UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

Ventura County Air Pollution Control District Rule 54

Sulfur Compounds

Prepared by: James Shears Reviewed by: Andrew Steckel

Octob er 2014 2



RULE IDENTIFICATION

Agency: Ventura County Air Pollution Control District ( V CAPCD )

SIP Approved Rule: Rule 54

– Sulfur Compounds

Amended

– June 14, 1994

Submitte d

– July 13 , 1994 EPA Appr oved

– April 19, 2000 (6 5 FR 20913 )

Subject of this TSD: R u le 54

– Sulfur Compounds

Amended

– January 14 , 201 4

Submitted

– May 13 , 2014

RULE SUMMARY

– VCAPCD Rule 54 limits emission of s ulfur c ompounds to the atmosphere from f ossil fuel combustion in Ventura. Rule requirements include

both point of discharge limit s and concentration limits at facility property lines for

sulf ur dioxide (SO 2 ) and hydrogen sulfide (H 2 S)

. EPA approved VCAPCD’s 1994

version of Rule 54 into the Stat e Implementation Plan (SIP) in 2000. VCAPCD revised Rule 54 in 2014 largely to add a .075 ppm 1

- hour SO 2 facility property line concentration limit in paragraph B.2.a. consistent with the National Ambient Air Quality Standard (NAAQS) promulgated nationall y in 2010. In 2011, the California Air Resources Board (CARB) asked EPA to designate all areas in

California in attainment with th is 2010 standard. EPA has not yet responded to this request, so VCAPCD is currently designated as being “better than the

nat ional standards” for the 1971 NAAQS for SO 2

.

Other changes in Rule 54 relative to the SIP

- approved rule include:

1. S ection B

. 1. corrects a deficiency in the 1994 rule regarding the

measurement of exhaust SO 2 concentration from various combustion

source s. Since different combustion sources are designed to function with different excess air input, it was unreasonable to set a single excess air requirement covering all sources in the 1994 rule. Th e amended rule

correc t s the measured SO 2 concentrations to the appropriate exhaust gas oxygen content according to the type of combustion source. Exhaust oxygen content corrections would apply to stationary internal combustion engines, water heaters, boilers, steam generators and other combustion operations

.

2. Section B.2. add s various options for demonstrating compliance with th e new .075 ppm 1

- hour standard by modeling 3

- year air monitoring data

. 3



3. Section C.2.f. clarifies that a 6

- year averaging period applies to the flare gas volume allowance calculations.

4. Other minor formatting and editing revisions to aid clarity.

EVALUATION CRITERIA

- The following criteria were used to evaluate the

submitted rule.

1. E nforceability

- T he Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Dev iations, EPA, May 25, 1988) and the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate compliance with the CAA § 110(a)(2)(A) requirement for enforceability.

2

. Stringency

– As discussed above, Ventura County is designated as being

“better than the national standards” for the 1971 NAAQS for SO 2

. The county has not been designated yet for the 2010 primary SO 2 NAAQS. As a result, this rule does not need to compl y with the specific sulfur nonattainment requirements in CAA §191, and only needs to comply with the general SIP requirements in CAA §110 that pertain to SO 2 NAAQS. Therefore, there is no specific level of stringency, e.g., reasonably available

control te chnology, required of this rule. 40 CFR 50.17 ( National Primary Ambient Air Quality Standards for Sulfur Oxides (Sulfur Dioxide), June 22,

2010 ) and SCAQMD Method 100.1 ( Source Test Protocol for Determining Oxygen Corrected Pollutant Concentrations from C ombustion Sources with High Stack Oxygen Content Based on Carbon Dioxide Emissions, March 3, 2011) were used to help evaluate compliance with CAA § 110

.

3. SIP Relaxation

– Where previous versions of rules have been SIP approved, new submittals must comp ly with CAA § 110(l) and § 193 regarding SIP relaxation.

EPA EVALUATION

– The submitted V CAPCD Rule 54 is equivalent in stringen cy

to the approved SIP , while the enforceability is enhanced

. If ambient air monitoring

shows concentrations above the current l imits, the sources suspected of contributing to the exceedance would be required to demonstrate compliance wi th

the .075 ppm ground level standard based on 3

- year monitoring data as indicated

in the 2010 Federal standard

. This requirement enhances complia nce enforceability. The rule enforceability is also strengthened by specifying the appropriate exhaust gas oxygen content be corrected to the SO 2 values obtained for the various sources of combustion operation (stationary internal combustio n engines, water heaters, boilers, etc.).

1. The rule requirements and applicability are clear, and recordkeeping, reporting and other provisions sufficient ly ensure that affected sources and 4

 regulators can evaluate and determine compliance with Rule 54

consistentl y.

2. The submitted rule is brought up to date with, and thus, is as stringent as

the 2010 Federal SO 2 standard, 40 CFR 50.17, and the exhaust oxygen

correct ion factors for combustion SO 2 monitoring are as stringent as other

air d istrict s’ method s , s uch as South Coast Air Quality Management District

Method 100.1

.

3. W e propose to determine that our approval of the submittal does comply

with CAA § 110(l) and § 193 because (1) the proposed SIP revision would

not interfere with the on

- going process for ensuring that requirements for RFP and attainment of the NAAQS are met, and (2) the overall requirements in the submitted rule are more stringent than the existing SIP

approved control requirements that they would replace.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

- The following revisions are not currently the basis for rule disapproval, but are

recommended for the next time the rule is amended.

1. In the Exemptions Section C.1.c., we recommend the phrase, “but not

limited to” be removed fr om the sentence such that it would be as follows: “The flaring event results from operational problems including emergency blowdowns, process upsets, power outages, and equipment breakdown.”

EPA ACTION

– Th e submitted Rule 54 improves the SIP and com plies with all relevant CAA requirements

. Therefore, EPA staff recommends a full approval of

Rule 54 pursuant to CAA § 110(k)(3)

.

REFERENCES

-

1. VCAPCD Rule 54

, Sulfur Compounds , as submitted to EPA on May 13

, 2014.

2. V CAPCD Rule 54

, Sulfur Compounds

, as approved into the SIP on April

19

, 2000.

3

. EPA, 40 CFR 50.17, National Primary Ambient Air Quality Standards for Sulfur Oxides (Sulfur Dioxide), June 22, 2010.

4

. South Coast Air Quality Management District (SCAQMD), Method 100.1

, Source Test Protocol for Determining Oxygen Corrected Pollutant Concentrations from Combustion Sources with High Stack Oxygen Content Based on Carbon Dioxide Emissions, March 3, 2011.

5

. The Little Bluebook, EPA Region 9, A ugust 21, 2001.

6. The Bluebook, EPA, M ay 25, 1988

.