SCAQMD Sunsets RECLAIM Program

Landing Rules: Proposed Rule 1100, Proposed Amended Rules 1146, 1146.1 and 1146.2 (Boilers, Steam Generators, Process Heaters and Water Heaters)

Background

Control Measure CMB-05 of SCAQMD’s 2016 Air Quality Management Plan (AQMP) and California State Assembly Bill 617 require SCAQMD achieve an additional reduction of 5 tons per day NOx on an expedited schedule. To meet this mandate, SCAQMD is transitioning out of the RECLAIM program and back to a command and control regulatory structure. The transition will require industry to promptly implement Best Available Retrofit Control Technology (BARCT) in order to achieve the 5 ton per day reduction.

What's New?

Proposed Rule 1100 and proposed amended Rules 1146, 1146.1 and 1146.2 require boilers, steam generators, process heaters and water heaters previously included in the RECLAIM program to lower NOx emissions to BARCT NOx concentration limits. Amendments to these rules are expected to be adopted as early as early as 2nd Quarter 2018. A summary of the proposed BARCT limits is included below:

Rule

Summary of NOx Emission Limits

Rule 1146
  • 5 ppm for natural gas units ≥ 75 MMBtu/hr;
  • 9 ppm for units burning gaseous fuels ≥ 5 and < 75 MMBtu/hr;
  • 12 ppm for atmospheric units;
  • 15 ppm for digester gas;
  • 25 ppm for landfill gas
Rule 1146.1
  • 9 ppm for natural gas units;
  • 12 ppm for atmospheric units;
  • 15 ppm for digester gas;
  • 25 ppm for landfill gas
Rule 1146.2
  • Manufacturer limit of 20 ppm;
  • End-user limit of 30 ppm

 

What do I need to do?

SCAQMD’s proposed compliance schedule is summarized as follows:

  • By July 1, 2018, submit to SCAQMD an inventory of Rule 1146.2 units. No retrofit provisions are currently proposed.
  • By August 1, 2018, submit complete permit applications for all units not currently meeting Rule 1146 or 1146.1 NOx concentration limits.
  • By January 1, 2021, meet NOx concentration limits for 75% of the total heat input of Rule 1146 and 1146.1 units.
  • By January 1, 2022, meet NOx concentration limits for 100% of the total heat input of Rule 1146 and 1146.1 units.

The August 1, 2018 deadline requires the submittal of “complete permit applications.” Complete infers that the application package contains all engineering evaluation, design and drawings for the selected modification/retrofit, vendor guarantees for NOx emissions performance, emissions calculations for all criteria pollutants affected by the modification/retrofit, a regulatory compliance analysis, and modeling for criteria and toxic pollutants if an emissions increases to a pollutant occurs [e.g., additional PM emitted by the SCR (if installed), or the modification results in additional combustion capacity].

Further Information

Further information regarding the RECLAIM Sunset can be found on SCAQMD’s website: www.aqmd.gov/home/rules-compliance/rules/proposed-rules

Our skilled SCAQMD Certified Permitting Professionals (CPPs) are ready to help you meet these new requirements, including equipment optimization, analyzing potential retrofit and control options, interfacing with the vendor and SCAQMD, scheduling, regulatory compliance analysis and preparation and submittal of SCAQMD permit applications. Please contact Mike Waller, P.E. (mwaller@algcorp.com; 805-764-6003) for details.

Our Qualification and Experience

For over 20 years ALG has provided expert air quality and environmental consulting services to a wide range of industries including refineries, bulk loading terminals, chemical plants, aerospace, mineral processing plants, steel manufacturers, power generators, and paper recyclers. ALG is recognized as a leader in the environmental consulting industry. We have a deep understanding SCAQMD regulations, including the RECLAIM program which, combined with our extensive permitting expertise of complex source operations, allows ALG to provide practical, innovative, cost-effective and resourceful technical consulting services. Further information relating to ALG’s expertise can be found in our SOQ as well at www.algcorp.com