OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

19)11-1-11 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:18 AM Sheet 19 of 142 

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PROPOSED CAPCCA 3ACT ANO LAEH POLICY 

CAPCOA endorses the concept of BACT and LASH and promotes 113 continued 

comprehensive application to new and modified scurcaa In Calfornla. CAPCOA 

beilavas that this goal Is ba3t accomplished througn the following 

guidelines to the extant allowed by district rules and regulations. 

Additional guidelines may be needad for the control of toxic compounds: 

1. A M basic equipment and control alternatives for a project should 

ba evaluated In any appI IcatIon for an authority to construct. 

Applications not containing the full ranga of alternatives and 

their technical and economic feasibility may be deseed Incomplete, 

unless the mest desirable basic equipment and the most effective 

control are evaluated In the application. A district may choose to 

perform part or all of thl3 evaluation of alternatives. 

2. Any district guidelines fcr source applicants cn 3ACT or LAEH 

snculd Include performance levels equivalent to tha mo3t 3trlngent 

control for a given category of source. Where alternative basic 

equipment exl3t3. dl3trlct3 may specify the lowest emitting devices 

a3 part of the 3ACT cr LAEH determination. 

3. 3ACT or LASH should be ace I led to any new or modified equipment 

wnere the new or mcdlflec eculcment would, by Itself, emit a 

pollutant at a leval greater than emission thresholcs for 

triggering SACT cr LAEH requirements. 3ACT or LASH shculd also be 

applied wnere the cumulative emission increase frcm the Initial 

source and subsequent modifications wculd trigger SACT or LAEH 

requirements. 

4. 3ACT or LAEH decisions sr.cul'd be based cn technological 

feasibility. If a district cheeses to consider cost In 3ACT or 

LAEH decisions, cost effectiveness should only be considered under 

the following conditions: 

The aggregation of equipment considered In tha permitting 

action Is permitted to emit no greater than the following 

amounts: 550 pounds per day carbon monoxide; 150 pounds par 

day for particulate matter; 82 pcund3 per day fcr PM10; and 

2C0 pounds per day fcr volatile organic compounds, or!de3 of 

nitrogen, and oxides of sulfur. 

The minimum cost per ten of emissions controlled for remedial 

or control equipment shculd consider the highest cost-per-ton 

value for control requirements In any regulation adopted for 

the applicable category and size of source by any local, 

state, or federal government authority for the pollutant In . 

quest Ion. 

c. Cost effectiveness may not be considered In districts 

which experience two or more ambient air quality standard 

violations of greater than 50 percent of the applicable state 

or federal air quality standard within the last calendar year . 

prior to application submittal. 
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DRAFT 

DESCRIPTION OF THE CAPCOA 3ACT AND LAEH POLICY 

INTHCOUCTION: 

Tha CAPCOA BACT and LAEH Policy was developed by tha CAPCOA 

Engineering Managers Committee to promote consistent and stringent BACT 

and LAEH determinations among the air pollution control districts of 

California. It will be submitted to tha CAPCOA Hoard of 0lrector3 for 

endorsement, and upon aooroval mada available for use by the districts. 

The Policy contains guidelines fcr addressing tha 

responsibilities of the applicant and district In the evaluation of 

control alternatives, specification of 3ACT/LAEH (both terms appear In 

the Policy: most districts' BACT Is equivalent to LASH, while a few 

districts have both), use of a "dual source definition," and criteria 

for economic feasibility considerations. The guidelines are not 

Intandad to preempt district rule3 and regulations; however, districts 

may wish to amend their rules and regulations to be consistent with tha 

guidelines. In addition, these guidelines are written fcr use In 

conventional new source review of criteria pollutants, and may or may 

net apply to ncn-crltarla or toxic air pollutants. 

0S3CHIPTICN CF GUIDELINES: 

GLi'rfe' 'r»* 1 of the Policy provides for a comprehensive 

evaluation of 3ACT/LAEH In an application. It encourages districts to 

require that applicants evaluate In their appl icat lcr.3 the full array of 

potential basic equipment and control alternatives along with the 

proposed equipment and controls. Acallcatlcns submitted without 

sufficiently complete arrays of alternative basic equipment and control 

technologies should be rejected. 

For examole, an application for a dlesel-flred engine with an 

aftercooler and Ignition retard could also Include an evaluation of 

other control techniques for dlesel-flred engines as well as basic 

equipment alternatives such as: electric motor, gas-fired engine, or 

gas turbine (depending on tha circumstances); and the corresponding 

array of controls for each. The district can then evaluate the 

feasibility of each, the rationale of the applicant, and mafce a 

decision. 

G-g Malin ; 2 provides the district, upon receiving a complete 

application, with tha ability to choose a level of control consistent 

with tha cleanest technology. It states that any district guideline, 

either formal or Informal, for source applicants on BACT/LAEH should 

along with descriptions of control techniques or equipment, also provide 

a performance-1 eve I for each source category. Such performance-levels 

shculd be at a minimum equivalent to the mo3t stringent control required 

for' a given category of source. Dl3trlct3 may therefore specify basic 

equipment as part of tha BACT/LAEH decision, or that tha corresponding 

performance level be met by whatever equipment Is chosen by the 

applleant. 

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For example, a district guideline may specify that any 

reciprocating engine must meat a BACT/LAEH requirement of 1.5 gm/bhp-nr, 

which corresponds to a level achievable by a gas-fired, rich burn engine 

with a non-selective catalytic reduction catalyst. In an application 

for an engine, the applicant 3hculd provide the array of alternatives 

and how the equipment proposed. If not ga3-flred, 'will meet the 1.5 

gm/bhp—hr level. 

Note too that applicants shculd be made aware that BACT/LAEH 

requirements may change during the procss3lng of an application and 

during the public comment period If a more appropriate control level 

becomes avaI table. 

Gu i^»Mn» •? of the Policy Is Intended to encourage districts 

to evaluate the applicability of BACT/LAEH requirements both on a 

permit-unit and 3tatlonary-scurce basis. I.e., under a "dual source 

definition." Some districts' rule3 a I lew sources to site large units 

without SACT/LAEH control technology providing the applicant 

simultaneously recuce3 a similar amount of emissions from existing 

permit unlt3 within the stationary scurce ("netting cut"). 

For example, a district's threshold fcr triggering 3ACT/LAEH 

Is 2C0 lb/day. An existing stationary scurce suomits an application to 

sits a new cogeneration turbine wnlch will emit 230 lb/day of NOx 

emlssicn3. and to sr:ut down an existing boiler which will provide 180 

lb/day of NOx emission reductions. The net amissions will be 100 

lb/day. Under seme district rules 3ACT/LAEH Is not triggered because 

the net change Is not over the threshold level of 2C0 lb/day. Guideline 

3. however, promotes that the turbine shculd trigger SACT/LAEH because 

by Itself It would be over tha threshold of 200 lb/day. 

Guideline 3 also encourages SACT/LAEH requirements be applied 

to the Incremental growth of a stationary scurce wnere multiple 

permitting act lens of smaller permit unlt3 bring the scurce clcse to the 

threshold levels fcr SACT/LAEH. Cncs the next mod IfIcatIon causes the 

scurce to exceed threshold emission levels for SACT/LAEH, that unit and 

all new units would be subject to SACT/LAEH. 

Fcr example, an existing stationary scurce has over the years 

since the adoption of a dlstrlct'3 New Scurce Review rule (with a 

BACT/LAEH threshold of 2C0 lb/day), received permits for 6 spray booths, 

each emitting 30 lb/day of H C it submits an application for a 7th 

soray booth, also to emit 30 lb/day. By Itself, the 7th soray booth 13 

not over the threshold of 200 lb/day. However, collectively with the 

7th booth, the stationary source Is over the threshold. Guideline 3 

would promote the application of 3ACT/LAER to the 7th booth and to any 

future modifications which talcs the stationary source over the 

threshold. 

GuMeltr* * states that 3ACT/LAEH decisions should be based on 

technical feasibility. However, It a 130 acknowledges a consideration 

for cost and provides criteria by which cost can be considered In a 

decision. 
First, It provides a cap on tha permitting action for naw or ' "^.. *• 

modified pieces of equipment, over which cost should not be cons I dared. 

Thay correspond to mo3t districts' thresholds for triggering offsats and 

tha EPA thresholds for PM and PM10. They are: 550 lb/day for CO, 150 

lb/day for PM, 82 lb/day for PM10, and 200 lb/day for NOx, HC, and SOx. 

Sacondly, It provides that a cast evaluation should constitute a 

comparison to tha highest co3t-per-ton (co3t-affeetIveness) value for 

any regulation adopted for tha applicable category, sirs, and pollutant 

source. Thirdly, It excludes cost consideration for those districts 

which are under a more severe air quality 3ltuatlcn. The 3tatu3 Is 

determined by whether ambient air quality standard violations 

experienced by a district during the last calendar year are greater than 

SOS over, either a 3tate or federal standard. For ozone, the threshold 

concentration Is 13.5 pphm which l3 5GS over the state oxidant AAGS of 9 

pphm. Therefore, districts experiencing ozone concentrations over 13.5 

pphm 3hculd not use co3t considerations In making 3ACT/LAEH decisions 

for HC or NOx sources. 

An examole Is where an applicant proposes to site two 25 

MWBtu/hr gas-fired boilers to be ccerated less than 365 days/year and 

less than 2-* hrs/day In a district with a 3ACT/LAEH thresncld of 150 

lb/day. Each 13 expected to emit uncontrolled 3-A lb/cay of NCx. 

totalling 133 lb/day. 3ACT/LASH Is triggered for the two units. 

Collectively they are belcw the 2C0 lb/day cap specified In Guideline 4. 

Also, the district's hlgne3t ozone violation In the last calendar year 

13 13 ppnm (belcw the 13.5 pphm cap also provided fcr In Guideline 4) . 

Therefore a cost analysis may be considered. To simplify the examole, 

assume the following control techniques will be evaluated. In descending 

effectiveness: SCR (at 80% control). FGH (at 60S control), and lo-Nox 

burners (at 5C% control), all with combustion modifications. 

For comoustlcn sources, the highest cost-effectiveness for a 

regulation adopted by a district Is s3.CC0/!cn of NCx controlled (the 

SCACWD Is conslCering a regulation with a cost-effectiveness of 

S20,0C0/tcn of NOx controlled). The rough estimated cost under the 

conditions specified for the bolters for the SCR Is siS.CCO/tcn 

controlled, for the FGH s3,0C0/tcn controlled, and the lo^-NCx burners 

S4.000/tcn controlled. Therefore, the district could maJce a 

determination of FGH as BACT/LAEH for this situation. 

Note that for districts which are experiencing violations 

greater than 5CS of the standards would not go through this type of a 

cost analy3l3 In determining BACT/LAEH. 

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