to limit the effort required of PSD reviewing authorities. 
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Public Participation 

One of the most important features of this policy is the requirement 

that the affected public be fully informed of the potential toxic emissions 

from a proposed project and of what the reviewing authority has done to 

minimize this potential within the BACT decision. A specific discussion of 

toxics concerns in a technical support document might be helpful in accomplishing this information transfer. Additional concerns related to the 

environmental effects of unregulated pollutants raised by commenters must 

then be addressed in the final BACT determination. This process is of : 

central importance to PSD permitting and comments received must be adequately 

addressed in the final decision. Strong public participation is consistent 

with the PSD goals contained in section 160 of the Act, which relate toj 

informing the public of increased air pollution, including that due to i 

unregulated pollutants. ! 

t 

It should be noted that although these analyses are used in the BACT 

decision, they will not be used as the basis for disapproving a project' 

that has agreed to apply BACT. In other words, today's policy requires that 

toxics be copsidered in the control of the proposed project only to the 

extent that the level of control chosen as BACT is achievable. 

Enforcement 

In the case of delegated (as opposed to SIP-approved) PSD programs, 

EPA has various enforcement tools. Pursuant to 40 CFR 124.19, any party 

that participated in the public proceedings with respect to a proposed 

permit may, within 30 days of the final permit decision, petition the 

Administrator of EPA to review any condition of that permit decision. The 

Administrator may also seek to review any such permit condition on his own 

initiative. Should this appeals procedure be unavailable in a particular 

case, EPA has the authority, depending upon the facts of the case, to 

withdraw the delegation with respect to an individual permit that is being 

or has been issued inconsistently with the terms of that delegation. Thus, 

EPA may be able to directly intervene in the issuance of a PSD permit to 

ensure implementation of today's policy. This withdrawal of delegation is 

not the preferred course of action but it may be available if needed. 

The consideration of air toxics in PSD permitting is a requirement of 

the Act and, through the definition of BACT, is incorporated in the SIP's. 

Therefore, violation of this policy would constitute a SIP violation and be 

enforceable by EPA. Section 113(a) of the Act provides for Federal issuance 

of a notice of violation in the case of a violation of a SIP. If the 

violation continues for more than 30 days, section 113(b) provides that the 

Administrator shall commence an action for injunction or civil penalty, or 

both. In addition, section 167 of the Act specifically provides that EPA 

take legal action to prevent the construction of a major emitting facility 

that does not conform to the requirements of PSD. Under section 167, EPA 

can issue an administrative order or commence a civil action. Since noi 
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t 

notice of violation would be necessary, in this case, EPA can use section 

167 to order immediate cessation of construction or operation. Note also 

that this section has been construed as providing EPA with authority to take 

enforcement action against sources out of compliance with PSD even if they 

have already been constructed. These remedies are more likely to be used 

in the case of SIP-approved programs than with delegated programs, for 

which an appeal under 40 CFR Part 124 would generally be the preferred 

course of action. 

Enforcement actions are pursued after reviewing a range of factors 

relevant to each particular case. For this reason, I am not setting forth 

detailed provisions as to required enforcement measures. There are, however, 

certain situations in which enforcement action is generally appropriate. 

These include procedural deficiencies, such as failure to solicit public 

comment on air toxics issues for applicable permits, and failure to address 

the air toxics concerns raised by public comment. Enforcement with respect 

to permits already in the pipeline should follow the transition scheme in 

today's policy for delegated programs and the State or local agreement 

established with EPA for SIP-approved programs. 

The Act and the PSD regulations require that States submit a copy of 

the public notice for proposed permits to EPA. I urge the Regional Offices 

to ensure that such notices are submitted and are reviewed for conformance 

with the criteria contained in this document. Although enforcement mechanisms are available to address noncomplying sources, our efforts to implement 

today's policy will be much more effective if taken prospectively and in 

coordination with the State permitting process. 

Conclusion 

Today's guidance summarizes the broad ranging impact of the June 3, 

1986, remand and provides some insight into the analyses and public 

disclosure that now should take place. We will continue to support and 

monitor subsequent decisions and to assess the need for more detailed or 

expansive guidance. Questions on today's nuidance should be addressed to 

Michael Trutna (629-5345) or Kirt Cox of OAQPS (629-5399). 

Attachment 

cc: C. Potter 

A. Eckert 

D. Clay 

Regional Administrator, Regions I-X 

Air Branch Chiefs, Regions I-X 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

215 Fremont S treat 

San Francisco. C*. 94106 

MEMORANDUM 

DATE: August 15 , 1986 

SUBJECT: North County Resource Recovery Associate s 

PSD 

FROM: 

TO: 

Da$j#£4Pi7^6i^jKWpy~Wrec tor 

Air Management DiviMon, Region 9 

i 

Lee M. Thomas:, Administrator 

U.S. Environmental Protection Agency 

This is in response to the June 3, 1986 remand of 

Region 9's April 2, 1985 determination to issue a .Prevention 

of Significant Deterioration (PSD) permit to the North 

County Resource Recovery Associates for the construction 

of a 1000 ton per day resource recovery facility. The 

remand charged Region 9 with reconsidering the effects 

of unregulated pollutants when making PSD determinations. 

Region 9 has reviewed the relevant BACT decisions 

and has prepared a response to the Administrator's remand, 

as recommended in the July 21, 1986 guidance memo from 

Gerald A. Emison, Director, Office of Air Quality Planning 

and Standards. Our response with supporting materials 

is attached. 

If you have any questions regarding the enclosed 

materials please contact me at 454-8201 (FTS) or have your 

staff contact Wayne A. Blackard, Chief of our New Source 

Section at 454-8249 (FTS). 

Enclosures 

J 
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RESPONSE TO PSD REMAND 

NORTH COUNTY RECYCLING AND ENERGY RECOVERY CENTER 

(PSD Appeal No. 85-2) 

On April 2, 1985 the Director of the Air Management 

Division, EPA Region 9, made a determination to issue a Prevention 

of Significant Deterioration (PSD) permit to the North County 

Resource Recovery Associates (NfRRA) for the construction and 

operation of a 33 megawatt, 1000 ton per day resource recovery 

facility. During the following appeal period EPA received 

three petitions filed pursuant to 40 CFR 124.19 requesting the 

Administrator to review Region 9's decision to issue the PSD 

permit. The Office of the Administrator reviewed the petitioners' 

comments and Region 9's responses to the comments and determined 

that Region 9 had satisfactorily addressed all of the petitioners' 

allegations with the exception of Region 9's assertion that EPA 

lacked the authority to "consider" pollutants not regulated by 

the Clean Air Act when making a PSD determination. The Administrator felt that Region 9*s assertion was overly broad and that 

when making a PSD determination, in particular a best available 

control technology (BACT) decision, a permitting agency must 

consider not only the environmental impact of the controlled 

regulated pollutant but must also consider the environmental 

• impacts of any unregulated pollutants that might be affected by 

the choice of control technology. For this reason the Administrator remanded the PSD determination to Region 9 for reconsideration and action consistent with the above interpretation of EPA authority. 

In response to the above, Region 9 has reviewed the BACT 

decisions made for the NCRRA PSD permit. Under the PSD regulations NCRRA must apply BACT to control emissions of SO2, NOx, 

lead, mercury, and fluorides from their proposed resource 

recovery facility. BACT is defined in the Clean Air Act as 

"...an emission limitation based on the maximum degree of 

reduction of each pollutant subject to regulation under this 

Act...on a case-by-case basis, taking into account energy, 

environmental and economic impacts and other costs..." Under 

environmental impacts our review of the original BACT determination 

included the impacts from both regulated and affected unregulated 

pollutants. The control of particulates, CO, and VOC emissions 

are not directly subject to the federal PSD BACT review, but 

are subject to the nonattainment permitting regulations which 

are administered by the San Diego Air Pollution Control District. 

NCRRA is proposing to use a dry scrubber with a baghouse 

to control emissions of SO2, acid gases, and particulate matter 

from the proposed resource recovery project. The dry scrubber 

consists of a spray dryer and a baghouse. The spray dryer injects 

an atomized lime slurry sorbent into the flue gas strean. The 

baghouse removes the dried sorbent and flyash (particulate matter) 

from the flue gas. The dry scrubber will be designed for a 

flue gas flow of 225,000 acfm at an inlet temperature of 
-2-

340 degrees F and a maxiaua outlet temperature of 265 degrees F. 

NCRRA expects the dry scrubber system to provide 83% removal of 

SO2 and 95% removal of acid gases as well aa 99.5% removal of 

particulates. 

Recent tests of emissions control devices for waste fired 

boilers (the latest being the Quebec City Test Program) have 

shown that properly designed and operated control devices can 

significantly reduce eaissions from resource recovery facilities. 

In particular, an acid gas scrubbing system operating at optimal 

stoichiometric ratios, at low temperature, in tandem with a 

baghouse;can achieve very high removal efficiencies of particulates, S<p2r HC1, organics, and heavy metals. The tests indicate 

that theNCRRA's proposed emission control system (lime slurry 

spray dr^er, baghouse, low temperature flue gas) is the most 

efficient for controlling the unregulated pollutants from a 

resourcejrecovery facility. While certain technologies may have 

the potential for greater removal of regulated pollutants (e.g. 

a wet scrubber may yield greater SO2 removal), available data 

suggests that greater control of unregulated pollutants will 

not result. Region 9 believes that the NCRRA's proposed control 

technology will have very high collection efficiencies of 

dioxins, furans, and heavy metals, with collection efficiencies 

of 95% for HC1, and greater than 90% for mercury. We conclude 

that a lime slurry spray dryer with a baghouse provides the 

greatest degree of control currently achievable for the relevant 

air toxics concerns and therefore, emission limitations based 

on the operation of a lime slurry spray dryer with a baghouse 

and continuous emission monitors constitute BACT for the control 

of SO2/ lead, mercury, and fluorides from the NCRRA facility. 

In addition to the proposed acid gas BACT, Region 9 also 

reviewed the BACT decisions made for controlling NOx emissions 

from the NCRRA facility. NCRRA has proposed to control NOx 

emissions with low excess air and staged combustion. After 

reviewing all of the available control technologies, Region 9 

believes that the alternate NOx control technologies currently ... 

available for resource recovery do not offer any better control 

of the affected pollutants (organics such as dioxins and furans) 

than do the controls proposed for the NCRRA facility. Our 

review included staged combustion, selective non-catalytic 

reduction; selective catalytic reduction, wet flue gas denitrification, and the different categories of source separation'. 

Our review also took into account the effects of the district 

permit requirements designed to reduce organic toxic pollutants 

(minimum 1800* F furnace temperature and minimum 2 second 

residence time in the combustion zone). We conclude that an 

emission limitation based on the use of low excess air and 

staged combustion and with continuous emission monitors is BACT 

(considering the effect of unregulated pollutants) at this time 

for the control of N0X emissions from the NCRRA facility. 

As part of our BACT review of the NCRRA PSD permit, Region 9 

prepared several charts listing the available SO2 and NOr control 

options for the NCRRA facility, ranked in order of control 
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\ 

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effectiveness, witth the extimated impacts of the controls on 

the projects' other air pollutants. The charts were prepared 

using data froa existing Region 9 PSD permits, permit applications, 

district permits, emission control technology reports from the 

California Air Resources Board and the New York City Department 

of Sanitation, and from reports on the Quebec City Test Program. 

The impacts on other pollutants were estimated using our best 

engineering judgement based on the available data. We have 

included these charts with this report for your review. 

After reviewing the above facts, Region 9 has concluded 

that no greater controls for the regulated pollutants can be 

applied that would be more effective in reducing the emissions \ 

of unregulated pollutants. Therefore, the BACT proposed by NCRRA 

and the BACT decisions made by Region 9 in the April 2, 1985 j 

PSD determination are reaffirmed as BACT for controlling SO2, 

NOx, lead, mercury, and fluoride emissions from NCRRA's 

proposed North County Recycling and Energy Recovery Center. j 

:*• 
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REFERENCES 

1. Air Pollution Control at Resource Recovery Facilities, 

California Air Resources Board, May 24, 1984. 

2. Clarke, Marjorie J., Emission Control Technologies for 

Resource Recovery, New York City Department of Sanitation, 

March 15, 1986. 

3. Hay, D.J., Finkelsteim, A., Klicuis, R., Masentette, L., 

"The National Incinerator Testing and Evaluation Program: 

An Assessment of A) Two-Stage Incineration B) Pilot 

Scale Emission Control", Presented at the 79th Annual 

Meeting of the Air Pollution Control Association, 

June 22-27, 1986, Minneapolis, Minnesota. 
ti_oj«cci north Cb'u,.Lr ___.. 

EPA 

(Ranked in De 

Control Options 

Spray Dryer, Alkaline 

Slurry, Baghouse 

Spray Dryer, Lime Slurry , 

Baghouse 

Spr.iy Dryer, Alkaline 

Slurry, ESP 

Dry Injection , Sodium 

Sorbent, Baghouse 

Spray Dryer, Lime Slurry , 

EESP 

Dry Injection , Lime, 

Baghouse 

Wet Scrubbing, Alkaline. 

Dry Injection , Sodium 

Sorbent, ESP 

Dry Injection , Lime, ESP 

Region 9 - New Source Section 

BACT ANALYSIS 

creasing Order of Oontrol Effectiveness) 

% Control 

80-95 

75-90 

75-90 

70-85 

65-85 

65-80 

50-90+ 

50-75 

40-70 

Emission 

Rates 

lbs/ton 

(ppm) U 

0.26-1.04 

(9-35) 

0.52-1.30 

(18-44) 

0.52-1.30 

(18-44) 

0.78-1.56 

(26-53) 

0.78-1.82 

(26-62) 

1.04-1.82 

(35-62) 

0.52-2.61 

(18-88) 

1.30-2.61 

(44-88) 

1.56-3.13 

(53-106) 

Emissions 

(tons/yr) 

53-212 

106-265 

106-265 

159-318 

159-371 

212-371 

106-530 

265-530 

318-636 

Heavy 

Metals 

Exc 

Exc 

good 

Exc 

Good 

Good 

Poor- - -

Fair 

Fair 

Project C 

Project T 

Pollutant 

Datet A 

ategoryt Resource Recovery 

ypet 1113 TFD, RDF, 36 KW 

t Kb 

ug 15, 1$86 

Project Engineer: Bob Baker 

Control Effectiveness on 

Other Pollutants 

Dioxin 

Furans 

Exc 

Exc 

good 

Poor 

Good 

Poor 

—Poor 

Poor 

Poor 

HC1 

Exc 

Exc 

Exc 

Exc 

Exc 

Exc 

EXC 

Exc 

Good 

Hg 

Good 

Good 

Fair 

Poor 

Fair 

Poor 

Fair 

Poor 

Poor 

Lead 

Exc 

Exc 

Good 

Good 

Good 

Good 

Fair 

Pair 

Fair 

(1. Corrected to 12% 002/

 2 4 hour average 

i* -
EPA Region 9 - New Source Section 

BACT ANALYSIS 

(Ranked in Decreasing Order of Control Effectiveness) 

Page 2 

Control Options 

Dry Injection, Limestone, 

ESP 

Wet Scrubbing, Water 

Source Separation 

% Control 

25-40 

20-30 

5-10 

(1 Corrected to 12% CD2, 24 hour average. 

Emission 

Rates 

lbs/ton 

(pem) (1 

3.13-3.91 

(106-132) 

3.65-4.17 

(124-141) 

4.69-4.95 

(159-168) 

Emissions 

(tons/yr) 

ti.ojecLt_Nortn Cbuity * -

Project ULe^ty , ^sourc e RECSS TM 

Project Typet^mrm^^jiF , 36 MW 

Pollutant! ^5 T -

Date: AJJQ ls/lSfl£ — 

Prr\ias*t- rv_^7—___ __. . -

...__v| XJ I JLJOO 

Project Engineert Bob Baker 

Oontrol Effectiveness on 

Other Pollutants 

Lea3 T 
EPA Region 9 - New Source Section 

BACT ANALYSIS 

(Ranked in Decreasing Order ot Control Effectiveness) 

Project> North Ooupty RRF 

Projec t Category; Resource Recovery 

Project Type: 1113 1PD, RDF, 36 m 

Pollutant: tOY 

Date: Aug 15, 1986 

Project Engineer: Bob Baker 

Control Options % Control 

Emission 

Rates 

lbs/ton 

(ppm) d 

Emissions 

(tons/yr) 

Control Effectiveness on 

Other Pollutants 

Dioxin 

Furans 

VOC CO Heavy 

Metals 

Selective Catalyti c 

Reduction (SCR) <2 

Wet Flue Gas Deqitrifi 

tion (FSDJ

 ( 2 caSelective Non-Catalytic 

Reduction (SNCR) 

Low Excess Air/Staged 

Oontoustion 

Flue Gas Recirculation 

Source Separation 

90-95 

80-90 

30-60 

30-35 

10-15 

Minimal 

0.31-0.61 

(15-30) 

0.61-1.21 

(30-60) 

2.43-4.25 

(110-200) 

3.94-4.25 

(185-200) 

5.16-5.46 

(240-260) 

65-129 

129-258 

473-860 

795-860 

1032-1118 

Unk 

None 

None 

Unk 

Worsen 

Eair 

Poor 

None 

._ None 

Unk 

Worsen 

Poor 

Poor 

None 

None 

Unk 

Worsen 

Poor 

None 

Poor 

None 

None 

None 

Poor 

(1 Corrected to 12% CO2, 24 hour average. « 

(2 This control technology has not yet been applied to refuse cocrbustion, and has not been considered a s a 

transferabl e technology due to as yet unresolved technological problems. 

* * 
EPA Region 9 - New Source Section 

BACT ANALYSIS 

(Ranked in Decreasing Order ot Control Effectiveness) 

Project: North OouQty RRF / 

Project Category; Resource Recovery \ 

Project Type: 1113 1PD, RDF, 3o NW 

Pollutant: ; NO'y • -m 

Date: Aug 15, 1986 

Project Engineer: Bob Baker 

Oontrol Options % Oontrol 

Emission 

Rates 

lbs/ton 

(ppm) d 

Emissions 

(tons/yr) 

Control Effectiveness on 

Other Pollutants 

Dioxin 

Furans 

VOC CO Heavy 

Metals 

Selective Catalytic 

Reduction (SCR) <2 

Wet Flue Gas Denitrification (EGDn) <2 

Selective Non-Catalytic 

Reduction (SNCR) 

Low Excess Air/Staged 

Combustion 

Flue Gas Recirculation 

Source Separation 

90-95 

80-90 

30-60 

30-35 

10-15 

Minimal 

0.31-0.61 

(15-30) 

0.61-1.21 

(30-60) 

2.43-4.25 

(110-200) 

3.94-4.25 

(185-200) 

5.16-5.46 

(240-260) 

65-129 

129-258 

473-860 

795-860 

1032-1118 

Unk 

None 

None 

unk 

Worsen 

Fair 

Poor 

None 

None 

Unk 

Worsen 

Poor 

Poor 

None 

None 

Unk 

Worsen 

Poor 

None 

Poor 

None 

None 

None 

Poor 

(1 Corrected to 12% OO2, 24 hour average. 

(2 This control technology has not yet been applied to refuse combustion, and has not been considered a s a 

transferable technology due to a s yet unresolved technological problems.