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SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

Best Available Control Technology Guidelines

Part A: Policy and Procedures

May 21,1999

Deputy Executive Officer

Planning, Rule Development and Area Sources

Jack P. Broadbent

Assistant Deputy Executive Officer

Planning, Rule Development and Area Sources

Elaine Chang, Dr. Ph.

Planning and Rules Manager

Planning, Rule Development and Area Sources

Anupom Ganguli, Ph.D.

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Authors:

Reviewed By:

Martin Kay, P.E.

Tran Vo, P.E.

Adewale Oshinuga

Knut Beruldsen

Bill Wong

Barbara Baird

Air Quality Analysis and Compliance Supervisor

Senior Air Quality Engineer

Air Quality Engineer II

Air Quality Engineer II

Senior Deputy District Counsel

District Counsel
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CHAPTER a- HOW ARE BACT AND T-BACT DETERMINEn?

The BACTi$·CommerciallyAvailable:

At least one vendor must offerthis equipmentfor regular orfuI scale operation

in the.JJnited States. A performallce warranty or guaranty must be available

wiIh the purdlase of the control techtdogy. as weB as parts service. .

The BACTIs Consistent with Clean Fuel Requirements:

.A dean fuel is one that prodIlCeS air ellissiOIlS equivalent10 or Iowerthan

natInI gas for NOz.so.. Roo. and fine respilable partictiate matter(PM,o).

Besides nabI'af gaS. other clean fuels are methanol, iquid peboteum gas (LPG),

and hydrogeL The burring of IancIIiI. cigeSte. refinefy and oIher by-product

gasesis notsubject10 the clean fuels requirement. However. the c:ambusticn of .

these fuels must ccmpIy will otherACiNJD rules, including 1he sulfur CCldent of

:.. thefuel .

The requirement ofa clean fuel is based on eng.eetilg feasNity. Engineeilg

feasa>ily considers 100 avaiabiIily of a dean fuel and safety COlicems . .

asSCJC:ialed with that fuel. Some state and local safety requilements limitthe

types of fuel which can be used fer emerges~)'staladby purposes. Some fire

departlTlents orfire malsha1s do not aIiaw the slDrage ofLPG near ocx:upied

buildings. Fie officials have, in scme cases, vetoed 1heuse Of meti.a.cl in

hospitals Ifspecial handJilIg orsafety c:onsideratioilS preclude the use ofthe

clean fuel, 1heAQMD has aBowed the use offuel ciI as a staadJy for fuel in

bailers and heaters, and far emesgerpt stalldby gelaeialDiS. The use of·~

fuels must meet 1he requiremetlts of AQMD rules limiting Nez and sulfur .

emissions.

The BACTDoes Not Resuit'ln a SIgnificant Impact on other

Environmental Media:

The goal of BACT is to nuine emissialS and to not baalSfer pclkltion from

one.media to anoIher. BACT cancidaIes will be reviewed to detetnilae the

secorldalyenvironmental impacts, incIucing other mecia and energy. that may

result atthe time it is appied to an individual permit appIicatioiL All new

teemoIogies wi! be examined for these fadors-cxxasistellt with the current

BACT Guidelines and recogIlizilg USEPA's I'll3Idate for l.DwestAchievable

EnissiuaI Rate (LAER). .

The BACTIs RerlBble:

AI techilOklgies must-.xlSbate a minimum of 12 moldhs of perfOiii&1Ce In

cad60ns that anirrorreal wOrld appic:aliol L This one year of data can be on .

pilot scale systems on a sip stream. orfull scale regular c:onUil8l'ciaJ operation.

DtI'ing the 12 n'IOIlths of operatioal, the teehalOlogy must demoIlStiate a IeYeI of

reJiabiIily CDllSistentwith the basic operatiOlL The teetlnoIogy must net

contabJte to a significant reductiOn in the avaiatldty ofthe basic equipment

- 29 AUGUST 1995
CHAPTER Sa HOW ARE BACT AND T-8ACT DETERMINED?

The BACTis Achievedin Practice:

. AchieVed in practice c:cntroJ teet... tOIagymay in operation in the United States

oranyOther part ofthe world. Sources for aetIieYed in practice levels include

- the CAPCOA BACTCIeaIaaghouse and the USEPA RACTJBACTJLAER

Clearinghouse. lAER deter.nilsationsmade by local Disn:tsin California. and

byStates and local DistrictS throughclutthe United States. respectively, ate

published in 1hese'~

Each permittillg ieam oflie AQMD Will alSo ~their Scurces for achieved in

Ievets. The Control tee:h1Ologymust passthe othercriteria for

COiII.telciaI avaiabi6ty; reiabiity other envirOlmentaJ in1p8Ct$.

In pcadice. most BACT detem*IatiOnS are based on achieved in practice . considerations. Most Of the equipment identif.ed in the BACT Guidelines has

- been in safe. reliable operation in multiple IIx:a£oIIS throughout the South Coast

Air Basin. This equiJ)ment has eiherbeen scuce tested orobserved to be

effectiVe in COJmolina poUution. .

The ~ACTIs Technologically Feasible:

TectIT.dagicaJfeasNily enlbodies two c:onc:epIS. The firSt is.the transfer Of

proven technologyfrom cne source to another. Sec:Cnd. it can be a brand new

type of techilOlogywhich has been detnorrstJated ttwugh pilot scale or slip

stream appIieaIions and.is aIfered asBACT wilt warraalties and guaJaJlte es by

the maruacturer. '. .

The baslSfer ofteehacgy from one soun:e to aslOtheris COJ1Im01JPfaCe. For .

exarnpJeo selective catal)tic reduction (SCR) was initiaDy~ated on

- boilers. SCR technology was then barlSfelTed to ClIhet canibustionprocesses

where the flue gas c:crnpcsitioIl was similar. SUCh as gasturbines and IC

engines (ICE). Techaology trallSfe also occurs frClma larger source to a .

.smaItersource. Afterburne:s were iniIiaIIyproven on large spray booths. The

same tec:hnClIClgy can be applied on smaller spray booths. A newtec::hI1Cfogy

can be feasible based on a pilotscale orslip stream testing of the equipment.

Lcw-NOx burnerswere OIigiImBy developed on very sma! c:cmbustion deviCes.

This 1eCI'J1ClIogy successfully scaled up and isnowIJSeC# for largerheaters

and boilers.

For a new1ectI1ClIagyto be c:orlSidered tec:hnClIClgic: feasible based on a pilct

scale demoIlStlaticxt. the piIct system would have to mirror "'real world"

. condiIions and have.been in operation for at least a year. In addition, a

manurac:uerwould be required to have the technology collrmescialy avaitabte.

as weB as Provide a warranty or guarantee with respect to its ooeraIion.

Tec:halClcgitaDy feasible BACT must also be c:cst effective.

..-...,.

The BACTis Cost Effective:

Cost effectiveness is a consideration fortectalClIogically feasible BACT and for

smaIJ business BACT. Prior1D listing in 1he 1995 BACT Guidetines ora

subsequent update. any tedmoIogicaDy feasible BACT and any smaD busineSS

BACT that has not already been achieved in practice based on the current

30 :1.38 AUGUST 1995 -
- CHAPTER 8- HOW ARE BACT AND T-BACT DETERMINED?

BACT Guideines. must pass the cost effectiveness test(S) desClibed in t1e next

sec:ticX'&. ~<ads may also use a cost effeCtiveness analysisto eIocLment that

"specifICc:haIaeteristics a BACT &sting notfeasible fortheir unique

appIica6ai (see Chapter 5 and the nextsection).

COST EFFECTIVENESS METHODOLOGY

There are two sftzmfions where AQMD must cosasider cost effectiveness:

• . R1je 1303(b) requires the AQMO to consider cost effectiveness for

as BACT detemlii iatioIiS for smaD busineSses

• The definition of BACT in Rule 1302(cI) requires air pollution wnbols

:. that are •....tedaaologicalyfeasible and costdedife as CClnpaled

to rneaswes as IisIBd in the AQMP orrules adopted by the Board.•

AppIicaIds may also c:anduct a cost effecIiYeneSS evaluation to support1heir

case for the special permit coslSidelalioiiS cisalSSed in Chapters.

What is Cost EffectIveness?

Cost effectiveness is measured in telms of ccntroI costs (dollars) pertDn of air

emissioItS redilCed. If the cost perten of emissioIlS reduced is lessthan the

maximum r&qUired control costs. then the wntroI method is COIISidered to be

cost effective. .

ihereare two types of cost effectiveness: average and malgi1l81. Average cost

effedi¥eness COIISiders the differela in cost and emissioIlS between 8

proposed BACT and an UlICOI.bolled case. On the otherhand, maJgilal cost

effec6:trenesslooks at the difference in cast and ernissiOiIS betlIIeen the

proposed BACT and a less stringenlleYel of c:ontrol

DiScounted cash Flow Method

The discounted cash flow method (OCF) is used in these 1995

Guidelines. This is also the method used irTthe 1994 Air QualitY ManagemerIt

. Plan. The DCF method catc:utates the peseslt value of the control costs over

the life Of 1he equipment by adding 1he capital cost 1D the present value of-an

annual costs and other periodic costs overthe life ofthe equipment. A real

iJ ItefeSt rate' of four percent. and a 1().year equipment fife is used. The cost

effediYeness is determined by dividing the total presetlt value ofthe c:cntroI '.

costs by the total emissiocl reductions in.tons overthe same 1D-year equipment . .

-The rea! interest rateisttle diffeseliee between martcetinlerest rates and nIation. wbichtypic:ally.renains

COllStaslt atfcur percem.

- 31 A..,.O

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AUGUST 1995
CHAPTER a. HOW ARE BACT AND T·BACT DETERMINED?

_Top Down Cost Method~logy

The-AQMD usesthe tap down appoac:tl for evaluating cost effectiveness. This

means that the best cantra method, with the highest enissicn redtlCtion. is first

analyzed. If it is not cost effective, then the secalld-best control method is

evaIuatBd for cost effectiveness. The process continues unfiI a COlIbol method

is flUId to-be c:cst-effedive.

Average cost effeci4eneSS wi! be used by AQMD staff to set a new BACT level

for an equipment ca~CNythat had no previousBACT requirement. Average

cost effectiveness must also be-used by an appicatlt to support their case for

the special permit cansiderations ciSCtlSsed in ChapterS. except for case

disalSSed in the nextsection. - - ,

AQUD staffwiII8Iaaiyze for boIh maJg6 aaJ and a.:erage cost effectiveuess

:. a _ysis when setting a more sbiagentBACT I8YeI for an equipment categoay

1hat already has a BACT requirement. The neW BACT must be cost effective

based·on boll analyses.

Agam. onlytecheotog':alyfeasible BACT and smaI business BACT are

required be analyzed for cost effediveness.

Cost Effectiveness for M~iflcationof Existing Equipment that

Has EmIssion Controls . - .

As ciscussed in the Spedaf PeJI.ilting COl asideratiatS section in Chapter$, an

aPPticalt is aIowed to demolistlale, for BACT determiJla~tS1hiIt haVe not

been ac:hiewoed in practice and ewe not coratailled in any SIP foramocific:ation.

that the BAc:rr is not cost effective. If the existiIg already has

eulissiai, COIIboIs. then magiIIaI c:ost etIectiYeness will be used. with the

existing level of cardrOI as a bade. This means 1hatthe etilission redtlCtion

used in the cost effectiveness evaluation would be based an the diffetesace

betvJeen the maximum emissions with BACT and the maximum ernissioItS with

the eJCistiJ19 level of emission contrcIs. The c:on1to1 costwiJ be arry new cost of

complying with BACT. If the cost perton exceeds the maximum. Iraghaal, cost

effec:tiIeness criteria, then that BACT level wiB not be required.

Maximum Cost Effectiveness Values

The BACT maxinaum cost effectiveness values have been revised based on the

natural break ofthe 1994AQMP c:ontroI measures and adopted AQMO niles'.

There are two sets of values: one forlarge businesseS and aJlOtherfor smaD

businesSes that is 25 pelt:ent less, The JowervaJuesfor small businesses

accountfor the higher cost of borrowing money for small busineSSeS versus

large businesses.. The vaiues wiD be updated again after the 1997 AQMP is

adcpled. The BACT maximum cost effectiveneSS vatues. shown in Tabte 4, are

based on a DCF analysis with a 4% real interest rate.

.........

32 AUGUST 1995
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CHAPTER 8. MOW ARE BACT AND T.BACT DETERMINED?

. Table4

Maximum Cost Effectiveness Criteria

Pollutant

ROO

NOX

SOx

PM,o

CO

Maximum $ perTon

18,000

17.000

9.000

4.000

350

SmaD Business

Maximum $ perTon

13,500

12.750

6,750

3,000

263

Whenever a maJginaJ cost effediveness analysis is done. the maximum cost

aitetia wiD be three times the amounts in Table 4 aboYe..

There are no cost criteria for Ieacl. BACT ferlead is eiIher BACT for PM,o or

c:ompliallce with Rule 1420. whichever is more stringent.

There are no cost criteria for haIogeJaaled hydrocaJboias. allBllOiJia, hydrcgen

fluoride. hydlogai chlcride orhydrogen suffide. BACT for sources that emit

hatcges aated hydrocarboIlS are based on achieved in padice criteria.

Costs to Include in a Cost Effectiveness AnalysIs

All reasonable. rea! and legitimate costs'A'i1J be included in a cost effectiveness

analysis. Cost effectiveness evaluations consider both capital and opetatiJIg .

costs. Capital cost includes not only the price ofthe the cost for

shippiag, engineering and inStaUation. Operating or annual costs include

expenditures associated with utifities. labor and replacernent costs. Finally, a

credit is given if any ofthe materials or energy created by the process result in a

positive cash fIovt. These cost items are shOwn in Table 5. Methodologies for .

detemIiiIias these values are given in documents prepaed by USEPAthrough

their Office of AirQuaIiy PIai.mag andSta _cis COAOPS Control Cost

Manual 4th Edition. USEPA4SOJ3.90-006 and Supplements).

The cost of land wiD not be cansidered bPcarse 1) add-on control equipment

usually takes up very IitIIe space, 2) add-on control equipment does not usually

require the pu1 dldSe of addiIionaIland. and 3) land is non-depredable and has

value at the end ofthe project. In additioI1. 1he cost of COldJoBing secondary .

emissions and c:ross-media polutanls caused by the primary BACT n!quirement

can be induded in any required cost effectiveness evaluation ofthe primary BACT requirement. .

33 AUGUST 1995