# STAFF REPORT

Rule 3.21

Industrial
, Institutional, and Commercial Boilers, Steam Generators, and

Process Heaters

Date of Release: March 14, 2006

Schedule of Meetings Rule 3.21Workshop: April 20, 2006 Public Hearing: June 5 , 2006

### STAFF REPORT

Industrial

, Institutional and Commercial Boilers, Steam Generators, and Process Heaters



### Date of Release: March 14 , 2006 Scheduled Date of FRAQMD Adoption: June 5, 2006 Feather River AQMD, 938 14 th 

### Street, Marysville , California 959 01

Contents Page Executive Summary

................................ ................................ ................................ . 1

1. Purpose

................................ ................................ ................................ ............... 1

2. Background

................................ ................................ ................................ ........ 1

3. Legal Mandate

................................ ................................ ................................ .... 2

4. Proposed Rule Requirement s

................................ ................................ ............. 2

5. Socioeconomic Impact

................................ ................................ ....................... 3

6. Effectiveness of Control Measure s

................................ ................................ .... 3

7. Estimated Cost Impact

................................ ................................ ....................... 5

8. Environmental Review and Compliance

................................ ........................... 6

9. Required Finding s

................................ ................................ .............................. 7

...........................................

Attachment A . Rule Analysis

Attachment B . Public Notice

Attachment C . Comments and Responses- 1

- 

### STAFF REPORT Executive Summary

Feather River Air Quality Management District (District) is a Bi

- County d istrict that admi nister s local, state and federal air quality management program s for Yuba and Sutter Counties. Under the provisions of the California Clean Air Act (CCAA) of 1988 , Yuba County and the northern portion of Sutter County have been designated as “moderate” non

- attainment areas for failing to meet the state ozone standard. The southern portion of Sutter County is designated as “serious” n on

- attainment for failing to meet the
state ozone standard.

Ozone is formed when volatile organic compounds (VOC) react wit h nitrogen oxides (NOx) in the presence of sunlight, and is one component of “smog”. Ozone is a strong irritant that attacks the respiratory system, leading to damage of lung tissues. Exposure to ozone aggravates asthma, bronchitis and other respiratory diseases, as well as cardiovascular diseases. Re ductions in the NOx and VOC is necessary to attain and maintain the state ambient air quality standard for ozone.

The 2003 Air Quality Attainment Plan requires the Northern Sacramento Valley Air Basin (NSV AB) to adopt rules and regulations deemed necessary to attain and maintain the state ambient air quality standard for criteria pollutants at the earliest practical date

. Rule 3.21, Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters has been developed to fulfill t he

com mitment made by the District and to help attain the state ambient air quality standards for ozone

.



### 1.0 Purpose :

The purpose of Rule 3.21 is to limit NOx emissions from boilers, steam generators, and pro cess heaters with rated heat inputs greater than or equal to one (1) million Btu per hour (MMBtu/hr).



### 2.0 Background :

The main function of boilers, steam generators, and process heaters are to transfer heat to water, which will eventually form stea m. Each unit creates h eat through combustion, which is an exothermic reaction between a fuel (liquid, gaseous, or solid) and air. Some final product s of combustion include oxides of nitrogen, carbon monoxide, vol atile organic compound s (VOC) and fine p ar ticulate m atter (PM

- 10 ) a nd are discharged into the atmosphere. Oxides of nitrogen and volatile organic compounds are recognized as precursors to ground

- level ozone formation , and r eductions in NOx and VOC are necessary to attain and

maintain the state amb ient air quality standard for ozone.

Rule 3.21, Industrial, Institutional and Commercial Boilers, Steam Generators, and Process Heater, regulates the NOx emissions of any unit defined in this rule. This rule applies to all boilers, steam generators, and process heaters used in industrial, institutional, and commercial operations that operate
within the boundaries of the Yuba and Sutter Counties

.

Staff proposed to adopt Rule 3.21 to achieve reasonable emission reduction s from boilers, steam
generators, and process heater s to help attain the state ambient a ir quality standard for ozone. The proposed rule will also be consistent among the NSVAB Districts, where emission standards are based
on the CARB’s Determination for Reasonable Available Control Tech nology (RACT) and Best- 2

-

Available Retrofit Control Technology (BARCT) for Industrial, Institutional and Commercial Boilers, Steam Generators, and Process Heaters.



### 3.0 Legal Mandate :

State Mandates: Yuba County and the northern area of Sutter County is designated as “moderate” non

attainment for the state ozone standard. The southern area of Sutter County, also know as Sacramento

Federal Non

- attainment Area (SFNA)

, is designated “serious” non

- attainment for the state ozone

standard. The California Clean Air Act (CCAA) requires areas designated as non

- attainment for ozone to adopt control measures required in Section 40918 & 40919 of California Health and Safety Code (CH&S)

. CH&S Code, Section 40918 requires the District to adopt a control measure that wi ll use reasonable available control technology (RACT) for all existing stationary sources in the “moderate”

non

- attainment area. CH&S Code, Section 40919 requires the District to adopt a control measure that

will use Best Available Retrofit Control Techno logy for all existing stationary source in the “serious”

non

- attainment area. The CCAA also requires the District to develop a plan to achieve California’s ambient air quality standard by the earliest practical date ( C H&S Code Section 40913 ).

All Feasibl e Measures Requirements: California Health and Safety Code Section 40914 requires the District’s plan to demonstrate that the plan includes “every feasible measure" to co ntrol emissions. Accordingly, the District must adopt an effective control measures t o limit NOx emissions from boilers, steam generators and process heaters. The District has evaluated the standards in the rule against similar requirements recently adopted by other districts. The District has determined that the standards a re feasible r equirements and have been achieved in practice.



### 4 .0 Proposed Rule Requirements:

4.1 Standard s

Rule 3.21 applies to all boilers, steam generators, process heaters used in industrial, institutional,

and commercial operations that operate with in the bound aries of the District. One year from the rule’s date of adoption, all boilers, steam generators and process heater shall meet the following

standards:

4 .1

. a Units with a rated heat input greater than or e qual to 5 million Btu per hour and

annual heat i nputs greater than or equal to 90,000 therms shall demonstrate compliance with Reasonable Available Control Technology (RACT) or Best Available Retrofit Control Technology (BARCT) emission limitations according to area of designation and fuel type , as show n in Table 1, Emission Limits

. The proposed RACT/BARCT emission limits are required by the CH&S, Section 40918

and 40919. All new units must comply with District Rule 10.1 , New Source Review.

4. 1.b Units rated greater than or equal to 5 MMBtu/hr with a heat input of less than 90,000 therms and units rated less than 5 MMBtu/hr but greater than or equal to 1 MMBtu/hr must provide to the District a list of all units operating within the District boundaries and select an option from either operating the uni t at 3% oxygen concentration, tuning units with satisfactory results or meeting specific emission

limits.- 3

- Table 1. Emission Limits

Type of Fuel Used

Only Gaseous Fuel Firing Units Gaseous & Non

- Gaseous

Fuel Co

- Firing Firing

Units Non

- Gaseous Firing Un its

North

Portion of
FRAQMD

Emission

Limits 0.08 lbs/MMBTU

or 70 ppmv *Heat Input Weighted

Average Fuel Limits 0.15 lbs/MMBTU

or 115 ppmv

SFNA

Portion of
FRAQMD

Emission

Limits 0.036 lbs/MMBTU

or 30 ppmv *Heat Input Weighted

Average Fuel Limits 0.052 lbs /MMBTU

or 40 ppmv

4.2 Applicability and Exemptions

Rule 3.21 applies to boilers , steam generators, and process heaters having heat input capacities greater than or equal t o 1 million Btu per hour (MMBtu /hr), used in all industrial, institutional,

and commercial operations : This rule shall not apply to the following:

4.2 .a Any unit with a rated heat input capacity less than 1 million Btu per hour.

4.2.b Any unit that does not meet the definition of a boiler, steam generator or process

heater

Rule 3.21 exempts the following units:

4.2.c Any unit with rated heat input greater than or equal to 1 MMBtu/hr but less than 5

MMBtu/hr willing to accept a permit condition that restricts operation to less than 90,000 therms per year of annual heat input.



### 5 .0 Socioeconomic Impact :

Yuba and Sutter counties have a combined population less than 500,000 persons. The Required Assessment in subsection (d) of the Ca lifornia Health and Safety Code (Section 40728.5) states

, “T his section does not apply to any distr ict with a population of less than 500,000 persons ”

. A s ocioeconomic impact analysis is not required.



### 6 .0 Effectiveness of Control Measures:

The reduction of NOx emissions from process equipment, such as boilers and heaters, can be accomplished through pre and/or post combustion modifications. The application of a specific technique will depend on the type of boiler, the characteristic of its primary fuel, and method of firing. Some- 4

-

controls have seen limited application, whereas certain boilers have l ittle or no flexibility for modification of combustion conditions because of method of firing, size, or operating practices.

The formation of NOx is governed primarily by the chemically

- bound nitrogen content of the fuel

, the

oxygen concentration of the flame, the temperature of the flame, and the length of time for which the combustion gases are held at the flame temperature. The NOx emissions may then be emitted to the atmosphere along with other products of combustion in the flue gas. NOx emissions can be reduced either by limiting NOx formation during fuel combustion using control measures such as Low NOx

Burner s or Flue Gas Recirculation , or by reducing NOx emissions from the exhaust flue gas by retrofitting the unit with Selective Catalytic Reduct ion or Selective Non

- Catalytic Reduction. The

control measures are described below.

1. Low NOx Burners (LNB)

Low NOx B urners utilize one or a combination of control technologies (i.e., low exc ess air, fuel and/or air staged combustion , combustion pro duct recirculation ) in the design of the burner to

reduce NOx emissions. L ow excess air minimizes the amount of excess oxygen for combustion and thus reducing the number of oxygen atoms available to react with nitrogen to form NOx. Staged combustion can a chieve lower NOx emissions by dividing the combustion process into a number of stage s in which air/fuel ratio varies to reduce NOx formation.

There are two types of staged combustion: staged air combustion and staged fuel combustion. Staged air combust ion involves controlling the formation of NOx by introducing in stages the total amount of air required for combustion. A portion of the air is used to form a fuel

- rich primary combustion zone in which all of the fuel is partially burned. Some heat from this incomplete combustion is transferred to the boiler tubes before the completion of combustion. Combustion is completed with the injection of the remainder of the combustion air in a secondary burnout zone downstream of the fuel

- rich primary zone. Bec ause some heat is transferred prior to the completion of combustion, temperatures are lower with staged air

combustion than with c onventional combustion. Lower temperature reduces NOx formation.

Stage d fuel combustion involves controlling NOx formati on by introducing in stages the amount of fuel required for combustion. In the primary combustion zone the burners are operated or fired with only a portion of the fuel; however, all of the required combustion air is added.

Because there is a hi gh level of excess air, the combustion temperature is lowered and the NOx formation reduced. In the secondary combustion zone, the remainder of the fuel is injected at high pressure and velocity into the combustion chamber which further reduce s the combustion
temp erature and the partial pressure of oxygen in the secondary combustion zone. This situation

retards the formation for NO x because of the decreased tempera ture and availability of oxyg en, while producing desirable results.

Low NOx Burners reduce temperat ure and the formation of NOx. Low NOx Burners are applicable to most gas

- fired and oil

- fired units. The control effectiveness range s from 10 to 55 percent for gas

- fired units and low

- nitrogen oil units.

2. Flue Gas Recirculation (FGR)- 5

-

Flue G as R ecircula tion for NOx control consist s of extracting a portion of the flue gas from the economizer outlet and returning it to the furnace, admitting the flue gas through the furnace windbox. Flue gas recirculation lowers the bulk furnace gas temperature and reduce s oxygen concentration in the combustion zone.

The retrofit installation of FGR consists of adding a fan, ductwork, dampers, and controls as well as possibly having to increase existing fan horsepower due to increased draft loss.

Flue Gas Recirculation is an effective control technique for both gas

- fired and distillate oil

- fired units. The control effectiveness of the FGR ranges from 60 to 70 percent for gas

- fired unit and

low

- nitrogen oil units.

3. Selective Non

- Catalytic Reduction (SNCR)

S elective No n

- catalytic Reduction is a post

- combustion control measure or after

- treatment device. SNCR reduces NOx through injecting ammonia or urea into a specific temperature zone of the flue gas. The injected ammonia or urea reacts with nitrogen oxides to produce nitrogen and
water vapor. Because the SNCR is highly dependent on the temperature , ranges between 1400 o F

to 2000 o F, a mmonia or urea in injected into the flue gas at a point in the system where the temperature is within the required range. If the temperatu re is be low 1600 o F, chemical enhancers such as hydrogen may be required to help the reaction. If the temperature is above 2000 o F, the ammonia or urea tends to react with any available oxygen to form NO. The ammonia injection point is usually located ups tream of the convection section as flue gas leaves the furnace.

With SNCR, it is very important to control the excess un

- reacted ammonia. The excess ammonia could react with other combustion by

- product and form ammonia salts. Un

- reacted ammonia may als o pass through the system and into the atmosphere. The ammonia salts and un

- reacted ammonia are sometimes visible in the plume from the stack. This is known as an ammonia slip.

A nd d ue its environmental impact, it is restricted by this rule to not emit ammonia emissions in excess of 20 ppmv at dry stack conditions adjusted to 3% oxygen into the atmosphere from any

control device. T he control effectiveness of the SNCR ranges up to 90 percent.

4. Selective Catalytic Reduction (SCR)

A Selective Catalytic Red uction unit is a post

- combus tion control measure and is operated similar to a SNCR. SCR injects ammonia to reduce NOx. Instead of injection in specific temperature zone, SCR inject ammonia into the flue gas over a catalyst bed . The catalyst bed

allows th e reaction to reduce NOx at a temperature range from 500 o F to 850 o F

. The injected

ammonia creates reducing atmosphere, where the rich ammonia environment strips the oxygen from the nitric oxide leaving nitrogen gas

.

Similar to SNCR, the ammonia slip is regulated by this rule to not emit ammonia emissions in excess of 20 ppmv at dry stack conditions adjusted to 3% oxygen into the atmosphere from any

control device. The control effectiveness of the SCR unit ranges up to 90 percent.- 6

-



### 7 .0 Estimated Cost Impact:

The proposed Rule 3.21 will require all units subject to this rule, to install additional equipment such as operational tracking devices and/ or emission control devices. The proposed rule will also require compliance testing to show compliance wi th the required emission standards or permit conditions. A summary of the estimated cost for equipment and te sting is shown below in Table 2

.

After one year of the date of adoption of the proposed rule, all units subject to this rule or to the usage

exe mption of this rule, shall install either a non

- resettable hour meter or a fuel flow totalizing meter to track the annual usage of each unit. The District anticipates most owners or operators will chose to

install a non

- resetta ble hour meter, which will c ost about $400.

For each unit to be in compliance with rule 3.21

, the facility must show that the unit operates at its optimal performance and/or meet the emission s requirement . For units less than 5 MMBtu/hr but greater

than 1 MMBtu and units equal to or greater than 5 MMBtu/hr but has a heat input less than 90,000

therms , the facil ity must operate at its optimal design where it is required to be tuned, set up an o xygen trim system or operate at 3% oxygen level of concentration. Th e District expects mo st facilities to tune
the unit (s) to meet the requirements in the proposed rule. Tune

- up s are about $600 for each unit by a qualified technician. For unit s rated greater than 5 MMBtu /hr and an annual heat input greater than or equal to 90,000 therms

, the facilities are expected to meet emission requirements for its designated area. Most units can achieve the emission standards by retrofitting the unit with a Low NOx Burner and/or a Flue Gas Recirculation. The estimated cost to retrofit a unit ranges fro m $65,000 to $442,000, which depends greatly on th e type of retrofit and the size of the boiler.

Furthermore, to show compliance on a continual basis, the proposed rule requires the facility to demonstrate in accordance with the compliance schedule and depending on the maximum unit capacity,

each unit is either properly tuned or source tested. Tune

- ups are required annually , and source tests are required once every two years or every 8,760 hours of operation, whichever occurs more frequently. A

source test, not in cluding District observation and review, is about $1,500 to $2,000 per source test.

Table 2

. Summary of Estimated Cost Equipment Cost (dollars)

Non

- resettable Hour Meter

Fuel Flow Meter Oxygen Trim System Equipment Retrofit

Low

- N O x Burner

Flue Gas Recirculation Selective Catalytic Reduction

S elective Non

- Catalytic Re d u ction Replace Unit $ 400 $ 1,500 $ 15,000 to $ 22,000

$ 65,000 to $442,000

$135,000 to $750,000

Testing

Annual Tune

- up Source T est $ 600 per boiler $1,500 to $2,000 per test- 7

-



### 8 .0 Environmental Review and Compliance:

The adoption of rule 3.21 is categorically exempt from the California Environmental Quality Act (CEQA) under Sections 15307 and 15308 of the State CEQA Guide lines and no exceptions to these exemptions apply. This exemption is allowed when the rule will help improve air quality in Yuba and Sutter County . California Public Resources Code (Section 21159) requires an environmental analysis of the reasonably forese eable methods of compliance. The District has concluded that no reasonably foreseeable adverse environmental impacts will be caused by adoption of the proposed rule.



### 9 .0 Required Findings:

The California Health and Safety Code, Division 26, Air Resource s, requires local Districts to comply with a rule adoption protocol as set forth in Section 40727 of the Code. This section has been revised through legislative mandate to contain 6 findings that the District must make when developing, amending, or repeal ing a rule. These findings and their definitions are listed in the following table.



### Table 3 . Required Findings

FINDING DEFINITION REFERENCE Authority A district shall adopt rules and regulations

and do such acts as may be necessary or

proper to execute the powers and duties granted to, and imposed upon, the district by this division and other statutory provisions California Health and Safety Code, Sections 40000, 40001, and 40702 are provisions of law that provide air districts with the authority to ado pt these proposed rules.

Necessity The District has demonstrated that a need

for the rule, or for rule amendment or repeal. It is necessary for districts to adopt these amendments to comply with state law and to ensure consistency with neighboring air

dis tricts. Clarity The rule is written or displayed so that its

meaning can easily be understood by the persons directly affected by it There is no indication, at this time, that the proposed rules are written in such a manner that it can not be easily under stood by persons affected by the rule. Consistency This rule is in harmony with, and not in

conflict with or contradictory to, existing statutes, court decisions, or State or federal regulations. These rules are consistent with applicable statutory requir ements.

Non

Duplication The rule does not impose the same

requirements as an existing State or federal regulation, unless the District finds that the requirements are necessary and proper to execute the powers and duties granted to, and imposed upon, the district The proposed rule does not impose requirements that duplicate existing laws or regulations.

Reference Any statute, court decision, or other

provision of law that the district implements, interprets, or makes specific by adopting, amending, or rep ealing a regulation. The proposed rule has been developed to meet the requirements of the 2003 State Implementation Plan.

# ATTACHMENT A

Rule Analysis

# ATTACHMENT B

Public Notice

# ATTACHMENT C

Comments and Responses