SCAQMD

Air Quality Permitting for Emerging Technologies

Jay Chen, P.E.South Coast Air Quality Management District

November 4, 2009Southern 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.