Air Quality Permitting for Emerging Technologies. Jay Chen, P.E. South Coast Air Quality Management District November 4, 2009 Southern California Waste Management Forum. AQMD’s Position about Emerging Technologies.
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Air Quality Permitting for Emerging Technologies Jay Chen, P.E. South Coast Air Quality Management District November 4, 2009 Southern California Waste Management Forum SCAQMD
AQMD’s Position about Emerging Technologies • AQMD rules are neutral – not promoting nor hindering emerging technologies in converting wastes to energy • Same rules that apply to dry cleaners, gas stations or oil refineries also apply to conversion technologies • AQMD Governing Board has not adopted any policy or amended any rule to change that position. SCAQMD
Key Air Quality Permitting Requirements (1 of 3) • Prohibitory Rules • Set certain basic requirements concerning visible emissions (smoke), particulates, and public nuisance, etc. • Source Specific Rules • Set emission and work practice standards based on specific source types, e.g., boilers, engines, and composting, etc. • Federal Regulations • NSPS (40cfr60) and NESHAP (40cfr63): similar to Source Specific Rules but for Major Sources SCAQMD
Key Air Quality Permitting Requirements (2 of 3) • New Source Review (NA-NSR and PSD) • For Criteria Pollutants: (NOx, SOx, VOC, PM10, CO,lead) and Ammonia • Best Available Control Technology: BACT analysis can be resource intensive and time consuming • Dispersion Modeling: To demonstrate compliance with ambient air quality standards • Emission Offsets: Availability and costs of ERCs can be a significant issue(not required for CO, lead and ammonia) • Statewide and Facility-wide Compliance SCAQMD
Key Air Quality Permitting Requirements (3 of 3) • New Source Review for Air Toxics • An unique health-risk based approach to addressing air toxics emission issues • Sets health risk limits: • Max. Individual Cancer Risks: 10 in a million (with T-BACT) or 1 in a million (without T-BACT) • Cancer Burden: 0.5 • Hazard Indices: 1.0 • T-BACT (BACT for Air Toxics) analysis can be resource intensive and time consuming • Cost of T-BACT can be significant SCAQMD
Public Participation • Public Notice Required if • Facility is within 1000 feet of a school (K-12) • Project Emissions or health risks are > Rule 212 thresholds • Federal Title V Permits • Apply to major sources and sources subject to NSPS or NESHAP (e.g., 40cfr60 Subpart Eb applies to thermal conversion technologies) • Enhanced public participation, EPA review, and enforcement, etc. • Public notice required for all initial permits, significant permit revisions, and 5-year permit renewals. SCAQMD
Tips to Successful Air Quality Permitting • Review thoroughly and incorporate all available air pollution control technologies and techniques for both criteria and toxic air pollutants. • Keep facility-wide emissions for each criteria pollutant to < 4 tons/year (or 22 lbs/day) to qualify for emission offsets exemption. • Not over-commit to emission levels that are difficult to demonstrate compliance. • Address CEQA, siting, and public acceptance issues early in the process. SCAQMD