BEST AVAILABLE CONTROL TECHNOLOGY (BACT) REQUIREMENTS FOR BURNERS IN COTTON GINS January, 1992 SJVUAPCD identifies driers as source subject to NOx control requirements. Draft rules will be set forth in 1995. April, 1993 SJVUAPCD, Southern Region requires gin to install burners that meet 60 ppm NOx.  Reference was milk drier. The Association responds with letter outlining concerns with District's premature application of this technology, since it has not been achieved in practice. Association states that it will begin testing of existing burners. There was no response from District. 1993, 1994, 1995 Several projects go through SJVUAPCD, which increase drying capacity or driers, District identifies use of natural gas or propane as BACT for cotton gin driers. May, 1995 SJVUAPCD - Southern Region requires gin to install Eclipse burner that will achieve 20 ppm NOx,  at a cost of $5,000 per Btu above cost for conventional burner. This burner has not been tested in a cotton gin. Gin is forced to accept strict fuel use limitation (less than currently allowed) in order to demonstrate that burner is not cost effective, and thereby meeting BACT requirements. SJVUAPCD - Central Region requires gin to follow same guidelines. Gin accepts fuel use limitation to opt of installing new burners. July, 1995 SJVUAPCD - Southern Region requires gin to install lo-NOx burners or accept fuel use limitations. The Association sends to SJVUAPCD APCO David Crow, outlining concerns with the District policy of requiring BACT that has not been proven. The Association meets with District which results in no resolution. August, 1995 The Association expresses opposition at Governing Board Meeting. Association and its members testify to Board that the burners have never been tested in a cotton gin, and are not economically feasible. Association offers to test burners in USDA laboratory.  September, 1995 SJVUAPCD offers compromise that gives three gins conditions on ATC to remove fuel use limitation and not require meters if burners do not test out. The District agrees to testing program at USDA Ginning Laboratory. November, 1995 CCGA Environmental Committee convenes burner subcommittee to handle development of a testing program for testing four burners: two conventional burners, and two "lo-NOx" burners. March, 1996 Actual testing program will begin for the four burners to be tested. Emissions, performance characteristics, and cost information will be collected to complete a technologic and economic feasibility study on the burners.

KEY ISSUES Technological Feasibility SJVUAPCD claims burners are technologically feasible. They have never been tested in a cotton gin. Gins Subject to Fuel Use Limitations Three gins are being limited on fuel use in order to comply with SJVUAPCD's BACT Requirements. They must not be subject to either the fuel use limitations or the new technology since it was not proven or verified at the time of application submittal. BACT Determination and Cost Effectiveness If the testing of the new burners does not meet the manufacturers claims or the emission reductions are not substantial enough for the burner to be cost effective what happens to the existing three burners. Manufacturer will not pay for installation, removal or testing of burners. Rule 2201 - Section3.8 BACT is the most stringent emission limitation or control technique of the following: 3.81 Has been achieved in practice for such emission unit and class of source; or 3.82 Is contained in any State Implementation Plan approved by the Environmental Protection Agency for such emissions unit category or class of source. A specific limitation or control technique shall not apply if the owner or operator of the proposed emissions unit demonstrates to the satisfaction of the APCO that such limitation or control technique is not presently achievable; or 3.8.3  Is any other emission or control technique, including process and equipment changes of basic or control equipment, found by the APCO to be technologically feasible for such class or category of sources or for a specific source, and cost effective as determined by the APCD.