Santa Barbara County Air Pollution Control District

STAFF REPORT

– June 19, 2008



### REVISIONS TO

RULE 102

. DEFINITIONS

REGULATION II. PERMITS

RULE 333. CONTROL OF EMISSIONS FROM RECIPROCATING

INTE RNAL COMBUSTION ENGINES

BACKGROUND

The Santa Barbara County Air Poll ution Control District (APCD) proposes modifications to Rule 201 and Rule 202, which implement the APCD permitting

process , and Rule 333, which specifies the requirements for engines

.

The APCD first required Permits to Operate for piston

- type internal combustion engines in 1988. In 1991, the APCD adopted Rule 333 to control emissions from reciprocating internal combustion engines. Other than a minor change to a rule

reference in 1997 , the APCD has not modified Rule 333 from the originally adopted rule. In 1995, the

EPA suggested changes to the engine permitting exemptions in Rule 202 and changes to Rule 333 to make the rules acceptable for inclusion into the State Implementation Plan.

In 1997, the APCD adopted Rule 201 and Rule 202

revisions as part of major revisions to Regulation II (Permits) . That rulemaking effort included moving the New Source Review provisions out of Regulation II into a new Regulation VIII (New Source Review).

The 1997 Regulation II changes modified the permitting requirements for engines. Those changes included revising the drill rig exemption, adding an exemption for engines registered in the statewide registration program, and exempting other

mis cellaneous engin es.

The APCD did not modify Rule 333 as part of the 1997 Regulation II changes. Thus, staff did not address EPA suggestions at that time. The current rulemaking effort includes changes to engine requirements in Rule 202 and Rule 333 to address the

EPA issues.

Aside from the March 2005 Rule 202 revision to expand permit applicability for diesel engines for the implementation of the state Airborne Toxic Control Measure, the APCD has not modified Rule 202 since

1997.



### PROPOSED REVISIO N S

This rulemaking effort addresses all ARB

- identified suggestions and all EPA

- identified deficiencies regarding the permitting and control of internal combustion engines. These concerns, summarized in Appendix A, need to be addressed in order for the engine permitting requirements of Rule 202 and the Rule 333 engine requirements to be considered for inclusion in the State Implementation Plan.

During the rule development process, the APCD received requests to modify and add Rule 202 permit exemptions t hat are unrelated to the internal combustion engine (ICE) exemptions. The APCD considered each request and, where suitable, included the new or amended exemption provision

.

In the amended Rule 333 provisions

, oxides of nitrogen (NOx), carbon monoxide (CO ), and reactive organic compound (ROC) limits for ICEs are revised

to meet a “ Reasonab ly Available Control Technology” (RACT) level of control. The EPA requires that rules have, at a minimum, a RACT levelSTAFF REPORT

- Regulation II/Rule 333 Page 2

June 19, 2008

Santa Barbara County APCD of control for them to be included in the State

Im plementation Plan.

The changes to the emission limits for spark ignitio n internal combustion engines are consistent with the

RACT standards in the CARB Reasonably Available Control Technology and Best Available Retrofit Control Technology D etermination. [1] The changes to the emission limits for compression ignition engines are based on other air district‟s RACT

standards. [2, 3]

These rule changes demonstrate that the District's

Clean Air P lan to attain the California ambient ozone standard provides for expeditious implementation of

“ every feasible measure ” to reduce ozone precursor emissions

.

The APCD expects the proposed revision s to Rule s 202 and 333 pertaining to ICEs to result in 6.5 tons

per year of NOx emission reduction and 0.03 ton per

year o f ROC emission increase . The cost

effectiveness of the R ule 333 revision is estimated to

be between $1,550 and $11,532 per ton of NOx

reduced.

Key provisions of proposed amended Rule 333 are illustrated in flowchart format in Appendix M.

Sources that M ay be Affected by the Changes to Rule 202.F and Rule 333

The sources using an engine that may be affected by this rulemaking effort include, but are not limited to, sources performing: o il and gas exploration, production, processing and petroleum produc t marketing; mineral processing; construction; and agricultural operations subject to the APCD Part 70 Operating Permit Program. Emergency standby engine requirements will not be affected by the proposed rule revisions.

Appendix B summarizes the known co mpanies with permit

- exempt engines that will become subject to permitting requirements due to the Rule 202.F revisions. Appendix C lists the known sources operating engines currently subject to or that will

become subject to the Rule 333 emission limits u nder

the proposed amended rules.

Rule 102, Definitions

The APCD proposes to add and modify several definitions that are used in various parts of the

rulebook. Appendix D contains an annotated proposed amended Rule 102 with notes on the origin and nec essity for

each of the new and revised definitions.

R ule 201, Permits Required

The Rule 201.D.2 provisions on exempting or permitting pile drivers, pipe

- laying barges, and derrick barges is relocated into Rule 202, Section F.7. The Rule 202.F.7 provisio n is expanded to include

cable

- laying and pipe

- laying vessels.

The Section D.1 alphanumerical designation is reduced to Section D (due to the relocation of Section D.2). The APCD is adding text to Rule 201, Section D, indicating equipment use requires an Authority to

Construct.

Appendix E contains an annotated proposed amended

Rule 202 with notes on the new and revised provisions.

R ule 202, Exemptions to Rule 201

The APCD proposes changes to the rule to 1) delete the construction engine and well dr illing equipment exemption, 2) add five new exemptions, and 3) modify several existing exemptions.

Appendix F contains an annotated proposed amended

Rule 202 with notes on the new and revised provisions.

Rule 333, Control of Emissions from Reciprocat ing Internal Combustion Engines

Changes to Rule 333 1) address ARB and EPA concerns and 2) revise the emission limits to be

consistent with the RACT standards.

Appendix G provides an annotated proposed amended Rule 333 with notes on each proposed change. The following table provides a summary of the Rule 333 NOx emission limit changes.STAFF REPORT

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June 19, 2008

Santa Barbara County APCD 

### SUMMARIZED OXIDES OF NITROGEN EMISSION LIMIT CHANGES

RESULTING FROM THE PROPOSED AMENDED RULE 333

Engine Type Rule 333 NOx

Limits Effective December 3, 1991 Rule 333 NO x

Limits Effective [ date of revised rule adoption ] Effect of Rule 333

Change

%

Control ppmv

(at 15% O2) %

Control ppmv

(at 15% O2)

Rich

- Burn Noncyclically

Loaded Spark Ignition Engines

– Category 1 Engines 90 50 90 50 No change

Lean

- Burn Spark Igniti on Engines in the 50 to less than 100 brake horsepower (bhp) Range

– Category 2 Engines 80 125

- 200 Increased emission

limit

Lean

- Burn Spark Ignition Engines Rated 100 bhp or

Greater

– Category 3 Engines 80 125 80 125 No change

Rich

- Burn Cyclically

Load ed Spark Ignition Engines

– Category 4 Engines 90 50

- 300 Increased emission

limit

Compression Ignition Engines and Dual

- Fuel Engines

– Category 5 Engines - 797 40 700 Decreased

emission limit



### NOx EMISSION REDUCTION / COST

- EFFECTIVENESS

The APCD id entified ten engines in Santa Barbara County that will require the application of emission control techniques (or enhanced emission control techniques) as a result of the changes to

Rules 202 and 333. Because emission reductions will occur, a discussion o f the cost

- effectiveness

and incremental cost

- effectiveness data follows

.

NOx Emission Reductions

App endix H indicates the total emission reduction from modifying Rules 202 and 333 is 6.5 tons of NOx per year. Cost

- Effectiveness

The cost

- effectiven ess associated with revising Rule 333 ranges from $1,550 to $11,532 per ton of NOx reduced. Appendix H includes a summary of the cost

- effectiveness data.

Incremental Cost

- Effectiveness

Health and Safety Code Section 40920.6 requires the performance of a n incremental

cost

- effectiveness analysis for a regulation that identifies more than one control option

to meet the same emission reduction objectives. Incremental cost

- effectiveness is defined as the difference in costs divided by

the difference in emiss ion reductions betweenSTAFF REPORT

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June 19, 2008

Santa Barbara County APCD one level of control and the next more stringent

le vel of control.

Rule 333 requires compliance with NOx, ROC, and CO emission limits. Although, the APCD expects the engines to be able to meet the limits

with low

- emissions tuning procedures , s ources could replace the engine with an electric motor in lieu of complying with the engine exhaust

limits . The incremental cost

- effectiveness

between the low

- emissions tuning procedure

and electrification is assessed to be $479 per

ton of NO x reduced. Appendix H also includes a summary of the incremental cost

effectiveness data.



### ENVIRONMENTAL IMPACTS OF METHODS OF COMPLIANCE / CEQA

Methods of Compliance

California Public Resources Code § 21159 requires the APCD to perform an environm ental analysis of the reasonably foreseeable methods of compliance if the proposed rule requires “the installation of pollution control equipment, or [specifies] a performance standard or treatment requirement

... ” The proposed revisions to Rule

333 specify revised performance standards. Many existing sources already comply with the proposed revisions by performing low emissions tuning or using either clean burn kits for lean

- burn engines or selective catalytic convertors for rich

- burn engines. These are th e most reasonably

foreseeable method s of compliance. CEQA Requirements

Pursuant to the California Environmental Quality Act (CEQA) Guidelines Section

15070 and the APCD Environmental Review Guidelines, adopted in October 1995 and

revised in November 2 000, the Technology

and Environmental Assessment Division of the APCD prepared a Negative Declaration for the implementation of revised APCD Rules 102 (Definitions), 201 (Permits Required), 202 (Exemptions to Rule 201), and 333 (Control of

Emissions from R eciprocating I nternal Combustion Engines).

The proposed Negative Declaration was circulated for public review for a period of 30 days from May 12, 2008 to June 12, 2008.



### ANALYSIS OF EXISTING FEDERAL AND DISTRICT REGULATIONS

Appendix I contains the written analysis required by the California Health & Safety Code Section 40727.2 requirements.



### COMMENTS AND PUBLIC MEETINGS

Comments

Appendix J contains the comments received in response to the workshops and stakeholder meetings. Appendix J als o contains the APCD‟s responses to

the comments. Meetings

PUBLIC WORKSHOP, DECEMBER 8, 2005

Industry representatives had concerns on the proposed revisions to the definitions, permitting requirements, and the engine provisions. There were

also concern s on the proposed stacking provisions and other nuances of the APCD permitting and enforcement process es.STAFF REPORT

- Regulation II/Rule 333 Page 5

June 19, 2008

Santa Barbara County APCD WSPA STA K E HOLDERS‟ MEETING, MARCH 3,

2006

WSPA met with APCD personnel and discussed

several concerns. These included the loss of the

construction equipment and well drilling equipment exemptions and requiring emission offsets for such short term projects. Also, there was discussion on requirements for continuous emissions monitors, source testing averaging times, engine modes during testing, and r outine engine monitoring (quarterly vs. monthly).

STAKEHOLDERS‟ MEETING, JANUARY 25,

2007

The APCD released revised proposed amended rules to the public on December 15, 2006. To get industry feedback on the latest proposed amended rules, the

APCD met wi th stakeholders on January 25, 2007. During the meeting, the group discussed rule revision issues and the progress being made to resolve them.

EXXONMOBIL MEETING, JUNE 12, 2007

Staff met with ExxonMobil representatives and

discussed concerns about the proposed revised rules. Many of the concerns were the same ones raised earlier by WSPA (e.g., loss of the well drilling equipment exemption, the construction equipment exemption, and offset requirements). The discussion included information on the past, current, and future Santa Ynez Unit Project construction and operations.

VANDENBERG AIR FORCE BASE MEETING, JUNE 14, 2007

The VAFB representatives presented their concerns on construction emissions, equipment emissions (i.e., the handling of constructio n emissions associated

with non

- permitted structures and infrastructure

- type utility pipelines and power lines), the treatment of marine vessel emissions when they are associated with VAFB, microturbines used for backup distributed generation, and the 55 g allons per year exemptions (e.g., Rule 202.I.3, coatings application equipment exemption, and Rule 202.U.3, solvent wipe cleaning exemption). PUBLIC WORKSHOP, FEBRUARY 13, 2008

The regulated community indicated that they generally appreciated the newly proposed permit exemptions. Further, the new exemptions addressed many of the industry‟s concerns stemming from the deletion of the well drilling and construction equipment exemptions. However, they provided suggestions on additional changes to the exem ptions provisions, clarification of existing exemptions, revisions to the Background Paper, and possible revisions to the APCD permitting program to avoid

new source review for short

- term projects. They also expressed a concern about possible CEQA implica tions (e.g., emissions mitigation) if the APCD grants a permit or an exemption under one of the new provisions (Rule 202.F.7, 202.F.8, or Rule 202.P.14).

The APCD answered questions, addressed some of the concerns and agreed to research and/or give

furthe r consideration to other concerns, requests, and suggestions.

On proposed amended Rule 202.F.1.f, industry would prefer that the APCD not require permits for spark ignition engines rated less than 50 bhp. Staff explained that there would be a rule relax ation issue (New Source Review provisions) and Part 70 Operating Permit provisions if the APCD eliminated the existing permit requirements for engines rated less than 50 bhp. However, to alleviate some the concern, the APCD has agreed to revise the propos ed threshold from 250 bhp to 400 bhp (based on the distribution of engines). The proposed range of the engine bhp ratings will remain the same: greater than 20 through less than 50 bhp.

Regarding the CEQA implications, the APCD anticipates being able to address these through the rulemaking process, thereby simplifying project

specific CEQA analyses associated with the Rule 202 provisions.

APCD staff confirmed that past alternative methods for determining fuel usage for an engine without a

dedicated fuel meter will continue to be acceptable (e.g., methods that take into account the individual engine operating hours, brake specific fuel consumption ratings and bhp ratings, and the fuel‟s higher heating value).STAFF REPORT

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June 19, 2008

Santa Barbara County APCD COMMUNITY ADVISORY COUNCIL MEETING, APRIL 23, 2008

The Community Advisory Council (CAC) recommended that the staff report include clarifications on the emissions offset requirements and the use of the temporary equipment exemption. With incorporation of those clarifications, the CAC passed a motion to recommend that the Board approve the proposed amended rules. Staff has provided these clarifications in Attachment N, Frequently Asked Questions. PUBLIC HEARING ON THE ADOPTION OF THE PROPOSED AMENDED RULES, JUNE 19, 2008

The Board is scheduled to co nsider the adoption of the revised rules at the June 19, 2008 Public Hearing.



### COMPARISON OF ADJOINING APCD RULES

Appendix K provides a comparison of the San Joaquin Valley APCD, Ventura County APCD, and the San Luis Obispo County APCD rules on p ermit exemptions and requirements for internal combustion engines. Basically, there are general similarities with some minor differences between the adjoining air district rules and the proposed

amended rules.



### IMPACTS OF THE REVISED RULES TO INDUSTRY AND THE APCD

Details of the impacts from the rule revisions are summarized in Appendix L

. T he rule revisions will cause impact s to the regulated community and APCD staff by :

1. Eighty

- nine previously exempt e ngines becoming subject to permitting (new applications)

. 2. Eleven engines becoming subject to Rule 333 emission limits for the first time.

3. Ten e ngines requiring an emission control technique or use of an enhanced emission control technique (modification applications for engines listed in Appe ndix H, Table 1)

. 4

. The requirement to submit new and revised Inspection and Maintenance Plans and Compliance Plans

. 5. The i nitial and subsequent source testing of engines to demonstrate compliance with a new or revised

emission limit.

6

. Applying and ve rifying control techniques to comply with the Rule 333 emission limits.

7. New or increased operating and monitoring costs.

8. New or increased fees associated with permitting, source testing, annual emissions, air quality plans, and the air toxics progr am. 9. Equipment owners or operators seeking exemptions under the new specialty equipment, gas turbine, or winery exemption provisions.



### RULE CLARIFICATION ISSUES

During public workshops and meetings, members of the regulated community raised concerns a nd questions about the intent of certain rule provisio ns. These are addressed in the public comment section (Appendix J) and the Frequently Asked Questions (Appendix N).STAFF REPORT

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June 19, 2008

Santa Barbara County APCD 

### REFERENCES

1. Air Resources Board

, D etermination of Reasonably Available Contr ol Technology and Best Available Retrofit Control Technology for Stationary Spark

- Ignited Internal Combustion Engines, November 1991

.

2. Sacramento Metropolitan Air Quality Management District, Rule 412, Stationary Internal Combustion Engines Located at M ajor Stationary Sources of NOx, June 1, 1995. 3. Ventura County Air Pollution Control District, Rule 74.9, Stationary Internal Combustion Engines, November 8, 2005.



### APPENDICES

Appendix A: EPA and ARB Concerns on Rules 202 and 333 (Pursuant to Do cuments Dating from 1992 and 1994) Appendix B: Known Companies with Permit

- Exempt Engines that will Become Subject to Permitting Due to

Revisions to Rule 202 Appendix C: Known Sources Currently Operating Engines Subject to or that will Become Subject to Ru le 333

Emission Limits Appendix D: Annotated Proposed Amended Rule 102, Definitions Appendix E: Annotated Proposed Amended Rule 201, Permits Required Appendix F: Annotated Proposed Amended Rule 202, Exemptions to Rule 201 Appendix G: Annotated Proposed Ame nded Rule 333, Control of Emissions from Reciprocating Internal

Combustion Engines Appendix H: Summarized Data on Emission Reductions, Cost

- Effectiveness, and Incremental Cost

- Effectiveness Appendix I: Identification of Existing Federal and APCD Regulatio ns that Apply to the Same Equipment or Source

Type Covered in Rule 333 Appendix J: Public Comments and the APCD Responses Appendix K: Comparison of the Proposed Amended Rules to the Rules in the Adjoining Air Districts Appendix L: Impacts of the Revised Rules to Industry and the APCD Appendix M: Flowchart Overviews of Proposed Amended Rule 333 Provisions on Applicability; Engine

Identification, Meters, and Continuous Monitoring Systems; Emission Limits; and Compliance

Schedule Appendix N: Frequently Asked QuestionsTHIS PAGE INTENTIONALLY LEFT BLANKSTAFF REPORT

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June 19, 2008



### Appendix A

Santa Barbara County

EPA and CARB Concerns o n Rules 202 a nd 333 (Pursuant to Documents Dating from 1992 and 1994)

REFERENCE

- AGENCY/LETTER CATEGORY

OF CONCERN SECTION No. CONCERN a COMMENT

CARB L etter of March 6, 1992, Item

1 Rule

Improvement

Issue D.3, Emission

Limits for Cyclic Engines In Section D.3, the requirements for cyclic engines are

unclear. Section D.3.a requires at least 6.5% oxygen in exhaust at all times and prescribes a source testing schedule. Section D.3.b additionally requires compliance with emissions limits for NOx, ROC, and CO. However, Section D.3.c states that, instead of complying with Section D.3.a and D.3.b, the engine can be declared noncyclic and the owner or operator can comply with Section D.1. Section D.1 specifies emission limits for "noncyclic rich burn engines," which are identical to those specified in Section D.3.b for cyclic engines. The effect of Section D.3.c seems to be to make compliance with Section D.3.a entirely optional, but this may not be the intent of the District.

It is also unclear whether the District intends that cyclic engines arbitrarily designated "noncyclic" be required to operate in "rich burn" mode, e.g., with oxygen below 4% in their exhaust. This section should be changed to clarify the District's intent.

Another point of confusion is the reference in Section

D.3.b to Section I. Section I.3.b seems to indicate that the District will decide within a year of adoption

whether emission limits in Section D.3.b (or some other limits) are to be applied or not. If emission limits are to be set subsequent to rule adoption, it would be clearer to specify only emission limits which must be complied with immediately or, if no current limits apply, to indicate that emission limits may be imposed in the future and to describe the period which will be allowed for compliance once they are imposed. Under the proposed amended Rule (PAR) 333, Section

D.3 becomes Section E.3. Staff has delete d references to the requirement to maintain the 6.5% oxygen in the

exhaust stream and source tests from this section. The proposed revisions to the definitions of lean

- burn and

rich

- burn engine should prevent sources from changing

the status of a rich

- bur n engine to be a lean

- burn engine without obtaining a District approval.

The optional Section D.3.c is deleted in the PAR. The revised rule provisions and the new cyclically

- loaded engine definition do not provide an option for owners/operators to declar e a cyclic engine to be a noncyclic engine.

On March 2, 1993, the Air Pollution Control District Board of Directors held a public hearing to review additional information pertaining to the requirements of Section D. Industry did not provide any info rmation on the emission limits at that time. Thus, no changes to the spark ignition emission limits were made and sources needed to be in full compliance with the Rule by March 3, 1994.

a These are verbatim from the referenced document.STAFF REPORT

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June 19, 2008

REFERENCE

- AGENCY/LETTER CATEGORY

OF CONCERN SECTION No. CONCERN a COMMENT

CARB Letter of March 6, 1992, Item

2 Rule Improvement

Issue D.4, Emi ssion

Limits for Diesel Engines Section D.4 specifies somewhat higher NOx limits for

diesel engines than permitted in Sections D.1. or D.2,

but does not indicate whether the emission limits for ROC and CO specified in those sections apply to diesel engines . The limits for ROC and CO emissions for diesel engines should be clearly indicated and, if none are to be imposed, this should be stated explicitly. The Rule 333, Sections D.1 and D.2 limits were not intended to apply to compression ignition engines. Further, the diesel engine emission limits in Rule 333, Section D.4, only limited NOx emissions.

Consistent with RACT requirements, the PAR 333 includes NOx, ROC, and CO emission limits for diesel engines. The text has been revised to clarify the appli cable emission limits for the different engine

classifications.

CARB Letter of March 6, 1992, Item

3 Rule Improvement

Issue G.3.a,

Requirements

- Testing, Test

Methods In Section G.3.a, the reference to "CARB Method 1

-

100" should be corrected to referen ce "CARB Method

100."

In addition, the reference to "EPA Method 18 or EPA Method 25" should be changed to "EPA Method 25 for determination of total organics and EPA Method 18 for determination of exempt compounds," since the

methods are not alternatives b ut are rather used in combination to determine ROC corrected for exempts. The change to CARB Method 100 is reflected in the revised rule. Consistent with the CARB Spark

- Ignited Engine RACT/BARCT determination, the draft rule

includes references to the EPA methods.

For ROC testing, our source testing staff prefers that the rule stipulate only the EPA method 18 with gas chromatography

- flame ionization detection speciation analysis for C1, C2, C3, C4, C5, C6+ species.

EPA Notice of Proposed Rulemaking,

Tech nical Support Document, November 1994, Item 1 Rule

Deficiency Section A,B

Applicability/ Exemptions Rule 333 applies to units with a rated brake

horsepower of 50 or greater. Although Rule 333 is written as applicable to these size engines,

SBCAPCD's Rule 202, which includes exemptions from permit requirements, exempts units rated below 100 brake horsepower. Rule 333 allows exemptions for units exempt from permit requirements. SBCAPCD has agreed to modify Rule 202 to ensure consistency

with Rule 333. Ther efore, the exemption provision in

section B.1.b of Rule 333 should be deleted. Providing a prohibitory rule exemption for permit

exempt equipment is a common practice (e.g., Rule 342.B.1.d). With the lowering of the single

- engine permitting threshold to 5 0 bhp in Rule 202, the “consistency issue” will be eliminated. Thus, the Rule 333.B.1.b provision shall be maintained.STAFF REPORT

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June 19, 2008

REFERENCE

- AGENCY/LETTER CATEGORY

OF CONCERN SECTION No. CONCERN a COMMENT

EPA Notice of Proposed Rulemaking, Technical Support Document, November 1994, Item 2 Rule

Deficiency Section C,

Definitions The defin ition of "rated brake horsepower" is specified

as the maximum revolutions per minute specified by

the manufacturer. The definition also allows an "alternative" bhp rating to be set by a district

- issued permit to operate. Under this alternative rating,

en gines can be operated at different levels such as maximum rating, continuous rating, or derated. Since engine ratings are crucial for determining rule applicability, the provision in this section allowing alternative ratings should be deleted. EPA believ es the definition should specify rating as output determined by the manufacturer and listed on the nameplate, regardless of any derating. The revised rated brake horsepower definition, proposed to be moved to Rule 102, is similar to the San Joaquin Valley Unified APCD (SJV) Rule 4701 and Rule 4702 definitions. EPA approved those SJV rules into the SIP on May 18, 2004 (69 FR 28061). Thus, the Santa Barbara County APCD does not anticipate that EPA will identify the engine derating component

of the definitio n to be a future rule deficiency.

EPA Notice of Proposed Rulemaking, Technical Support Document, November 1994, Item 3 Rule

Deficiency Section D.2 and

D.4, Emission

Limit Requirements The provision specifying emission limits for diesel

engines requires a limit of 8.4 g/bhp

- hour be met. The corresponding concentration limit given as corrected to 15% oxygen is 797 ppm. These limits do not correspond to one another. 8.4 g/bhp

- hr converts to approximately 670 ppm assuming 35% efficiency. Due to the discrep ancy, the rule allows the least stringent (797 ppm) limit to be met. This limit should be corrected to reflect the RACT level of 8.4 g/bhp

- hr.

According to the definition given for lean

- burn engines, (which includes diesel engines) it is unclear if

diese l engines must comply with the 125 ppm limit given for lean burn engines or the 797 ppm limit. The rule should distinguish between lean burn and diesel engines so as not to cause ambiguity in which emission limits are applicable. For compression ignition engines, the PAR 333 limits NOx to 700 ppmv at 15% O2 limit or, when using exhaust controls, a minimum 40% reduction. These limits are being proposed to meet a RACT level of

control.

Regarding the ambiguities on the engine definitions and

the rule limi ts, the following changes are being made:

1) The Rule 333 definition of diesel engine is being moved to Rule 102 and it is being modified. 2) PAR 102 includes new definitions for compression ignition engine, dual

-

fuel engine, and spark ignition engine

. 3) PAR 333 includes new definitions for air

- balanced pumping engine, beam

- balanced pumping engine,

crank

- balanced pumping engine, four

- stroke engine

and stoichiometric air

- to

- fuel ratio. 4) PAR 333 includes modified definitions of cyclically

- loaded eng ine, lean

- burn engine, noncyclically

- loaded engine, rich

- burn engine, and

two

- stroke engine. 3) PAR 333, Section E, uses specific engine classification terms, when setting emission limits.STAFF REPORT

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June 19, 2008

REFERENCE

- AGENCY/LETTER CATEGORY

OF CONCERN SECTION No. CONCERN a COMMENT

EPA Notice of Proposed Rulemaking, Technical Support
Document, N ovember 1994, Item 4 Rule

Deficiency Section D.5,

Emission Limit Requirements Generally, alternative emission control plans (AECPs)

are not approvable in rules unless the provisions meet the requirements of EPA's Emission Trading Policy Statement (ETPS) an d Economic Incentive Program (EIP) requirements b . Rule 333 requires that AECPs must be submitted to SBCAPCD by March 9, 1992 and approved by the Control Officer, ARB, and EPA. There have been no AECPs submitted or approved and the option for submitting A ECPs has expired. Thus, EPA is not evaluating this provision for approvability

with the ETPS/EIP and does not consider it in this case a rule deficiency since it is no longer applicable. However it is recommended that these provisions be

deleted. PAR 333 does not include an alternative emission control provision.

EPA Notice of Proposed Rulemaking, Technical Support Document, November 1994, Item 5 Rule

Deficiency Section I,

Compliance

Schedule Owners/operators of cyclic engines are allowed to

comply with less stringent emission limits established by the Santa Barbara County Board of Supervisors through their public hearing process. This provision is

intended to take into account additional information of a study proposed by industry to test the feasibilit y of

the current rule emission limits in effect in Ventura County. Since no alternative limits were considered or established by the district's Board of Directors pursuant to section I.3., this provision is no longer applicable. However, it is recommende d that these provisions by

deleted. On March 2, 1993, the Air Pollution Control District Board of Directors held a public hearing, but industry did not provide any information on the emission limits. Thus, no changes to the spark ignition emission limit s were made and sources needed to be in full compliance with the Rule by March 3, 1994. The PAR 333 will delete the Section I.3 provisions.

It is our understanding that compliance with the VCAPCD Rule was, for the most part, accomplished by

electrificati on.

b The ETPS was published on December 4, 1986 in 51 FR 43814 and the EIP was published April 7, 1994 in 59 FR 16690 and 40 CFR P art 51, Subpart U, 51.490

- 51.494.STAFF REPORT

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Santa Barbara County APCD 

### Appendix B

Santa Barbara County Known Companies with Permit

- Exempt Engines That will Become Subject to Permitting due to Revisions to Rule 202 a

Company Name (Stationary

Source Identification No.) Facility Name Fac.

No. Equipment Description Pe rmit Category

Size > 20 bhp but < 50 bhp with > 400 bhp Aggregate (202.F.1.f) Derated

ICEs (202.F.1.f) Size ≥ 50

bhp but < 100 bhp (202.F.1.f) Well

Drilling (Deleted 202.F.6)

B.E. Conway Energy, Inc. (SSID 1944) Magenheimer Leases (A, B, C) 01946 1 Engine, DID No. 009094. X

Catco Energy (SSID 1510) Tognazzini Lease (Catco) 03200 15 Engines, DID No. 002367, 002368, 002373, 002374, 002378, 002379, 002380, 002381, 002382, 002385, 002388, 002389, 002390, 002392, &

002393. X

Catco Energy (SSID 1510) Tognazzini Lease (Catco) 03200 3 Engines, DID No. 002375, 002383, &

002414. X

Elysium Russell , LLC (SSID 4639) Russell Ranch

Lease 01086 11 Engines, DID No. 006265, 006268, 006269, 006271, 006272, 006723, 006274, 006279, 006281, 006282, & 006283. X

Elysium Russell, LLC (SSID 4639) Russell Ranch

Lease 01086 5 Engines, DID No. 006262, 006275, 006276, 006277, & 006290. X

ExxonMobil Production Company (SSID 1482) Platform Harmony 08018 1 Engine, DID No. 005346. X

ExxonMobil Production Company (SSID 1482) Platform Heritage 08019 1 Engine, DID No. 005370. X

Greka Oil & Gas, Inc. (SSID 5032) Texas Lease 03327 1 Engine, DID No. 003155. X

Greka Oil & Gas, Inc. (SSID 2680) Gato Ridge IC Engines (located at

the Williams Holding Lease, FID 3512) 04215 5 Engines, DID No. 005203, 005204, 005205, 002506, & 005207. X

Greka Oil & Gas, Inc. (SSID 2680) b Gato Ridge IC Engines 04215 1 Engine, DID No. 004439. X

Greka Oil & Gas, Inc. (SSID 2200) Jim Hopkins Lease 03092 9 Engines, DID No. 002106, 002107, 002108, 002109, 002110, 002111, 002112, 002114, &

002115. X

Greka Oil & Gas, Inc. (SSID 8678) Los Flores IC Engines (Vintage) 01848 10 Engines, DID No. 001258, 001260, 001261, 001262, 001266, 001267, 001269, 001270, 001273,

& 008524. X

a Unless otherwise specified , the data is based on the 2005 Inventory. There may be additional engines subject to permitting that the APCD is unaware of.STAFF REPORT

- Regulation II/Rule 333 Page B

- 2

June 19, 2008

Santa Barbara County APCD Company Name (Stationary

Source Identification No.) Facility Name Fac.

No. Equipment Description Pe rmit Category

Size > 20 bhp but < 50 bhp with > 400 bhp Aggregate (202.F.1.f) Derated

ICEs (202.F.1.f) Size ≥ 50

bhp but < 100 bhp (202.F.1.f) Well

Drilling (Deleted 202.F.6)

Greka Oil & Gas, Inc. (SSID 8675) SMV East IC Engines 04212 7 Engines, DID No.

004223 , 004231, 004233, 004236, 004237, 004239,

& 004241. X

Greka Oil & Gas, Inc. (SSID 8702) Zaca Area IC Engines 04005 4 Engines, DID No. 003594, 003595, 003596,

& 003603. X

Pacific Operators Offshore, Inc. (SSID 8001) Platform Hogan 08001 1 Engine . DID No. 007107. X

Pacific Operators Offshore, Inc. (SSID 8001) Platform Houchin 08002 1 Engine. DID No. 007108. X

Purisima Hills LLC (SSID 1153) H.P. Boyne Lease 03777 6 Engines, DID No. 005908, 005909, 005910, 005911, 005912, &

009015. X

S anta Maria Refining Company (SSID 3730) Armelin Lease 03736 4 Engines, DID No. 005947, 005949, 005950,

& 006231. X

Venoco, Inc. (SSID 1063) Platform Holly 03105 3 Engines, DID No. 009130, 009131, &

009132. X

TOTALS BY CATEGORY 26 40 16 7

OVERA LL TOTAL 89STAFF REPORT

- Regulation II/Rule 333 Page C

- 1

June 19, 2008

Santa Barbara County APCD 

### Appendix C

Santa Barbara County Known Sources Operating Engines Currently Subject to or That will Become Subject to Rule 333 Emission Limits When the Proposed Amended Rules are Adopted a

Company Name, Stationary Source Description, and Facility Description Stat.

Source

No. Fac.

No. Device

No. Device Name Bhp ICE Will Become Subject to the

Emission Limits

for the 1 st time

due to the Rule

Revisions b

BreitBurn Energy Company LP, BreitBurn Energy

- Orcutt Hill, Orcutt Hill IC Engines 02667 04214 004434 IC Engine: (#19766) 400

BreitBurn Energy Company LP, BreitBurn Energy

- Orcutt Hill, Orcutt Hill IC Engines 02667 04214 004435 IC Engine: (#12163) Fox Injection 301

City of Lompoc, City of Lompoc

- WWT Plant, Lompoc WWT

Plant 01708 01708 001192 IC Engine: Air Compressor 275

City of Lompoc, City of Lompoc

- WWT Plant, Lompoc WWT

Plant 01708 01708 001193 IC Engine: Air Compressor 275

City of Lompoc, City of Lompoc

- WWT Plant, Lompoc WWT

Plant 01708 01708 001194 IC Engine: Air Compres sor 275

DCOR, LLC, Platform Habitat,

Platform Habitat 08012 08012 004972 IC Engine: South

Crane 128

DCOR, LLC, Platform Habitat,

Platform Habitat 08012 08012 004973 IC Engine: North

Crane 350

DCOR, LLC, Platform Habitat,

Platform Habitat 08012 0801 2 004985 IC Engine: Compressor IC Engine 1350

DCOR, LLC, South County/Dos Cuadras, Platform A 08003 08003 004872 IC Engine: South

Crane 109

DCOR, LLC, South County/Dos Cuadras, Platform A 08003 08003 004873 IC Engine: North

Crane 230

DCOR, LLC, So uth County/Dos Cuadras, Platform B 08003 08004 004886 IC Engine: 15

- Ton Pedestal Crane (South Crane) 109

DCOR, LLC, South County/Dos Cuadras, Platform B 08003 08004 004887 IC Engine: 25

- Ton Pedestal Crane (North Crane) 230

DCOR, LLC, South County/Dos Cuadras, Platform Hillhouse 08003 08005 004905 IC Engine: 25

- Ton Pedestal (North) Crane 238

DCOR, LLC, South County/Dos Cuadras, Platform C 08003 08006 004924 IC Engine: 25

- Ton Pedestal Crane (North Crane) 230

a Based on the APCD 2005 Emission Inventory.

b An “X” is shown for engines becoming subject to Rule 333 emission limits for the f irst time. If no “X” appears, the engine is already subject to Rule 333 emission limits.STAFF REPORT

- Regulation II/Rule 333 Page C

- 2

June 19, 2008

Santa Barbara County APCD Company Name, Stationary Source Description, and Facility Description Stat.

Source

No. Fac.

No. Device

No. Device Name Bhp ICE Will Become Subject to the

Emission Limits

for the 1 st time

due to the Rule

Revisions b

DCOR, LLC, South County/Dos Cuadras, Pl atform Henry 08003 08007 004939 IC Engine: 25

- Ton Pedestal (North Crane) 475

E & B Natural Resources Mgt. Corp., E & B

- South Cuyama, E & B IC Engines 01073 08916 006388 IC Engine: W

- 2 195

E & B Natural Resources Mgt. Corp., E & B

- South Cuyama, E & B IC Engines 01073 08916 006389 IC Engine: W

- 3 195

E & B Natural Resources Mgt. Corp., E & B

- South Cuyama, E & B IC Engines 01073 08916 006390 IC Engine: W

- 8 195

E & B Natural Resources Mgt. Corp., E & B

- South Cuyama, E & B IC Engines 01073 08916 006391 IC Engine: W

- 4 195

E & B Natural Resources Mgt. Corp., E & B

- South Cuyama, E & B IC Engines 01073 08916 006392 IC Engine: W

- 12 Wastewater Inj, (added by dfg) 195

E & B Natural Resources Mgt. Corp., E & B

- South Cuyama, E & B IC Eng ines 01073 08916 006393 IC Engine: W

- 11 195

E & B Natural Resources Mgt. Corp., E & B

- South Cuyama, E & B IC Engines 01073 08916 006394 IC Engine: W

- 15 195

E & B Natural Resources Mgt. Corp., E & B

- South Cuyama, E & B IC Engines 01073 08916 006 395 IC Engine: W

- 42 Wastewater Inj, (added by dfg) 195

E & B Natural Resources Mgt. Corp., E & B

- South Cuyama, E & B IC Engines 01073 08916 006396 IC Engine: B

- 5 Wastewater Inj, (added by dfg) 135

E & B Natural Resources Mgt. Corp., E & B

- South Cuyama, E & B IC Engines 01073 08916 006397 IC Engine: B

- 6 174

E & B Natural Resources Mgt. Corp., E & B

- South Cuyama, E & B IC Engines 01073 08916 006400 IC Engine: HRA #9 (not on PTO 8010) 792

E & B Natural Resources Mgt. Corp., E & B

- South C uyama, E & B IC Engines 01073 08916 006401 IC Engine: HRA #10 (not on PTO 8010) 792

E & B Natural Resources Mgt. Corp., E & B

- South Cuyama, E & B IC Engines 01073 08916 006402 IC Engine: HRA #11 792

E & B Natural Resources Mgt. Corp., E & B

- Sou th Cuyama, E & B IC Engines 01073 08916 006403 IC Engine: HRA #12 (not on PTO 8010) 792

ExxonMobil Production Company, Exxon

- SYU Project,

Platform Hondo 01482 08009 004956 IC Engine: Pedestal

Crane West 160STAFF REPORT

- Regulation II/Rule 333 Page C

- 3

June 19, 2008

Santa Barbara County APCD Company Name, Stationary Source Description, and Facility Description Stat.

Source

No. Fac.

No. Device

No. Device Name Bhp ICE Will Become Subject to the

Emission Limits

for the 1 st time

due to the Rule

Revisions b

ExxonMobil Production Company, Exxon

- S YU Project,

Platform Hondo 01482 08009 004957 IC Engine: Pedestal

Crane East 160

ExxonMobil Production Company, Exxon

- SYU Project, Platform Harmony 01482 08018 005326 Pedestal Crane East 450

ExxonMobil Production Company, Exxon

- SYU Project,

Platfo rm Heritage 01482 08019 005350 Pedestal Crane East 450

Greka Oil & Gas, Inc., Cat Canyon, Cat Canyon IC Engines 02658 03831 006466 Controlled IC Engine

12253 Gas Compressor (added by dfg) 225

Greka Oil & Gas, Inc., Cat Canyon, Cat Canyon IC Engines 026 58 03831 006467 Controlled IC Engine:

Waukesha 110007 (Inj. #2

- added by dfg) 190

Greka Oil & Gas, Inc., Cat Canyon, Cat Canyon IC Engines 02658 03831 006468 IC Engine: #20 6LRZ (#912330) (NSCR) (Not found in PTO 8036) 410

Greka Oil & Gas, Inc., Cat Canyon, Cat Canyon IC Engines 02658 03831 007289 IC Engine: Compressor #1: #F3521GSI (last used in 2002, removed from permit in 2004) 747

Greka Oil & Gas, Inc., Clark Avenue Source, Clark Avenue IC Engines 02200 04204 004178 IC Engine: #912330 186

Greka Oil & Gas, Inc., Clark Avenue Source, Clark Avenue IC Engines 02200 04204 004179 IC Engine: #912331 186

Lash Construction, Lash Const. (5 S. Calle Cesar Chavez ), Lash Const. (5 S. Calle Cesar Chavez ) 10309 10437 010082

or 107679 Diesel IC Engine (may

be superseded by DID 107679) 434.5

Mafi

- Trench Corporation, Mafi

Trench, Mafi

- Trench 01717 01717 001195 IC Engine: Air Compressor 456

Pacific Operators Offshore, LLC, Pacific Operators

- Carpinteria, Platform Hogan 08001 08001 004849 IC Engine: North

Crane 230

Pacific Operators Offshore, LLC, Pacific Operators

- Carpinteria,

Platform Houchin 08001 08002 004861 IC Engine: North

Crane 230

Pacific Operators Offshore, LLC, Pacific Operators

- Carpinteria, Platform Hogan 08001 08001 007107 IC En gine: Well Service Rig 400 XSTAFF REPORT

- Regulation II/Rule 333 Page C

- 4

June 19, 2008

Santa Barbara County APCD Company Name, Stationary Source Description, and Facility Description Stat.

Source

No. Fac.

No. Device

No. Device Name Bhp ICE Will Become Subject to the

Emission Limits

for the 1 st time

due to the Rule

Revisions b

Pacific Operators Offshore, LLC, Pacific Operators

- Carpinteria,

Platform Houchin 08001 08002 007108 IC Engine: Well Service Rig 400 X

Plains Exploration & Production Company, Pt. Pedernales/Lompoc Oil Fields, Platform Ire ne 04632 08016 005082 IC Engine: North

Crane 210

Plains Exploration & Production Company, Pt. Pedernales/Lompoc Oil Fields, Platform Irene 04632 08016 005083 IC Engine: South

Crane 197

Purisima Hills LLC

- Barham Ranch, H.P. Boyne Lease 01153 03777 0 05908 IC Engine: Well Pump 65 X

Purisima Hills LLC

- Barham Ranch, H.P. Boyne Lease 01153 03777 005909 IC Engine: Well Pump 65 X

Purisima Hills LLC

- Barham Ranch, H.P. Boyne Lease 01153 03777 005910 IC Engine: Well Pump 65 X

Purisima Hills LLC

- Bar ham Ranch, H.P. Boyne Lease 01153 03777 005911 IC Engine: Well Pump 65 X

Purisima Hills LLC

- Barham Ranch, H.P. Boyne Lease 01153 03777 005912 IC Engine: Well Pump 65 X

Purisima Hills LLC

- Barham Ranch, H.P. Boyne Lease 01153 03777 009015 IC Engine: Natural

Gas

- Fired 65 X

SBC Resource Recovery & Waste Mgmt Div., County of

Santa Barbara

- Foxen Canyon, County of Santa Barbara

- Foxen Canyon 03706 03706 104269 Diesel Fired IC Engine (Gen 4) 78

SBC Resource Recovery & Waste Mgmt Div., County of

Santa Barbara

- Foxen Canyon, County of Santa Barbara

- Foxen Canyon 03706 03706 106429 Diesel Fired IC Engine (Gen 5) 78

Southern California Gas Company, So Cal Gas

- La Goleta, La Goleta 05019 01734 001199 IC Engine: Gas Compressor # 2 650

Southern Calif

ornia Gas Company, So Cal Gas

- La Goleta, La Goleta 05019 01734 001200 IC Engine: Gas Compressor # 3 650

Southern California Gas Company, So Cal Gas

- La Goleta, La Goleta 05019 01734 001201 IC Engine: Gas Compressor # 4 650

Southern California Gas Company, So Cal Gas

- La Goleta, La Goleta 05019 01734 001202 IC Engine: Gas Compressor # 5 650

Southern California Gas Company, So Cal Gas

- La Goleta, La Goleta 05019 01734 001203 IC Engine: Gas Compressor # 6 660STAFF REPORT

- Regulation II/Rule 333 Page C

- 5

June 19, 2008

Santa Barbara County APCD Company Name, Stationary Source Description, and Facility Description Stat.

Source

No. Fac.

No. Device

No. Device Name Bhp ICE Will Become Subject to the

Emission Limits

for the 1 st time

due to the Rule

Revisions b

Southern California Gas Company, S o Cal Gas

- La Goleta, La Goleta 05019 01734 001204 IC Engine: Gas Compressor # 7 660

Southern California Gas Company, So Cal Gas

- La Goleta, La Goleta 05019 01734 001205 IC Engine: Gas Compressor # 8 660

Southern California Gas Company, So Cal Gas

- La Goleta, La Goleta 05019 01734 001206 IC Engine: Gas Compressor # 9 1100

Southern California Gas Company, So Cal Gas

- La Goleta, La Goleta 05019 01734 005666 IC Engine: Electrical

Generator #1A 170

Southern California Gas Company, So Cal Gas

- L a Goleta, La Goleta 05019 01734 005667 IC Engine: Electrical

Generator #2A 170

Southern California Gas Company, So Cal Gas

- La Goleta, La Goleta 05019 01734 005668 IC Engine: Electrical

Generator #3A 170

Southern California Gas Company, So Cal Gas

- La Goleta, La Goleta 05019 01734 005669 IC Engine: Electrical

Generator #20A 144

The Point Arguello Companies, The Point Arguello Project,

Platform Harvest 01325 08013 005000 IC Engine: Crane (800A) 503

The Point Arguello Companies, The Point Arguel lo Project,

Platform Harvest 01325 08013 005001 IC Engine: Crane (800B) 503

The Point Arguello Companies, The Point Arguello Project,

Platform Harvest 01325 08013 005002 IC Engine: Crane (CR801) 270

The Point Arguello Companies, The Point Arguello Pr oject,

Platform Hermosa 01325 08014 005029 IC Engine: West

Crane 475

The Point Arguello Companies, The Point Arguello Project,

Platform Hermosa 01325 08014 005030 IC Engine: East Crane 475

The Point Arguello Companies, The Point Arguello Project,

Pla tform Hidalgo 01325 08015 005058 IC Engine: West

Crane 475

The Point Arguello Companies, The Point Arguello Project, Platform Hidalgo 01325 08015 005059 IC Engine: East Crane 475

United States Air Force, Vandenberg Air Force Base, Vandenberg AFB 30 C ES/CEV 01195 00201 006182 IC Engine: Electrical Generator (Building 7425) 115

Venoco, Inc., Venoco

- Carpinteria, Carpinteria Gas Plant 00027 00027 000201 Gas compressor (IR #1) 440STAFF REPORT

- Regulation II/Rule 333 Page C

- 6

June 19, 2008

Santa Barbara County APCD Company Name, Stationary Source Description, and Facility Description Stat.

Source

No. Fac.

No. Device

No. Device Name Bhp ICE Will Become Subject to the

Emission Limits

for the 1 st time

due to the Rule

Revisions b

Venoco, Inc., Venoco

- Carpinteria, Carpinteria Gas Plant 00027 00027 000202 IC Engine: Compressor: SACS Cooper (CA

- 83) 1800

Venoco, Inc., Venoco

- Carpinteria, Carpinteria Gas Plant 00027 00027 000203 Gas compressor (IR #3) 440

Venoco, Inc., Venoco

- Carpinteria, Carpinteria Gas Plant 00027 00027 000204 Gas compresso r (IR #4) 300

Venoco, Inc., Venoco

- Carpinteria, Carpinteria Gas Plant 00027 00027 000205 Gas compressor (IR #5) 440

Venoco, Inc., Venoco

- Carpinteria, Carpinteria Gas Plant 00027 00027 000206 Gas compressor (IR #6) 440

Venoco, Inc., Venoco

- Carpi nteria, Carpinteria Gas Plant 00027 00027 008166 IC Engine: Diesel

fired 180

Venoco, Inc., Venoco

- Carpinteria, Carpinteria Gas Plant 00027 00027 100222 IC Engine: Compressor (G

- 1) (Was DID 009138) 220

Venoco, Inc., Venoco

- Ellwood, Platform Holly 01063 03105 002336 IC Engine: Pedestal

Crane 92

Venoco, Inc., Venoco

- Ellwood, Platform Holly 01063 03105 009130 IC Engine: Drilling Rig Generator #1 803 X

Venoco, Inc., Venoco

- Ellwood, Platform Holly 01063 03105 009131 IC Engine: Drilling Rig Gen erator #2 803 X

Venoco, Inc., Venoco

- Ellwood, Platform Holly 01063 03105 009132 IC Engine: Drilling Rig Generator #3 1053 X

Venoco, Inc., Venoco

- Ellwood Marine Terminal, Jovalan Barge 01085 03203 002437 IC Engine: VRU 245

Venoco, Inc., Venoco

- E llwood

Marine Terminal 01085 03203 002438 IC Engine: Generator 89STAFF REPORT

- Regulation II/Rule 333 Page D

- 1

June 19, 2008

[ Annotated draft of June 19, 2008 ] Santa Barbara County APCD Rule 102 102

- 1 May 20, 1999 [ Date of revised rule adoption ] 

### Appendix D

Santa Barbara County Annotated Proposed Amended Rule 102, Definitions

RULE 102. DEFINITIONS. (Adopted 10/18/1971, revised 1/12/1976, readopted 10/23/1978, revised

7/11/198 9, 7/10/1990, 7/30/1991, 7/18/1996, 4/17/1997, 1/21/1999, 5/20/1999, 6/19/2003, and

1/20/2005
, and [ date of revised rule adoption ] )

These definitions apply to the entire rulebook. Definitions specific to a given rule are defined in that rule or in the

fi rst rule of the relevant regulation. Except as otherwise specifically provided in these Rules where the context otherwise indicates, words used in these Rules are used in exactly the same sense as the same words are used in

Division 26 of the Health and S afety Code.

[. . .]

“Alternative Diesel Fuel” means any fuel used in a compression ignition engine that is not commonly or commercially known, sold, or represented by the supplier as diesel fuel No. 1

- D or No. 2

- D, pursuant to the specifications in ASTM D 975, “Standard Specification for Diesel Fuel Oils,” ASTM International , or an alternative fuel, and does not require engine or fuel system modifications for the engine to operate, although minor modifications (e.g., recalibration of the engine fuel contr ol) may enhance performance. Examples of alternative diesel fuels include, but are not limited to, biodiesel; Fischer

- Tropsch fuels; emulsions of water in diesel fuel; and fuels with a fuel additive, unless:

1. the additive is supplied to the engine fue l by an on

- board dosing mechanism, or

2. the additive is directly mixed into the base fuel inside the fuel tank of the engine, or

3. the additive and base fuel are not mixed until engine fueling commences, and no more additive plus base fuel combination is mixed than required for a single fueling of a single engine.



### [Note 1: This definition is similar to the definition in the Airborne Toxic Control Measure for Stationary Compression Ignition Engines. It is needed because the

term is used in the definitio n of “dual

- fuel engine.”]

[. . .]

“ ASTM” means American Society for Testing and Materials

. In 2001, the American Society for Testing and Materials officially changed its name to “ASTM International.”



### [Note 2: The “ASTM” term appears in several rules . Thus, consistent with the APCD policy, the definition of the “ASTM” acronym is being added to Rule 102. Also, the note after the definition recognizes the official name change to add clarity to the references of the “ASTM International” standards.]

[. . .]

“Compression Ignition Engine” means a reciprocating, internal combustion engine that is not a spark ignition engine

.



### [Note 3: This is modeled on the “compression

- ignition” definition in 40 CFR, Part

89, Subpart A, Section 89.2. Defining the ter m in Rule 102 is necessary because it is used in Rule 202, Rule 333, and Rule 1201.]

[. . .]STAFF REPORT

- Regulation II/Rule 333 Page D

- 2

June 19, 2008

[ Annotated draft of June 19, 2008 ] Santa Barbara County APCD Rule 102 102

- 2 May 20, 1999 [ Date of revised rule adoption ] “Derated” means a ny physical change to an emission unit to physically limit and restrict the equipment‟s power rating from th e power rating specified by the manu facturer on the date of initial manufacture of the equipment

.



### [Note 4: The definition is similar to the San Joaquin Valley APCD definition: “De

rated Engine: An internal combustion engine which has been physically limited and restricted by permit condi tions to an operational level of 50 horsepower or less.” The Santa Barbara County APCD made it more general to apply to other items (e.g., boilers) in Rule 202. It is necessary to define derated in Rule 102

because Rule 202 refers to Rule 102 in its defi nition section.]

“ Diesel Engine ” means a compression ignited four stroke engine that is operated with an exhaust stream oxygen concentration of 4 percent by volume, or greater type of internal combustion engine that uses low

- volatility petroleum fuel and fuel injectors and initiates combustion using compression ignition (as opposed to spark ignition that is used with gasoline engines)

.



### [Note 5: The APCD relocated the definition of rated brake horsepower from Rule

333 and revised the definition. The revi sed definition is from the CARB “Glossary

of Air Pollution Terms” on the CARB Web Site: http://www.arb.ca.gov/html/gloss.htm. The APCD is adding the term for clarity.]

[. . .]

“Dual

- Fuel Engine” means any compression ignition engine that is engineered and designed to operate on a combination of alternative fuels, such as compressed natural gas (CNG) or liquefied petroleum gas (LPG) and diesel fuel or an alternative diesel fuel. These engines have two separate fuel systems, which inject both fuels

simul taneously into the engine combusti o n chamber.



### [Note 6: This definition is the same as the definition in the Airborne Toxic Control Measure for Stationary Compression Ignition Engines. It is necessary to include the definition in Rule 102 to clarify appl icable provisions in Rule 202 and Rule 333.]

[. . .]

“Fuel” means any substance that is burned, combusted, or incinerated in an engine, boiler, heater, burner, steam generator, process heater, flare, thermal oxidizer, or any other combustion unit, and wh ich includes, but is not limited to, gasoline, natural gas, field gas, produced gas, waste gas, methane, digester gas, landfill gas, contaminated soil/water cleanup gaseous effluent, ethane, propane, butane, liquefied petroleum gas (LPG), jet propellants, diesel fuels

, and distillate fuels.



### [Note 7: The APCD is adding this definition for clarity. The definition is similar to the one found in the Determination of RACT and BARCT for Stationary Spark

Ignited Internal Combustion Engines.]STAFF REPORT

- Regulation II/Rule 333 Page D

- 3

June 19, 2008

[ Annotated draft of June 19, 2008 ] Santa Barbara County APCD Rule 102 102

- 3 May 20, 1999 [ Date of revised rule adoption ] “Fuel Additive” m

eans any substance designed to be added to fuel or fuel systems or other engine

- related engine systems such that it is present in

- cylinder during combustion and has any of the following effects: decreased emissions, improved fuel economy, increased perform ance of the engine; or assists diesel emission control strategies in decreasing emissions, or improving fuel economy or increasing performance of the engine.



### [Note 8: This definition is the same as the one found in the Airborne Toxic Control

Measure for Stationary Compression Ignition Engines. It is necessary to clarify the definition of alternative diesel fuel.]

[. . .]

“ Higher Heating Value ” means the total heat liberated per mass of fuel burned (B ritish t hermal u nit per pound), when fuel and dry air at standard conditions undergo complete combustion and all resulting products are brought to their standard states at standard conditions. “G ross heating value” shall have the same meaning as “higher heating value

. ”



### [Note 9: The term higher heating val ue is being added to Rule 102 because the term is used in more than one prohibitory rule. The reference to the gross heating value having the same meaning as higher heating value is added for clarity. The term “gross heating value” is found in the Rule 2 10, Schedule A.3.]

“Internal Combustion Engine” means an engine in which both the heat energy and the ensuing mechanical energy are produced inside the engine. In ternal combustion engines in clude gas turbines, spark ignition, and compression ignition eng ines.



### [Note 10: This definition is from the CARB “Glossary of Air Pollution Terms” on the CARB Web Site. The APCD is adding the term for clarity.]

[. . .]

“Portable i I nternal c C ombustion e E ngine” means any internal combustion engine that is portable, meaning it is carried or moved from one location to another in the normal course of business. Indicia of portability shall include, but are not limited to, wheels, skids, carrying handles, or a dolly, trailer, vessel, or platform , or mounting . “Portable internal combustion engine” does not include an engine used to propel nonroad equipment or a motor vehicle of any kind, including, but not limited to, a heavy duty vehicle. The engine is not portable if:

1. the engine or its replacement is attached to a foundation, or if not so attached, will reside at the same location for more than 12 consecutive months. The period during which the engine is maintained at a storage facility shall be excluded from the residency time determination. Any engine, such as a back

- up or stand

- by engine, that replace engine(s) at a location, and is intended to perform the same or similar function as the engine(s) being replaced, will be included in calculating the consecutive time period. In that case, the cumulative time of al l engine(s), including the time between the removal of the original engine(s) and installation of the replacement engine(s), will be counted toward the consecutive time period; or

2. the engine remains or will reside at a location for less than 12 conse cutive months if the engine is located at a seasonal source and operates during the full annual operating period of the seasonal source, where a seasonal source is a stationary source that remains in a single location on a permanent basis (at least two yea rs) and that operates at that single location at least three months each year; orSTAFF REPORT

- Regulation II/Rule 333 Page D

- 4

June 19, 2008

[ Annotated draft of June 19, 2008 ] Santa Barbara County APCD Rule 102 102

- 4 May 20, 1999 [ Date of revised rule adoption ]

3. the engine is moved from one location to another in an attempt to circumvent the portable residence time requirements.



### [Note 11: The APCD used the ARB definition o f portable in the Statewide Portable Equipment Registration Program (PERP) to model the revised definition of portable internal combustion engine .]

[. . .]

“ Rated brake horsepower ” means the maximum continuous brake horsepower rating at maximum revolution s per minute (RPM) specified for the engine by the manufacturer . Alternately, the rated brake horsepower of an engine shall be the maximum allowable and enforceable rating specified by the District, stated in the Permit to Operate (PTO), and accepted by t

he engine operator or listed on the original nameplate of the unit, unless otherwise physically limited and specified by a condition on the engine's Permit to Operate

.



### [Note 12: The APCD relocated the definition of rated brake horsepower from Rule

333 an d revised the definition

. EPA identified the rated brake horsepower definition as a rule deficiency in a November 1994 Technical Support Document. Their concern indicates, in part, “EPA believes the definition should specify rating as output determined b y the manufacturer and listed on the nameplate, regardless of any derating.” Although the revised definition may not completely address the EPA concern, it is similar to the San Joaquin Valley Unified APCD (SJV) Rule 4701

and Rule 4702 definitions. EPA a pproved those SJV rules into the SIP on May 18, 2004 (69 FR 28061). Thus, we do not anticipate EPA identifying the engine derating component of the definition to be a future rule deficiency.]

[Note 13: It is necessary to have the definition in Rule 102 because the term is used in Rule 202 and Rule 333.]

[. . .]

“Spark Ignition Engine” means a gasoline

- fueled engine or other engine with a spark plug (or other sparking device) and with operating characteristics significantly similar to the theoretical Ot to combustion cycle. Spark ignition engines usually use a throttle to regulate intake air flow to control power during normal operation.



### [Note 14: This is similar to the definition of “spark

- ignition” in 40CFR 89.2. It is necessary to have the definiti on in Rule 102 because the term is used in Rule 202 and Rule 333.]

[. . .]

“Specialty Equipment” means portable engines used to power equipment located in the Outer Continental

Shelf or State Territorial Waters that satisfy all of the following condition s:

1

. The portable engine is ineligible for registration in the State Portable Equipment Registration Program; and

2

. A similar portable engine or equipment unit capable of performing the specialty work is not registered in the State Portable Equipment Registration Program or, if registered is not available

for use ; andSTAFF REPORT

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[ Annotated draft of June 19, 2008 ] Santa Barbara County APCD Rule 102 102

- 5 May 20, 1999 [ Date of revised rule adoption ]

3

. The portable engine/equipment unit performs a unique function or activity outside the normal scope of drilling or construction activities; and

4

. The equipment will be used for less than 500 hours per stationary source in any calendar year and

emit not more than 10 tons per stationary source of oxides of nitrogen

, oxides of sulfur

, reactive organic compounds, or particulate matter in any calendar year; and

5

. Use of the equipment i s not recurrent from year to year.

“Specialty Equipment Emergency Use” means that conditions giving rise to the use of the specialty equipment were due to 1) conditions beyond the reasonable control of the stationary source, including but not

limited to t he breakdown of essential drilling or construction equipment, and 2) the use of the specialty equipment is necessary to complete essential short

- term projects.



### [Note 15: The above two definitions are needed because of the newly

- proposed “specialty equip ment” exemption in Rule 202, Section F.5. The APCD is adding that exemption in response to an industry request. The definitions were modified after the February 13, 2008 workshop to address issues raised by the regulated community. These revisions inclu ded extending the Specialty Equipment definition to State Territorial Waters and adding or construction text to the definitions.]

[. . .]THIS PAGE INTENTIONALLY LEFT BLANKSTAFF REPORT

- Regulation II/Rule 333 Pa ge E

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[ draft of June 19, 2008 ] Santa Barbara County APCD Rule 201 201

- 1 April 17, 1997 [ Date of revised rule adoption ] 

### Appendix E

Santa Barbara County Annotated Proposed Amended Rule 201, Permits Required

RULE 201. PERMITS REQUIRED. (Adopted 10/18/1971, revised 5/1/1972, readopted 10/23/1978, revised

7/2/1979, and 4/17/1997 , and [ date of revised rule adoption ] )

A. Applicability

This rule applies to any person who builds, erects, alters, repla ces, operates or uses any article, machine, equipment, or other contrivance which may cause the issuance of air contaminants.

B. Exemptions

Exemptions to this rule appear in Rule 202 (Exemptions to Rule 201).

C. Definitions

See Rule 102 for defin itions not limited to this rule. For the purposes of this rule, the following definitions shall apply:

"Erect" means the setting up, installing, or assembling of equipment that can be moved from one location to another and that must be stationary in o rder to operate.

D. Requirement

- Authority to Construct

1. Any person building, erecting, altering, or replacing , or using any article, machine, equipment or other contrivance, the use of which may cause the issuance of air contaminants or the

use o f which may eliminate or reduce or control the issuance of air contaminants, shall first obtain an Authority to Construct for such construction or use from the Control Officer. An Authority to

Construct issued to a source shall remain in effect until the Permit to Operate the equipment for which the application was filed is granted or denied or the application expires.



### [Note 1: Adding the text “using” and “or use” is consistent with the Health and Safety Code Section 42300(a) provisions. Section D.1 is becoming Section D.]

2. Notwithstanding any exemption in these rules and regulations, equipment used for the dredging of waterways, except during emergencies declared by public officials in accordance with state law, or equipment used in pile driving adj acent to or in waterways, or pipe

- laying and derrick barges, shall obtain an Authority to Construct and a Permit to Operate when the potential to emit of such equipment per stationary source is equal to or greater than 25 tons per year of any affected poll utant during any consecutive 12 month period. The Control Officer shall not require Best Available Control Technology for such sources if federal law preempts this requirement.

[. . .]



### [Note 2: The APCD is moving the Section D.2 provision into Rule 202 , Section F.7 to

group the exemptions together. The proposed revised text found in Rule 202.F.7 provides clarification on when permits are required and helps address some of the regulated community’s concerns with the removal of the construction exemption (Rule 202.F.3). The proposed new Section 202.F.8 also provides NSR options for marine vessel engines associated with stationary source activities.]THIS PAGE INTENTIONALLY LEFT BLANKSTAFF REPORT

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[ Annot ated draft of June 19, 2008 ] Santa Barbara County APCD Rule 202 202

- 1 April 17, 1997 [ Date of revised rule adoption ] 

### Appendix F

Santa Barbara County Annotated Proposed Amended Rule 20 2, Exemptions to Rule 201

RULE 202. EXEMPTIONS TO RULE 201. (Adopted 10/18/1971, revised 5/1/1972 and 6/27/1977,

readopted 10/23/1978, revised 12/7/1987, 1/11/1988, 1/17/1989, 7/10/1990, 7/30/1991, 11/05/1991, 3/10/1992, 5/10/1994, 6/28/1994, and 4/17/19 97 , and [ date of revised rule adoption ])

A. Applicability

An Authority to Construct or Permit to Operate shall not be required for equipment, operations

, and

activities described herein.

B

. Exceptions

Notwithstanding any exemption created by this Rul e rule , any :

1. e E quipment, activity or operations proposed by an applicant for use as an Emission Reduction Credit is not exempt.

2. Emission unit that functions for distributed electrical generation and is not certified under the regulations of the Air Resources Board is not exempt

.



### [Note 1: The new provision on distributed electric generation equipment is needed for consistency with the California Administrative Code, Title 17, Section 94201(d) provisions on the applicability of the California distr ibuted generation certification program.]

[. . .]

D

. General Provisions

[. . .]

5. Temporary Equipment

A permit shall not be required for temporary equipment where the projected actual aggregate emissions of all affected pollutants do not exceed 1 t on (except carbon monoxide, which shall not exceed 5 tons) and the use of each individual piece of equipment does not exceed one 60 day period in any consecutive 12 month period. Such equipment shall also meet one of the following requirements:

a. the te mporary equipment is not part of an existing operating process of a stationary

source; or

b. the temporary equipment replaces equipment that has qualified for a breakdown pursuant

to Rule 505.STAFF REPORT

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[ Annot ated draft of June 19, 2008 ] Santa Barbara County APCD Rule 202 202

- 2 April 17, 1997 [ Date of revised rule adoption ]

To qualify for this exemption, the owner or operator shal l submit a written request to the Control

Officer , who shall make a determination in writing approving or denying the request . This request shall identify the temporary equipment, its location, any equipment being replaced, and shall

include the emission calculations and assumptions that demonstrate that the equipment meets the exemption criteria. The temporary project may commence as soon as the written request has been made, however, project commencement with equipment that is later found ineligible for the exemption shall constitute a violation of the District‟s Rules and Regulations. This exemption shall not apply to equipment used for the specific purpose to control emissions of Hazardous Air

Pollutants Toxic Air Contaminants . The owner or operator shall pay any applicable fee pursuant

to Rule 210.



### [Note 2: The new text on the APCO making a written determination for the exemption is needed for clarification and uniformity within Rule 202. Owners and operators seeking an exemption per Rule 202, Sec tions D.5, D.7, F.5, F.7, K.6, and P.14 shall file an APCD

- 38 Form, Request for Written Determination of Permit Exemption, along with the fee.]

[Note 3: The terminology for the specific purpose is added to make the exemption applicable to systems that h ave small amounts of TACs while requiring control systems for vapor streams that are composed of TACs to be subject to permitting. Without this change, the use of a vapor recovery system on a temporary tank would require a permit because small amounts of TACs

would be directed to the vapor recovery system .]

[Note 4: The change from Hazardous Air Pollutants (HAPs) to Toxic Air

Contaminants (TACs) is necessary to cover certain air pollutants (e.g., ammonia, copper compounds, diesel exhaust) that are listed as a TAC but not listed as a Hazardous Air Pollutant.]

[. . .]

7. Stationary Source Permit Exemption

A permit shall not be required for any new, modified or existing stationary source if the uncontrolled actual emissions of each individual affected pol lutant from the entire stationary source are below 1.00 ton per calendar year, unless:

[. . .]

Each owner or operator who desires seeking this exemption shall submit an a written request to the

Control Officer, who shall make a determination in writing approving or denying the
request exemption request form and obtain written concurrence from the District

. A fee shall be assessed as specified in The owner or operator shall pay any applicable fee pursuant to Rule 210 (Schedule F)

.



### [Note 5: The reasons f

or these changes are discussed in Note 2.]

[. . .]

11. Where an exemption is described in this Rule rule for a general category of equipment, the

exemption shall not apply to any component which otherwise would require a permit under the provisions of th ese Rules and Regulations. See Note

2.

See Notes

3 and 4.STAFF REPORT

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[ Annot ated draft of June 19, 2008 ] Santa Barbara County APCD Rule 202 202

- 3 April 17, 1997 [ Date of revised rule adoption ] [. . .]

15. For the purposes of the exemptions set forth in F.1.e; F.1.f ; F.1.g ; and G.1, the ratings of all

engines or combustion equipment used in the same process sha ll be accumulated to determine whether these exemptions ap ply.



### [Note 6: This provision clarifies that several emission units are treated as one emission unit where simultaneous operation of two or more emission units in the same process could occur to meet operation and/or system demands. This

is consistent wi th past practice. A determination that equipment is used in the same process is based on the engineering design. For example, analysis will involve looking at the equipment’s or system’s maximum energy needs or

demands under a worst

- case scenario.

16. N otwithstanding any exemption in these rules and regulations, i f the combined emissions from all construction equipment used to construct a stationary source which requires an Authority to

Construct have a projected actual in excess of 25 tons of any pollut ant, except carbon monoxide, in a 12 month period, the owner of the stationary source shall provide offsets as required under the provisions of Rule 804 and shall demonstrate that no ambient air quality standard would be

violated.



### [Note 7a: The proposed new Rule 202, Section D.16 text is essentially the same text found in the current Rule 202.F.3. Although the APCD is proposing to delete the Rule 202.F.3 exemption for engines used in construction, it is necessary to maintain the portion of the 202.F.3 te xt on offset requirements. The intent is to not remove large stationary source construction mitigation.]

17. No additional permit shall be required at a stationary source in the District for equipment permitted by the District for various location uses p rovided the following conditions are met:

a. The owner or operator of the equipment has a valid Permit to Operate issued by the District that specifically denotes the equipment as being usable at various locations within

the District and that the terms an d conditions of the Permit to Operate are fully complied

with.

b. The equipment is not used to replace equipment which is part of an existing process at the stationary source.

c. The equipment is used for repair and maintenance related purposes only.

d

. The stationary source reports all uses (including the start and end dates) and associated emissions for each use under this exemption to the APCD in their next annual report (or

semi

- annual report for Part 70 sources).



### [Note 7b: The APCD is adding thi s provision in response to comments from industry.]

[. . .]STAFF REPORT

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[ Annot ated draft of June 19, 2008 ] Santa Barbara County APCD Rule 202 202

- 4 April 17, 1997 [ Date of revised rule adoption ] F. Internal Combustion Engines

1. A permit shall not be required for internal combustion engines if any of the following conditions is

satisfied:

a. Engines used in aircraft and in lo comotives;

b. Engines used to propel marine vessels, except vessels associated with a stationary source which shall be regulated as specified under the provisions of Regulation VIII.

c. Engines used to propel vehicles, as defined in Section 670 of the California Vehicle Code, but not including any engine mounted on such vehicles that would otherwise require a permit under the provisions of these Rules and Regulations.

d. Spark ignition piston

- type internal combustion engines used exclusively for emer gency electrical power generation or emergency pumping of water for flood control or firefighting if the engine operates no more than 200 hours per calendar year, and where a record is maintained and is available to the District upon request; the record sh all list the identification number of the equipment, the number of operating hours on each day the engine is operated and the cumulative total hours.

e. Compression ignition engines with a rated brake horsepower of less than 50 or less

. No

compre ssion ignition engine otherwise subject to permit shall be exempt because it has

been derated.



### [Note 8: The addition of the word “rated” before brake horsepower is needed for consistency with the new rated brake horsepower definition in Rule 102. The cu toff is being revised from 50 brake horsepower (bhp) or less to less than 50 bhp . This is necessary for consistency with the California Airborne Toxic Control Measure for Diesel Particulate Matter from Portable Engines Rated at 50 Horsepower and Greater ( California Code of Regulations, Title 17, Sections 93116 et seq.).]

[Note 9: The new provision on permitting derated equipment is necessary to ensure that the derating method is enforceable.]

f. Spark ignition piston

- type internal combustion eng ines with a manufacturer's maximum rating of 100 rated brake horsepower of less than 50. or less or gas turbine engines with a maximum heat input rate of 3 million British thermal units per hour or less at standard

conditions , except if the total horsep ower of individual spark ignition piston

- type internal combustion engines less than 100 brake horsepower but greater than 20 brake horsepower at a stationary source, as defined in Rule 102, exceeds 500 bhp in which case the

individual engines are not exemp t. Notwithstanding the previous sentence, none of the individual engines in the range of less than 50 but greater than 20 rated brake horsepower
are exempt if such engines at a stationary source have a total rated brake horsepower rating of 400 or greater

.

No spark ignition piston

- type internal combustion engine otherwise subject to permit shall be exempt because it has been derated. Spark i gnition piston

- type Internal internal combustion engines exempt under other provisions of Section F and permitted s park ignition piston

- type internal combustion engines do shall not count toward the 500 400 bhp rated brake horsepower aggregate limit. See Notes 10

and 11.

See Note 12.

See Note

13.

See Note

14.STAFF REPORT

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[ Annot ated draft of June 19, 2008 ] Santa Barbara County APCD Rule 202 202

- 5 April 17, 1997 [ Date of revised rule adoption ]



### [Note 10: The addition of the word “rated” before brake horsepower is needed for consistency with the new rated brake horsepower definition in Rule 102.]

[Note 11: Less than 50 bhp Threshold for the Single

- Engine Exemption for Spark Ignition Piston

- Type Engines : The exemption, on a single

- engine basis, is being changed from the permitting threshold of greater than 100 brake horsepower to 50 brake horsepower and greater . Lowering the single

- engine exemption threshold from 100 to less than 50 brake horsepower is consistent with an EPA

- identified deficiency, requirements in adjoining APCDs, and the ARB Determination of

Re asonably Available Control Technology and Best Available Retrofit Control Technology for Stationary Spark

- Ignited Internal Combustion (ARB RACT/BARCT Determination).]

[Note 12: The exemption on gas turbine engines is being moved to Section F.1.g.]

[Note 13: Exemption for Sources with Multiple Spark Ignition Piston

- Type Engines : For situations where there are several spark ignition engines at the same stationary source, the proposed revised provision will:

1. Change the less than 100 but greater than 2 0 brake horsepower range for assessing the total rated brake horsepower sum to less than 50 but greater than 20 brake horsepower

.

2. Change the amount for the permitting threshold from 500 brake horsepower to 400 brake horsepower

.

Revising the range t o be greater than 20 to less than 50 brake horsepower is consistent with permitting engines rated 50 brake horsepower and greater. The APCD is setting the “gatekeeper” figure at 400 brake horsepower based on the distribution of engines in the 2005 invento ry.]

[Note 14: The new provision on permitting derated equipment is necessary to ensure that the derating method is enforceable. Indicating permitted engines are not counted towards the 400 brake horsepower aggregate limit is appropriate

because these e ngines already require permitting.]

g. G as turbine engines with a maximum heat input rat ing of 3 million British thermal units per hour or less at standard conditions

. No gas turbine engine otherwise subject to permit shall be exempt because it has been derated. For the purposes of this s ection, power generating microturbines fired on natural gas which meets General Order 58

- A of the Public Utility Commission that have been certified by the Air Resources Board to meet the applicable distributed gen eration standards certified by a current Air Resources Board Executive Order are not subject to the provisions of Section D.15 if the potential annual emissions of each affected pollutant does not exceed 1 ton (except carbon monoxide,

which shall not excee d 5 tons)

.



### [Note 15: This sentence is currently within Rule 202.F.1.f. For clarity, it is being moved to a separate section.] See Note

16. See Note 15.

See Note

17.STAFF REPORT

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[ Annot ated draft of June 19, 2008 ] Santa Barbara County APCD Rule 202 202

- 6 April 17, 1997 [ Date of revised rule adoption ]



### [Note 16: The new provision on permitting derated equipment is necessary to ensure that the derating method is enforceable.]

[Note 17: This text allows for limited “grouping/multi

- packing” of microturbine engines under certain conditions. The greater than 1 ton per year (except CO,

which is 5 tons per year ) pollutant threshold stems from previously EPA

- approved

levels for APC D exemptions.]

2. A permit shall not be required for portable engines registered in the Statewide Registration Program, pursuant to California Code of Regulations, title 13, section 2451 et seq. and Health and Safety Code Section 41753 et seq. Notwi thstanding this provision, the requirements of Section F.3

D.16 shall apply to such portable engines and the requirements of Section F.6 shall apply to such portable engines used in the outer continental shelf

. All o perators using this permit exemption

sh all comply with the State Portable Equipment Registration Program and Air Resources Board

issued registration

.



### [Note 18: The replacement of the reference to Section F.3 with Section D.16 is needed because the Section F.3 provision on construction equipm ent offset requirements is being moved to Section D.16.]

[Note 19: The deletion of the Section F.6 text is necessary because the exemption for well drilling in state territorial waters (STW) and the outer continental shelf (OCS) is being deleted.]

[Note 20: The APCD is adding this provision to ensure that all operators (i.e., those located onshore, in STW, and the OCS) of engines registered in the State Portable Equipment Registration Program (PERP) availing themselves to the exemption comply with the r equirements of the PERP and the ARB

- issued registration for their engine.]

3. A permit shall not be required for engines used in construction activities. However, if the combined emissions from all construction equipment used to construct a stationary so urce which requires an Authority to Construct have the potential to exceed 25 tons of any pollutant, except carbon monoxide, in a 12 month period, the owner of the stationary source shall provide offsets as required under the provisions of Rule 804 and sha ll demonstrate that no ambient air quality

standard would be violated.



### [Note 21: Rule 202 will no longer provide an exemption for construction engines. The owners and operators of such engines should be registering them in the Statewide Portable Equipme nt Registration Program. The construction engine offset provision is being moved to the general provisions of Rule 202 (new Section D.16).]

4. A permit shall not be required for engines used for aircraft shows or to power amusement rides at

seasonal or special occasion shows, fairs, expositions, circuses or carnival events, provided that the duration of such event is less than 18 days in any calendar year.

5 4

. A permit shall not be required for engines with a rated brake horsepower of less than 50 bhp u sed:

a. for military tactical support operations including maintenance and training for such operations; See Notes

18 and 19.

See Not e 20.STAFF REPORT

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[ Annot ated draft of June 19, 2008 ] Santa Barbara County APCD Rule 202 202

- 7 April 17, 1997 [ Date of revised rule adoption ]

b. to power temperature and humidity control systems on cargo trailers used to transport satellites and space launch equipment;

c. exclusively for s pace launch facility support and which power hoists, jacks, pulleys, and other cargo handling equipment permanently affixed to motor vehicles or trailers pulled by motor vehicles.



### [Note 22: This change is needed to eliminate the bhp acronym.]

6 5

. A per mit shall not be required for drilling specialty equipment

. used in state waters or in the outer continental shelf provided the emissions from such equipment are less than 25 tons per stationary source of any affected pollutant during any consecutive 12 mo nth period. To qualify for this exemption, the owner or operator of the stationary source shall submit a written request to the Control Officer, who shall make a determination in writing approving or denying the request. The owner or operator shall pay a ny applicable fee pursuant to Rule 210. For specialty equipment emergency use, operations may commence as soon as the written request has been made; however, operation of equipment which is later found ineligible for the exemption shall constitute a viola tion of the District‟s Rules and Regulations.



### [Note 23: Rule 202 will no longer provide a general exemption for offshore drilling equipment. The owners of portable engines should be registering them in the Statewide Portable Equipment Registration Pro gram. Owners of existing stationary well drilling engines located on the platforms have 90 days to submit a PTO application per Rule 202.E.]

[Note 24: Industry requested that Rule 202 include an exemption for specialty equipment due to the loss of the d rilling exemption. Additional provisions have been added for “specialty equipment” and “specialty equipment emergency use.”]

7 6

. An internal combustion engine which powers an item of equipment identified as exempt in any other part of this Rule rule is not exempt unless the engine qualifies for an exemption pursuant to

this rule.

7. A permit shall not be required for Notwithstanding any exemption in these rules and regulations, equipment used for the dredging of waterways, except during emergencies dec lared by public officials in accordance with state law, or equipment , including associated marine vessels, used in for pile driving adjacent to or in waterways, or cable and pipe

- laying vessels/barges or and derrick barges

, shall obtain an Authority to Con struct and a Permit to Operate when if the potential to emit of such equipment per stationary source is less equal to or greater than 25 tons per year of any affected pollutant during any consecutive 12 month period. The Control Officer shall not require Best Available Control Technology for such sources if federal law preempts this requirement. To qualify for this exemption, the owner or operator of the stationary source shall submit a written request for exemption to the Control Officer, who shall make a determination in writing approving or denying the request. The request shall identify the equipment, its location, and shall include the emission calculations and assumptions that demonstrate that the equipment meets the exemption criteria. The

owner or operator shall pay any applicable fee pursuant to Rule 210. Alternatively, an owner or operator of the stationary source may qualify for an exemption from the New Source Review provisions of Regulation VIII by obtaining an Authority to Construct and Pe rmit to Operate which limits the potential to emit of such equipment to less than 25 tons per year of any affected pollutant during any consecutive 12 month period.



### [Note 25: The APCD relocated the Rule 201.D.2 provision here at the request of industry to include this exemption with other exemptions. The proposed revisedSTAFF REPORT

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June 19, 2008

[ Annot ated draft of June 19, 2008 ] Santa Barbara County APCD Rule 202 202

- 8 April 17, 1997 [ Date of revised rule adoption ]



### text provides clarification on when permits are required and helps address some of the regulated community’s concerns with the removal of the construction exemption (Rule 202.F.3). It provides stationary sources with the ability to exempt qualifying equipment from the requirement to obtain an ATC under Regulation VIII.]

8. For purposes of Regulation VIII, the following shall not be subject to New Source Review: Marine vessel engines (propulsion engines, auxiliary engines and permanently affixed support engines) associated with construction, maintenance, repair and/or demolition activities at a stationary source provided the duration of the activities do not exceed 12 consecutive month s and the potential to emit of such engines per stationary source is less than 10 tons per stationary source of oxides of nitrogen, oxides of sulfur, reactive organic compounds or particulate matter. To qualify for this exemption, the owner or operator of the stationary source shall submit a written request for exemption to the Control Officer, who shall make a determination in writing approving or denying the request. The request shall identify the marine vessels, project activities, duration, and shall include the emission calculations and assumptions demonstrating that the engines meet the exemption criteria. The owner or operator shall pay any applicable fee pursuant to Rule 210. Alternatively, an owner or operator of the stationary source may qualif y for an exemption by obtaining an Authority to Construct and Permit to Operate which limits the potential to emit of such equipment to less than 10 tons per year. Such Authority to Construct/Permit to Operate shall be exempt from Regulation VIII.



### [Note 26: With the removal of the construction exemption (202.F.3.), engines used to propel marine vessels associated with a stationary source construction project will need to be permitted (see 202.F.1.b). The addition of new Rule 202.F.8 will help address so me of the regulated community’s concerns with the removal of the construction exemption.]

G

. Combustion Equipment (Other than Internal Combustion Engines)

Notwithstanding the listed exemptions, any collection of articles, machines, equipment or other

c ontrivances within each listed equipment category at a stationary source that has aggregate emissions in excess of 25 tons per calendar year of any affected pollutant is not exempt.

1. Combustion equipment with a maximum heat input of less than or equal to two (2) million British thermal units per hour is exempt from permit requirements if fired exclusively with one of the following:

a. Natural or produced gas which meets General Order 58

- A of the Public Utility Commission,

b. Liquefied petroleum ga s, which meets Gas Processors Association Standards,

c. A combination of natural or produced and liquefied petroleum gas, meeting the requirements of subdivisions (a) and (b) above.

Combustion equipment with a maximum heat input rate of 1 million Bri tish thermal units per hour or less is exempt and does not count towards the 25 tons per calendar year stationary source exemption threshold listed above in this paragraph

, provided the equipment is fired exclusively

with fuel listed above in a, b, or c li sted above in this paragraph

. No combustion equipment otherwise subject to permit shall be exempt because it has been derated.STAFF REPORT

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[ Annot ated draft of June 19, 2008 ] Santa Barbara County APCD Rule 202 202

- 9 April 17, 1997 [ Date of revised rule adoption ]



### [Note 27: The text has been revised for consistency and clarity. The last sentence is added to ensure that the derating metho d is enforceable.]

2. Combustion equipment (other than internal combustion engines) which provides heat energy to any item of equipment identified as exempt in any other part of this Rule rule , is not exempt unless fired exclusively with one of the fuels l isted in G.1.a., G.1.b., or G.1.c. the combustion equipment is exempt as specified in G.1.



### [Note 28: This section is being revised for consistency and clarity.]

[. . .]

I. Coatings Applications Equipment and Operations

The following listed coating a pplications equipment and operations is exempt from permit requirements. Notwithstanding the listed exemptions, any collection of articles, machines, equipment or other contrivances within each listed equipment category at a stationary source that has agg regate emissions in excess of 10 tons per calendar year of any affected pollutant is not exempt.

[. . .]

5. Polyurethane powder Powder coating operations , provid ed the powder coating material reactive

organic compound content i s equal to or less than fiv e percent, by weight.



### [Note 29: At the request of industry, the APCD is revising this exemption to include all powder coating materials with an ROC content not exceeding five percent by weight.]

[. . .]

K. Food Processing and Preparation Equipment

Th e following listed food processing and preparation equipment is exempt from permit requirements. Notwithstanding the listed exemptions, any collection of articles, machines, equipment or other contrivances within each listed equipment category at a statio nary source that has aggregate emissions in excess of 10 tons per calendar year of any affected pollutant is not exempt.

[. . .]

7

. Fermentation, aging, and bottling process operations conducted at wineries, breweries, distilleries

and similar facilities , provided the projected actual emissions from such operations for each individual affected pollutant from the entire stationary source are below 1.00 ton per calendar year. To qualify for this exemption , the owner or operator shall submit a written reque st to the Control Officer, who shall make a determination in writing approving or denying the request. The owner or operator shall pay any applicable fee pursuant to Rule 210.



### [Note 30: Wineries, breweries, and distilleries have been considered exempt p er Rule 202.D.7 (the one ton per year exemption). The APCD proposes this separate exemption to provide a stand

- alone exemption for such activities.]

[. . .]

L. General Utility Equipment and OperationsSTAFF REPORT

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[ Annot ated draft of June 19, 2008 ] Santa Barbara County APCD Rule 202 202

- 10 April 17, 1997 [ Date of revised rule adoption ] The following listed general utility equipment an d operations is exempt from permit requirements. Notwithstanding the listed exemptions, any collection of articles, machines, equipment or other contrivances within each listed equipment category at a stationary source that has aggregate emissions in

exce ss of 10 tons per calendar year of any affected pollutant is not exempt.

[. . .]

15. Notwithstanding G.2 of this rule, portable steam cleaning/pressure washing equipment with

maximum heat input rating less than 1 million Btu/hr British thermal units per hour fired exclusively on diesel fuel.

16. Notwithstanding G.2 of this r ule, portable water heaters used exclusively for underwater diving activities with a maximum heat input rating less than 1 million British thermal units per hour fired exclusively o n diesel fuel.



### [Note 31: At the request of industry, the APCD is adding an exemption for water heaters that provide underwater divers with heated water to prevent hypothermia.]

[. . .]

P. Miscellaneous Equipment and Operations

The following miscellan eous equipment and operations is exempt from permit requirements. Notwithstanding the listed exemptions, any collection of articles, machines, equipment or other contrivances within each listed equipment category at a stationary source that has aggregate emissions in excess of 10 tons per calendar year of any affected pollutant is not exempt.

[. . .]

14. For purposes of Regulation VIII, the following shall not be subject to New Source Review:

Marine vessel engines (propulsion engines, auxiliary engines and permanently affixed support engines) associated with launch vehicle recovery operations for the Missile Defense Agency‟s Airborne Laser program provided the potential to emit is less than 5 tons per year of oxides of nitrogen, oxides of sulfur, reactiv e organic compounds or particulate matter. To qualify for this exemption, the owner or operator of the stationary source shall submit a written request for exemption to the Control Officer, who shall make a determination in writing approving or denying

th e request. The request shall identify the marine vessels, project activities, duration, and shall include the emission calculations and assumptions demonstrating that the engines meet the exemption criteria. The owner or operator shall pay any applicable fee pursuant to Rule 210. Alternatively, an owner or operator of the stationary source may qualify for an exemption by obtaining an Authority to Construct and Permit to Operate which limits the potential to emit of such equipment to less than 5 tons per year. Such Authority to Construct/Permit to Operate shall be exempt from Regulation VIII.



### [Note 32: The APCD is adding this exemption in response to a request from Vandenberg Air Force Base.]

[. . .]STAFF REPORT

- Regulation II/Rule 333 Page F

- 11

June 19, 2008

[ Annot ated draft of June 19, 2008 ] Santa Barbara County APCD Rule 202 202

- 11 April 17, 1997 [ Date of revised rule adoption ] U. Solvent Application Equipment and Operations

The following solvent application equipment and operations is exempt from permit requirements. Notwithstanding the listed exemptions, any collection of articles, machines, equipment or other contrivances within each listed equipment category at a stationa ry source that has aggregate emissions in excess of 10 tons per calendar year of any affected pollutant is not exempt.

[. . .]

3. Equipment used in wipe cleaning operations

, provided that the solvents used do not exceed 55

gallons per year per station ary source

.

To qualify for this exemption, the owner or operator shall maintain records of the amount (gallons per year) of solvents used at the stationary source for each calendar year.

These records shall be kept maintained on site for a minim um of at least 3 years and be made available to the District on request. Thereafter, the records shall be maintained either on site or readily available for expeditious inspection and review for an additional 2 years. Solvents meeting

the criteria of 2.b . or c. above do not contribute to the 55 gallon s per year per stationary source

limitation.



### [Note 33: The per stationary source and at the stationary source text is being added for clarity. Specifying that the exemption applies on a stationary source b asis is consistent with the legislative intent when this provision was added in 1997.]

[Note 34: Changes to the record retention provisions are consistent with the EPA policy.]

[. . .] See Note

34. See Note 33.

See Note

33.THIS PAGE INTENTIONALLY LEFT BLANKSTAFF REPORT

- Regulation II/Rule 333 Page G

- 1

June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 1 April 17, 1997 [ Date of revised rule adoption ] 

### Appendix G

Santa Barbara Coun ty Annotated Proposed Amended Rule 333, Control of Emissions from

Reciprocating Internal Combustion Engines

RULE 333. CONTROL OF EMISSIONS FROM RECIPROCATING INTERNAL COMBUSTION

ENGINES. (Adopted 12/03/1991, revised 12/10/1991
, and 4/17/1997 , and [ date of revised rule adoption ] )

A. Applicability

1. The provisions of this rule shall apply to all any engine s with a rated brake horsepower of 50 or
greater and which are fueled by natural gas, field gas, liquefied petroleum gas, diesel fuel, gasoline

, or any other liquid fuel

.



### [Note 1: These changes make the rule applicable to any engine rated at 50 brake horsepower or greater without any reference to the fuel burned.]

B. Exemptions

1. Notwithstanding A.1., t T he requirements of this R r ule shall not ap ply to:

a. Engines Spark ignition engines operating on gaseous fuel consisting of 75 percent or more of landfill gas on a volume basis determined by annual fuel use. To qualify for this exemption

written documentation must shall be submitted with the A uthority to Construct application to and approved by the Control Officer. The documentation must describe the fuel meter s used

, and the level of accuracy of the fuel meter s , and calculations to correct volumes to

standard conditions to demonstrate complia nce. Separate fuel meters shall be used which

that measure s the volume s ( ft 3 cubic feet ) of landfill gas used and a separate fuel meter for the volume (ft 3 ) of all other gases gaseous fuel used. Fuel usage records shall be maintained identifying the volum

e of landfill gas and the volume of natural gas all other gaseous fuel used annually. The following method shall be used to determine the 75 landfill gas percent
percentage on a volume basis:

Volume in ft 3 cubic feet of landfill gas co nsumed annually x 100

Percent of Fuel use Landfill Gas Percentage = Total Volume in ft 3 cubic feet of all gas gaseous fuel consumed annually

The volumes in the above equation shall be corrected for standard conditions

.



### [Not e 2: These changes add clarity, improve grammar, and correct the equation

terms. ]

b. Engines that are exempt from permit under the provisions of Rule s 202, Exemptions to Rule

201

.



### [Note 3: This is a minor change for clarity. EPA suggested that this exemption be removed for consistency. Instead of deleting this exemption, the APCD has achieved consistency by changing the Rule 202 permit exemption threshold (as explained further in Appendix A, page A

- 2, EPA Item 1).]STAFF REPORT

- Regulation II/Rule 333 Page G

- 2

June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 2 April 17, 1997 [ Date of revised rule adoption ]

c. Any d erated engine having a ma ximum allowable and enforceable output rating of less than

50 brake horsepower , provided such rating is specified by the District in an Authority to Construct or Permit to Operate and accepted by the engine owner or operator

.



### [Note 4: Providing an exempt ion for these engines is consistent with the “applicability” provision in the ARB Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology for Stationary Spark

- Ignited Internal Combustion (ARB RACT/BARCT Deter mination).]

d. Any c ompression ignition emergency standby engines

, as defined under California Code of Regulations, Title 17, Section 93115

, Airborne Toxic Control Measure for Stationary Compression Ignition (CI) Engines

.



### [Note 5: The exemption recogniz es that these emergency compression ignition engines are subject to the state Airborne Toxic Control Measure for Stationary Compression Ignition Engines and are low use engines.]

2. Engines which operate An y engine that has a total aggregated operational period less than 200 hours per calendar year are is exempt from Sections D

. , E

. , F

. , and G. the requirements of this rule , with the exception of the engine identification requirement in Section D. 1 , the elapsed operating time meter requirement in Section D. 2 , the recordkeeping provisions in Section J .3 , and the compliance schedule provision s in Section K

. To qualify for this exemption

, the engine owner or operator shall maintain and record in a log, as required in Section H, the engine hour meter reading every first working day of each calendar quarter

. The hours per year operating period of a r elocated engine that perform s the

same functio n as the engine it displaced will be included in calculating the total aggregated operating period for determining appl icability of this exemption

.



### [Note 6A: The Airborne Toxic Control Measure for Stationary Compression Ignition Engines (California Code of Regulations, Title 17) Section 93115.3(j) has a low

- use exemption for p rime engines operating no more than 20 hour s per year. Thus, a compression ignition engine may be exempt from Rule 333, but not the ATCM.]

[Note 6B: The requirements to use an elapsed operating time meter and to perform recordkeeping exist in the current rule text (Sections 333.B.2 and 333.H). The requirements to provide a method for engine identification, document engine relocations, and adhere to a compliance schedule are new. These are added to improve substantiation of exemption claims.]

3. Section G requirements for a Compli ance Plan shal l not be applicable to any compression ignition engines that are subject to an exhaust emission standard in the:

a. California Code of Regulations, Title 13, Section 2423, for off

- road engines, or

b. 40 CFR, Part 89, for nonroad compression ignition en gines.



### [Note 7: The APCD has determined that compression ignition engines subject to State or Federal requirements in “a” and “b” above do not need a compliance plan. ]STAFF REPORT

- Regulation II/Rule 333 Page G

- 3

June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 3 April 17, 1997 [ Date of revised rule adoption ] C. Definitions

See Rule 102 for definitions not limited to this rule. For the p urpose of this R r ule, the following definitions apply:



### [Note 8: The addition is made for rule clarification. Numerous engine

- related terms are being added to Rule 102 because they appear in Rule 202 and Rule 333.]

“Air

- balanced pumping engine” means a noncyclically

- loaded engine powering a well pump, with the pump using compressed air in a cylinder under the front of the walking beam to offset the weight of the column of rods and fluid in the well, eliminating the need for counterweights.



### [Note 9: Thi s definition is needed to clarify the definition of noncyclically

- loaded engine .]

“ Beam

- balanced pumping engine ” means a cyclically

- loaded engine powering a well pump, with the pump counterweight on the back end of the walking beam. The counterweight is moved mechanically without a cylinder supplying air pressure.

“ Crank

- balanced pumping engine ” means a cyclically

- loaded engine powering a well pump, with the pump counterweight attached to a gearbox which is attached to the walking beam with a pitman arm. The counterweight is moved mechanically, in a circular motion, without a cylinder supplying air pressure.



### [Note 10: The two preceding definitions are needed to clarify the cyclically

- loaded engine definition.]

“ Cyclic ally

- loaded engine ” means an engin e that under normal operating conditions has an external load that

varies in shaft load by 40 percent or more of rated brake horsepower during any load cycle or recurrent periods of 30 seconds or less, or is used to power an oil a well reciprocating pump in g unit including beam

- balanced or

crank

- balanced pumps. Engines powering air

- balanced pumps are noncyclically

- loaded engines

.



### [Note 11: The APCD is replacing the existing “cyclic engine” term with the “cyclically

- loaded engine” term and relocating the term to be in alphabetical order. The definition has also been revised for clarity. Use of the “cyclically

- loaded engine” term is consistent with the ARB RACT/BARCT Determination. An engine being classified as a cyclically

- or noncyclically

- loaded engin e is strictly dependent on its external load in a particular service.]

1. “ Engine ” means any spark or compression ignited ignition engine in which the pistons are contained within a cylinder and move back and forth in a straight line.

2. “ Cyclic engine ” means an engine that under normal operating conditions varies in shaft load by 40 percent or more of rated brake horsepower during recurrent periods of 30 seconds or less, or is used to power an oil well reciprocating pumping unit.



### [Note 12: The APCD relocated the definition of cyclic engine to put the definitions into alphabetical order, changed the term to cyclically

- loaded engine , and modified

the definition .]

3. “ Noncyclic engine ” means any engine which is not a cyclic engine.STAFF REPORT

- Regulation II/Rule 333 Page G

- 4

June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 4 April 17, 1997 [ Date of revised rule adoption ]



### [Note 13: The APC D relocated the definition of noncyclic engine to put the definitions into alphabetical order, changed the term to noncyclically

- loaded engine , and

modified the definition .]

“Exhaust c ontrols ” means any device or technique used to treat an engine's exhaus t to reduce emissions, and include (but are not limited) to catalysts, afterburners, reaction chambers, and chemical injectors.



### [Note 14: The addition of the exhaust controls term is needed to clarify alternative compliance provisions available when usin g an exhaust control (i.e., requirements in lieu of meeting the exhaust concentration limits).]

4. “ Existing engine ” means an engine which that by December 3, 1991 [ date of revised rule adoption ] ;

a 1

. has been issued a valid ATC Authority to Construc t, or PTO Permit to Operate, or Exemption to a Permit to Operate (or listed as exempt on an Authority to Construct or Permit to Operate) pursuant to District rules and regulations; or

b 2

. has been identified in an application for an ATC Authority to Con struct submitted to and deemed complete by the District; or

c 3

. is an identical replacement as defined in Rule 202 A. (5) for an engine defined in Section

C.4.a. has been operated in Santa Barbara County as exempt and now requires a Permit to Operate beca use of a Rule 202 exemption change effective [ date of revised rule adoption ].



### [Note 15: Changes to the above three sections are needed to improve clarity. Also,

the references to Exemption to a Permit to Operate and listed as exempt on an Authority to Construct or Permit to Operate are added to address engines that were installed at the time of adoption of the amended rule. The terms new engine and existing engine are necessary to determine compliance schedules for this amended rule.]

5. “ New engine ” is an engine which is not an existing engine.



### [Note 16: The term new engine is relocated to put the definitions into alphabetical order.]

6. “ Field gas ” means gas which does not meet the standards as published by the Public Utilities

Commission for n atural gas (37 California Code of Regulations 589)

.



### [Note 17: The APCD is deleting this term as it is no longer used in Rule 333.]

“Four

- stroke engine ” means any type of engine which completes the power cycle in two crankshaft revolutions, with intake and compression strokes in the first revolution and power and exhaust strokes in the

second revolution.



### [Note 18: The term “four

- stroke engine” is used in the definitions for “lean

- burn engine” and “rich

- burn engine.” Both ARB and EPA noted that a die sel engine is also

a “lean

- burn” engine and the existing rule emission limits were not clear. The

addition of the four

- stroke engine term will help clarify the different engine classifications and their emission limits.]STAFF REPORT

- Regulation II/Rule 333 Page G

- 5

June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 5 April 17, 1997 [ Date of revised rule adoption ] 7. “ Lean

- burn engine ” means a s park

- ignited or compression ignited, Otto

- cycle, Diesel cycle or

any two

- stroke or four

- stroke engine where the manufacturer's recommended operating air

- to

- fuel ratio divided by the stoichiometric air

- to

- fuel ratio is greater than 1.1 . Any existing engine where there are no manufacturer‟s recommendations regarding the air

- to

- fuel ratio will be considered a lean

- burn engine if the excess oxygen content of the exhaust at full load conditions that is operated with an exhaust stream oxygen

concentration of is greater than 4 2 percent by volume , or greater

. Where exhaust control is employed on such an existing engine, The the exhaust gas oxygen content shall be determined from the uncontrolled

exhaust stream. An y engine modification that changes a ny rich

- burn engine to a lean

- burn engine or vice versa requires approval from the Control Officer in the form of a p ermit modification.



### [Note 19: The term “lean

- burn engine” has been modified to address EPA and ARB concerns and definitions.]

“ New engine ” is an en gine that is not an existing engine.



### [Note 20: The new engine definition has been relocated to be in alphabetical order.]

" Noncyclic ally

- loaded engine " means any engine which is not a cyclic ally

- loaded engine.



### [Note 21: The APCD relocated the defini tion of noncyclic engine here, changed the term to noncyclically

- loaded engine and revised the definition.]

8. “ Operating engine ” means an engine that is operating and consuming fuel for its intended application a minimum of 150 hours for each month dur ing the 12 consecutive month period prior to the adoption of this Rule as certified by the engine owner or operator.



### [Note 22: The APCD is deleting this term as it is will no longer used in the revised Rule 333.]

9. " Rated brake horsepower " means the maximum brake horsepower rating at maximum revolutions per minute (RPM) specified for the engine by the manufacturer. Alternately, the rated brake horsepower of an engine shall be the maximum allowable and enforceable rating specified by the District, sta ted in the Permit to Operate (PTO), and accepted by the engine operator.



### [Note 23: The rated brake horsepower definition is being modified and relocated into Rule 102, Definitions.]

“ppmv” means parts per million by volume , dry

.



### [Note 24: This is a ne w definition that is added to clarify the units used for mass rate emission limits and monitoring/testing results.]

10. “ Rich

- burn E e ngine ” means a spark

- ignited , Otto

- cycle, or a an y spark ignition

, four

- stroke naturally aspirated engine where the manuf acturer

- recommended operating air

- to

- fuel ratio divided by the

stoichiometric air

- to

- fuel ratio is less than or equal to 1.1

. Any existing engine where there are no manufacturer‟s recommendations regarding the air

- to

- fuel ratio will be considered a rich

- b urn engine if the excess oxygen content of the exhaust at full load conditions that is operated with an exhaust stream oxygen

concentration of is less than or equal to 4 2 percent by volume. Where exhaust control is employed on such an existing engine

, Th e the exhaust gas oxygen content shall be determined from the uncontrolled exhaust stream. Additionally, any engine which is designated as a rich burn engine on a District Permit on the date of rule adoption shall be a rich burn engine. An y engine modific ation that changes a ny rich

- burn engine to a lean

burn engine or vice versa requires approval from the Control Officer in the form of a permit modification.STAFF REPORT

- Regulation II/Rule 333 Page G

- 6

June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 6 April 17, 1997 [ Date of revised rule adoption ]



### [Note 25: The term “Rich

- burn engine” has been modified to address EPA and ARB

concerns and defin itions.]

11. “ Diesel Engine ” means a compression ignited four stroke engine that is operated with an exhaust stream oxygen concentration of 4 percent by volume, or greater.



### [Note 26: The diesel engine definition is being modified and relocated into Ru le 102, Definitions.]

“Stoichiometric air

- to

- fuel ratio ” means the chemically correct air

- to

- fuel ratio where all fuel and all oxygen in the air and fuel mixture will be consumed

.



### [Note 27: The “stoichiometric” term is used in the definitions for “lean

- burn engine,”

“rich

- burn engine,” and “two

- stroke engine,” which are being revised to address

ARB and EPA

- identified deficiencies.]

“Two

- stroke engine ” means a type of engine which completes the power cycle in single crankshaft revolution by combining th e intake and compression operations into one stroke and the power and exhaust operations into a second stroke. This system requires auxiliary scavenging and inherently runs lean of the

stoichiometric air

- to

- fuel ratio

.



### [Note 28: This term is used in the definition of “lean

- burn engine.”]

D. Requirements

– Engine Identification, Meter s , and Continuous Monitoring System s

The owner or operator of any engine subject to this r ule shall ensure each engine meets the following requirements in accordance with t he compliance schedule specified in Section K

.

1. A ny engine subject to this r ule shall have a permanently affix ed plate, tag

, or marking listing:

a. the engine's make, model, and serial number; or

b. the owner‟s or operator's unique identification num ber.

The plate, tag, or marking shall be made accessible and legible.



### [Note 29: This section allows for expedited and efficient engine identification.]

2. Each engine shall be equipped with a nonresettable elapsed operating time meter and the meter

sha ll be maintained in proper operating condition.



### [Note 30: This is a recommendation from the ARB RACT/BARCT Determination.]

3

. Each engine shall be equipped with a nonresettable fuel meter or , where approved by the Control Officer in writing, an alternat ive device, method, or technique for determining fuel consumption. The fuel meter shall be calibrated periodically p ursuant to the recommendations of the

manufacturer and shall be maintained in proper operating condition.



### [Note 31: This is a recommendat ion from the ARB RACT/BARCT Determination. Alternative techniques must be approved by the Control Officer.]STAFF REPORT

- Regulation II/Rule 333 Page G

- 7

June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 7 April 17, 1997 [ Date of revised rule adoption ] 4. Engines in the following category shall be equipped with a continuous oxides of nitrogen and

oxygen monitoring system approved by the Control O fficer:

New engines rated at 1,000 brake horsepower or greater that:

a. are installed on or after [ date of revised rule adoption ] , and

b. are subject to the emission limits specified in Section E

, and

c

. have Permits to Operate allowing operation s in excess of 2,000 hours per year

.

This system shall determine and record exhaust gas oxides of nitrogen concentrations in parts per million by volume (dry) , corrected to 15 percent oxygen. The continuous monitoring system may

be a continuous emission s monitoring system or an alternative approved by the Control Officer.

A lternative s to a continuous emissions monitoring system must be submitted to and approved by

the Control Officer. Continuous emission monitoring systems shall meet the District Conti nuous Emission Monitoring Protocol (1992) and applicable federal requirements described in 40 CFR Part 60. These include the performance specifications found in Appendix B, Specification 2, the quality assurance requirements found in Appendix F, and the re porting requirements of Parts 60.7(c), 60.7(d), and 60.13.

The monitor ing system shall have data gathering and retrieval capability as approved by the

Control Officer

. All data collected by the monitoring system shall be maintained for at least two

years and made available for inspection by the Control Officer. Any Control Officer approved

c ontinuous monitoring system for oxides of nitrogen, carbon monoxide, and oxygen shall suffice in lieu of the quarterly monitoring required in Section F.3

.



### [Note 32: The continuous monitoring system provisions stem from the ARB RACT/BARCT Determination. Based on input from the regulated community, the APCD modified the provision to apply to only engines installed on or after the date of the revised rule adoption. Qu arterly NOx box testing will not be required for engines equipped with a continuous monitoring system approved by the APCO.]

D E

. Requirements

- Emission Limits

Owners or operators of engines shall meet the following requirements based on biennial sour ce testing, in accordance with the compliance schedule set forth in Section I K :



### [Note 33: The biennial source testing text is unnecessary because compliance with the emission limits is not based solely on source testing. Compliance determinations are

b ased on various methods, including portable analyzer tests, readings of parameters established to show compliance, “method” tests, and, possibly CEMs.]

1. Noncyclic Rich Rich

- Burn Noncyclically

- Loaded Spark Ignition Engines

a. The emission concentrati ons
, corrected for oxygen, from any such engine Rich burn noncyclic engines shall not exceed the following concentration limits corrected for oxygen :STAFF REPORT

- Regulation II/Rule 333 Page G

- 8

June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 8 April 17, 1997 [ Date of revised rule adoption ] Limit ( ppmV ppmv at 15 percent oxygen )

Pollutant 15% Oxygen 3% Oxygen

NOx 50 152

ROC 250 758

CO 4

, 500 13,653



### [Note 34: The APCD is specifying all emission limit figures corrected to 15% oxygen. Thus, all the references to 3% oxygen corrected figures are being dele ted. The limits

shown above are consistent with the ones listed in the ARB RACT/BARCT Determination (Table A

- 1) for the engine classification. However, emission limits in federal requirements (40CFR) may be more restrictive and supercede the less

stringe nt limits specified in Rule 333 for engines subject to the federal provisions.]

b. Rich burn noncyclic engines shall meet E ngines using either combustion modifications or

exhaust controls shall meet the oxides of nitrogen (NOx) requirements limit specif ied above, or the oxides of nitrogen (NOx) shall be reduced by at least 90 percent by mass of the

uncontrolled emissions across the control device

. For engines with exhaust controls, t he percent control shall be determined by measuring concurrently the o xides of nitrogen concentration upstream and downstream from the exhaust control. For engines without external control devices, the percent control shall be based on source test results for the uncontrolled engine and the same engine after the control dev ice or technique has been employed. In this situation, the engine‟s typical operating parameters, loading, and duty cycle shall be documented and repeated at each successive post

- control source test to ensure that the engine is meeting the percent reducti on limit. The parts per million by volume (dry) limits for reactive organic compounds and carbon monoxide apply to all engines.



### [Note 35: The alternative compliance method of meeting at least a 90 percent NOx reduction for engines using combustion modi fications or exhaust controls is consistent with the ARB RACT/BARCT Determination (Table A

- 1).]

2. Noncyclic Lean Lean

- Burn Spark Ignition Engines

a. The emission concentrations, corrected for oxygen, fr om any such engine Lean burn noncyclic engine s shall not exceed the following limits as corrected for oxygen :

Any engine with a rated brake horsepower of 50 or greater but less than 100:

Limit (ppmv at 15 percent oxygen )

Pollutant

NOx 200

ROC 750

CO 4,500



### [Note 36: Including “spark ignition” in the description stems from an EPA

- identified rule deficiency. In the 1994 Technical Support Document for Rule 333, EPA indicated that it is unclear if diesel engines must comply with the 125 ppm limit given for lean burn engines or the 797 ppm limit.] See Note

37. See Note

36.STAFF REPORT

- Regulation II/Rule 333 Page G

- 9

June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 9 April 17, 1997 [ Date of revised rule adoption ]



### [Note 37: The emission limits for this range of lean

- burn spark ignition engines are consistent with those in the ARB RACT/BARCT Determination. However, emission limits in federal requirem ents (40CFR) may be more restrictive and supercede the

less

- stringent limits specified in Rule 333 for engines subject to the federal provisions.]

Any engine with a rated brake horsepower of 100 or greater:

Limit ( ppmV ppmv at 15 percent oxygen )

Po llutant 15% Oxygen 3% Oxygen

NOx 125 380

ROC 750 2

, 275

CO 4

, 500 13,653

b. Lean burn engines shall meet Any engine with a rated brake horsepower of 100 or gre ater using either combustion modifications or exhaust controls shall meet the oxides of nitrogen (NOx) requirements specified above, or the oxides of nitrogen (NOx) shall be reduced by

at least 80 % percent by mass of the uncontrolled emissions across the c ontrol device

. For engines with exhaust controls, t he percent control shall be determined by measuring concurrently the oxides of nitrogen concentration upstream and downstream from the

exhaust control. For engines without external control devices, the p ercent control shall be based on source test results for the uncontrolled engine and the same engine after the control device or technique has been employed. In this situation, the engine‟s typical operating parameters, loading, and duty cycle shall be do cumented and repeated at each successive
post

- control source test to ensure that the engine is meeting the percent reduction limit. The parts per million by volume (dry) limits for reactive organic compounds and carbon

monoxide apply to all engines.



### [N ote 38: The limits and provisions for lean

- burn spark ignition engines rated at 100 brake horsepower or greater are consistent with the ARB RACT/BARCT Determination (Table A

- 1). However, emission limits in federal requirements (40CFR) may be more restri ctive and supercede the less

- stringent limits specified in Rule 333 for engines subject to the federal provisions.]

3. Cyclic Rich

- Burn Cyclically

- Loaded Spark Ignition Engines

a. On or before March 2, 1992 the owner or operator of cyclic engines shall m aintain an exhaust stream oxygen concentration of 6.5 percent or greater, by volume. Owners or operators of cyclic engines shall comply with the following:

i. An initial source test shall be performed within twelve months from December 3,

1991 for each e ngine. Subsequent source tests shall be performed in accordance with Section G.; and

ii. The exhaust stream oxygen concentration shall be monitored on a monthly basis utilizing a portable analyzer or any other method approved by the Control Officer.

The instrument reading shall be recorded as set forth in Section H.

b. The e mission concentrations

, corrected for oxygen, from any such engine Cyclic engines shall not exceed the following limits , in accordance with Section I. :STAFF REPORT

- Regulation II/Rule 333 Page G

- 10

June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 10 April 17, 1997 [ Date of revised rule adoption ] Limit ( ppmV ppmv at 15 percent oxygen )

Pollutant 15% Oxygen 3% Oxygen

NOx 50 300 152

ROC 250 758

CO 4

, 500 13,653



### [Note 39: Consistent with the ARB RACT/BARCT Determination and to address ARB concerns, the APCD is revising the engine classification terms and the NOx emission limit. Emission limits in federal requirements (40CFR) may be more restrictive and supercede the less

- stringent limits specified in Rule 333 for engines subject to the federal provisions,. The APCD is also deleting text that is no longer pertinent.]

Alternatively, NOx emissions may be reduced by at least 90% of the uncontrolled emissions

across the control device.



### [Note 40: There is no percent control of NOx pr ovision recommended for this engine classification in the ARB RACT/BARCT Determination.]

c. In lieu of D.3.a. and D.3.b. above, an engine owner or operator may choose for any cyclic engine to comply with Section D.1. of this rule by designating the cyclic engine as a noncyclic engine for the purposes of this Rule. In this case the owner or operator shall notify the District in writing on or before March 2, 1992 which cyclic engines will be designated as noncyclic engines. These engines shall be included as part of the compliance plan as set

forth in Section F.



### [Note 41: The APCD is deleting the above text because it is no longer pertinent and to address ARB concerns.]

4. Compression Ignition Engines and Dual

- Fuel Engines

a. The emission concentrat ions, corrected for oxygen, fr om any such engine Diesel engines

shall not exceed 8.4 grams per brake horsepower

- hour of oxides of nitrogen or the following limits as corrected for oxygen :

Limit ( ppmV ppmv at 15 percent oxygen )

Pollutant 15% Oxygen 3% Oxygen

NOx 797 700 2,400

ROC 750

CO 4,500



### [Note 42: EPA pointed out that the 8.4 grams per brake horsepower hour NOx limit equates to about 670 ppmv at 1 5% O2 (assuming 35% efficiency), not the rule’s 797 ppmv NOx at 15% O2 limit. Thus, the deletion of the 8.4 grams per brake horsepower hour limit will eliminate the consistency problem.]

[Note 43: The APCD is basing the new NOx and ROC limits on the Sac ramento Metropolitan AQMD Rule 412 limits and the CO limit on the Ventura County APCD Rule 74.9 limit. The 700 ppmv NOx at 15% oxygen limit is considered a reasonably See Note

42.

See Note 42. See Note

43. See Note

44.STAFF REPORT

- Regulation II/Rule 333 Page G

- 11

June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 11 April 17, 1997 [ Date of revised rule adoption ]



### available control technology (RACT) limit. The APCD is proposing RACT limits to

fulfill EPA requirements. However, the NOx emission limits in the Airborne Toxic Control Measure for Stationary Compression Ignition Engines (California Code of Regulations, Title 17, Section 93115) are more restrictive and, for engines subject to the statute, s upercede the less

- stringent limit specified in Rule 333. Also, emission limits in federal requirements (40CFR) may be more restrictive and supercede the

less

- stringent limits specified in Rule 333 for engines subject to the federal provisions.]

[Note 44: ARB pointed out that there was confusion over whether the ROC and CO limits in Sections 333.D.1 or D.2 applied to diesel engines. They suggested that if diesel engines had no ROC or CO limits, this should be stated explicitly in Section

333.D.4. With t he addition of the ROC and CO limits, the APCD has addressed this concern.]

b. Engines using either combustion modifications or exhaust controls shall meet the oxides of nitrogen limit specified above

, or the oxides of nitrogen shall be reduced by at leas t 40 percent by mass of the uncontrolled emissions. For engines with exhaust controls, the percent control shall be determined by measuring concurrently the oxides of nitrogen concentration upstream and downstream from the exhaust control. For engines wi thout external control devices, the percent control shall be based on source test results for the uncontrolled engine and the same engine after the control device or technique has been employed. In this situation, the engine‟s typical operating parameters , loading, and duty cycle shall be documented and repeated at each successive post

- control source test to ensure that the engine is meeting the percent reduction limit. The parts per million by volume (dry) limits for reactive organic compounds and carbon monoxide apply to all engines.



### [Note 45: The APCD is basing the 40 percent NOx reduction figure on the AP

- 42 NOx emission factor for uncontrolled compression ignition engines rated less than 600 brake horsepower (Table 3.3

- 1) and the new 700 ppmv limit. (The inventory has no compression ignition engines rated greater than 600 bhp that are subject to Rule 333.)]

5. Alternative Emission Control Plan (AECP)

An owner or operator of any existing engine subject to this rule may meet the NO

x emission cont rol requirements of Sections D.1, D.2, and D.3.b, by controlling additional existing engines at the same stationary source, which are not otherwise subject to this rule, provided the owner or operator submits

an Alternative Emission Control Plan that is en forceable by the District and is approved in writing by the Control Officer, ARB and EPA prior to implementation.

Any Alternative Emission Control Plan must be submitted by March 9, 1992.

The Alternative Emission Control Plan shall:

a. Include all information determined by the Control Officer as necessary to confirm that the requirements of this section will be met.

b. Include the control of all engines 20 horsepower and larger at the stationary source. All engines shall be controlled consisten t with the applicable schedule specified in Section I.

c. Achieve at least 20 percent more tonnage of NOx emission reductions than otherwise required by Sections D.1, D.2 and D.3.b. The required tonnage of emission reductions shallSTAFF REPORT

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Santa Ba rbara County APCD Rule 333 333

- 12 April 17, 1997 [ Date of revised rule adoption ] be calculated using a 90% (80% for lean burn engines) reduction from an uncontrolled emission factor of 2,000 lbs of NOX/MMSCF fuel used, with the baseline fuel usage calculated in accordance with Rule 802.F.2. When engine specific fuel usage is not available, fuel use data will be apportioned to individual engines based on their estimated utilized horsepower, following a method approved by the Control Officer.

d. Specify NO

x , ROC and CO ppmv emission limits for each engine. NO

x ppmv limits for each engine shall be equal to or less than that emitted from the engine when the exhaust stream oxygen concentration is set at the maximum percentage achievable while maintaining stable engine operation. The ROC and CO ppmv limits specified in Sections D.1, D.2 and

D.3.b. shall not be exceeded. All engines included in the AECP shall be included as non

exempt engines on District permits with these emission limits specified.

e. Calculate the uncontrolled emission factor for engines 20 to 49 horsepower by measuring the

NO

x emission s in accordance with Section G. (except the test shall be conducted for 30 minutes) with the exhaust stream oxygen concentration adjusted to 2 percent or greater by volume. Baseline fuel usage for these engines shall be calculated as specified above.

f. Calculate the tonnage of emission reductions achieved to meet the requirements of Section D.5.c. by subtracting the controlled emission rate from the uncontrolled emission rate. The controlled emission rate shall be calculated using the controlled engi ne NO

x ppmv limit and the baseline fuel usage. The uncontrolled emission rate shall be calculated as specified in Section D.5.c for engines 50 horsepower and over and Section D.5.e for engines 20 to 49 horsepower.

g. Provide that emission reductions fo r any engine required under Regulation VIII shall not be used to reduce the emission reductions required of any other engine.

h. Include engine specific fuel usage monitoring, and other continuous monitoring on each engine determined necessary by the Co ntrol Officer to confirm continuous compliance with the required pollution reductions.

i. Exempt from the requirements of Section G and D.5.h., any 20 to 49 horsepower engines whose control is not required to meet the obligations established under Secti on D.5.c. These engines must, however, meet all other requirements in the rule, including requirements in Section E. The AECP shall specify any engines subject to this exemption.

j. Insure compliance with all other provisions of this rule, including b ut not limited to D.3.a,

D.4 and D.5.

The AECP may be modified at a future date to incorporate equivalent replacement engines which meet the requirements of Rule 202.D.9. The emission limit for the new engine shall be the same as for the replaced engin e.

All District costs for the review and enforcement of the AECP and for District participation in any field studies shall be reimbursed under the cost reimbursement provisions of Rule 210.

A violation of the AECP shall be a violation of this rule an d any applicable permit.



### [Note 46: The deletion of the entire Alternative Emission Control Plan section is consistent with a recommendation by EPA and will eliminate an outdated provision. The March 9, 1992 deadline for submitting an AECP has passed, n o sources ever submitted an AECP, and no such plans are currently in effect.]STAFF REPORT

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Santa Ba rbara County APCD Rule 333 333

- 13 April 17, 1997 [ Date of revised rule adoption ] 6 5

. The use of anhydrous ammonia to meet the requirements of this rule is prohibited unless case

- specific analysis indicates that the use is acceptable to the Control Officer

.



### [Note 47: Adding the case
- specific provision will allow future analysis (including CEQA analysis) to address the acceptability of using anhydrous ammonia for a control technique.]

E F

. Requirements

- Owner or Operator Engine Inspection s and Maintenance Plan

All Any engine s subject to the requirements of Section D E shall be inspected by the engine owner or operator

in accordance with a District District

- approved engine Engine inspection Inspection and maintenance

Maintenance plan Plan for each stationa ry source

. which The owner or operator shall meet the following requirements for the Plan in accordance with the compliance schedule specified in Section K :

1. The plan shall be submitted to the District by March 2, 1992

. Obtain the Control Officer‟s approval

of the Plan. A n Inspection and Maintenance Plan for each stationary source shall be submitted to the District in a format approved by the Control Officer

.



### [Note 48: Per the recommendations in the ARB RACT/BARCT Determination, engine owners and operators are to implement an Inspection and Maintenance Plan (I&M Plan) as part of the Emission Control Plan requirements. Section K.2.d.ii.1) requires the owners and operators of any existing engine subject to the emission limits

to submit a new/revised I&M Plan no later than six months from the date of the revised rule adoption.]

2. Such plan shall list List all engines by engine classification , identified as either cyclics ( rich

- burn noncyclically

- loaded spark ignition

, rich

- burn cyclically

- loaded spa rk ignition, lean

- burn spark ignition, and noncyclics compression ignition , or dual

- fuel )

, and identify the method, engine and control equipment operating parameters parameter ranges , and compliance values , including engine exhaust oxygen con c entration range s, to be used to verify compliance with Section D E

.



### [Note 49: The ARB RACT/BARCT Determination recommends that engine owners and operators establish ranges for control equipment parameters, engine operating parameters, and engine exhaust oxygen concentra tions that source testing has shown results in pollutant concentrations within the rule limits. This data will be used during the inspections required by the I&M Plan to ensure that the equipment is operating correctly.]

3. The plan shall require a mini mum of one inspection for each engine every calendar quarter

. The readings for each parameter identified in E .2

. shall be recorded pursuant to Section H

.



### [Note 50: The current “quarterly inspection and monitor reading recordkeeping” requirements of Subs ection 3 are being integrated into other sections. Hence, the current provisions in Section 3 are deleted and Subsection 4 will be renumbered as 3.]STAFF REPORT

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[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 14 April 17, 1997 [ Date of revised rule adoption ] 4 3

. A portable NOx emissions analyzer or any other method approved by the Control Office r shall be

used to take NOx oxides of nitrogen and carbon monoxide emission readings and engine exhaust oxygen concentration readings to determine compliance with the emission limits or percent control specified in Section D E during which any quarter (or month , if performing monthly monitoring) in which a source test is not performed under Section G I and an engine is operated in excess of 20 hours
per quarter

. If such an engine cannot be operated for portable analyzer emissions testing due to

mechanical failure or lack of fuel, the monitoring requirement may be waived provided written Control Officer approval is obtained prior to the end of the quarter (or month , if performing monthly monitoring)

. All emission readings shall be taken at an engine‟s typic al duty cycle. The results shall be recorded pursuant to Section H

. The analyzer shall be calibrated, maintained, and operated in accordance with the manufacturer‟s specifications and recommendations or a Control Officer approved protocol. The applicable control equipment parameters and engine operating parameters will be inspected and monitored in conformance with a regular inspection schedule listed in the P lan.

A n portable analyzer instrument reading in excess of the emission compliance values shall no t be

considered a violation of this rule , so long as the problem is corrected engine is brought into compliance and a follow

- up inspection is conducted within 15 days of the initial inspection out

- of

compliance reading

. If an engine owner or operator or di strict staff find an engine to be operating outside the acceptable range for control equipment parameters

, engine operating parameters

, engine

exhaust oxides of nitrogen or carbon monoxide concentrations

, the owner or operator shall bring the engine into c ompliance within 15 days. Also, when there has been a portable analyzer instrument reading in excess of the emission compliance value or a source test result in excess of an emission

limit or less than the percent control requirement , the inspection and m aintenance monitoring schedule will be performed on a monthly basis and continue to be monthly until Rule 333 compliance is demonstrated in three consecutive months (by portable analyzer or source tests).



### [Note 51: The text on “NOx Analyzer” is being rev ised to be “emissions analyzers” to take into account that the instrument needs to measure NOx, CO, and the oxygen concentration to provide compliance data corrected for oxygen. The or any other method approved by the Control Officer text is being deleted to simplify the rule. Exhaust oxygen concentrations need to be determined to correct the NOx and CO emission readings to the 15% O2 standard.]

[Note 52: The APCD is proposing that the inspections required by I&M plans continue to be on a quarterly ba sis. However, if the engine or its control equipment is found to be operating outside an acceptable range, parameter, or NOx/CO emission limit, the monitoring frequency will be changed to a monthly basis. The monthly frequency will continue until there a re three months of monitoring results demonstrating compliance.]

[Note 53: The in excess of 20 hours per quarter provision is added to waive the monitoring requirements for engines that have low usage or that are out of service. Also, owners and operat ors of engines encountering mechanical failures or lack of fuel may seek a waiver on the monitoring requirement. The APCD added these provisions based on input from Industry.]

[Note 54: During an annual or biennial comprehensive source test, it is the A PCD practice to test emission units at the maximum load feasible. At a minimum, source test loads must reflect loads representative of typical operations. For a monthly or quarterly I&M, the APCD will accept tests performed at an engine’s typical duty

cy cle.] See Note

51.

Se e Note

52.

See Note

52. See Note

53.

See Note

54.

See Note

55.

See Note

56.

See Note

57.STAFF REPORT

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June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 15 April 17, 1997 [ Date of revised rule adoption ]



### [Note 55: This text is from the ARB RACT/BARCT determination (except the reference to monthly monitoring was removed).]

[Note 56: These text changes are made for clarity.]

[Note 57: This provision is added to clarify that there is a 15

- day peri od to bring a noncompliant engine into compliance.]

The results and instrument readings for each engine and control equipment operating parameter
identified in the inspection plan Inspection and Maintenance Plan

, the analyzer instrument readings, a descri ption of the corrective actions taken, a determination of whether or not the engine is in compliance, and the initials name of the person recording the measurement information shall be

recorded on in an inspection log consistent with the recordkeeping prov isions specified in Section J .1

.



### [Note 58: The APCD is changing the provision from recording initials to name to improve accountability. Also, the cross

- reference to the recordkeeping provisions in Section J.1 is included for consistency.]

4

. I nclude preventive and corrective maintenance procedures. Before any change in operations can be implemented, the P lan must be revised as necessary, and the revised P lan must be submitted to and approved by the Control Officer.



### [Note 59: The new number 4 and pl an change provisions are consistent with those specified in the ARB RACT/BARCT Determination (§VII.A(2)).]

F G

. Requirements

- Compliance Plan



### [Note 60: The ARB RACT/BARCT Determination recommends that engine owners and operators subject to the emission limits submit an “Emission Control Plan.” These plans are what the APCD refers to as a “Compliance Plan” in Rule 333.

A compliance The owner or operator of an y engine subject to the emission limits in Section E shall submit and

obtain the Control Officer ‟s approval of a Compliance plan Plan

. A new or revised Compliance Plan for each stationary source shall be submitted to the District in a format approved by the Control Officer in accordance

with the time schedule specified in Section I.2. K unless otherwise specified by the Control Officer

. or I.3. to
the District for each stationary source The C ompliance P lan shall describe all actions, including a schedule of increments of progress, which will be taken to meet the applicable emissions limitation s in Section E and the compliance schedule in Section K. The owner or operator shall ensure that the C ompliance P lan meets the following requirements and shall include :



### [Note 61: The APCD added the any engine subject to the emission limits in Section E text to clarify that only engines subject to the Rule 333 emission limits require a Compliance Plan.]

[Note 62: This language is included to allow APCO discretion on the submittal of revised I&M and Compliance Plans.]

[Note 63: This is the same text fo und in the ARB RACT/BARCT Determination (§VII.A(1)).] See Note

61.

See Note

62.

See Note

63.STAFF REPORT

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[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 16 April 17, 1997 [ Date of revised rule adoption ] 1. a l L ist of all engines with by classification ( rich

- burn noncyclically

- loaded spark ignition, rich

- burn cyclically

- loaded spark ignition, lean

- burn spark ignition, compression ignition , or du al

- fuel), make, model, serial number (or owner‟s/ operator's ID number), rated brake horsepower and

associated RPM , type of fuel (including higher heating value and percent or ppm parts per million by volume (dry) sulfur), engine application, maximum total hours of operation per in the previous year, typical daily operating schedule, fuel consumption (cubic feet of gas or gallons of liquid) for the previous one year period, engine location and engine PTO Permit to Operate number (if applicable) ;

. and



### [Note 6 4: Specifying the engine classification is important to establish the applicable Rule 333, Section E emission limits.]

[Note 65: The APCD is adding owner’s on the engine identification provision for consistency with Rule 333.D.1.]

[Note 66: Providing the information for each engine is consistent with a recommendation in the ARB RACT/BARCT Determination.]

2. List manufacturer

- tested typical emission rates or source test values, if available or documentation showing existing emissions of oxides of nitr ogen, reactive organic compounds, and carbon

monoxide ;

. and



### [Note 67: The ARB RACT/BARCT Determination, Section VII.A(1)(k) recommends that the documentation on the existing emissions of NOx, VOC, and CO be provided.]

3. List the applicable emission lim its

.



### [Note 68: Reference the ARB RACT/BARCT Determination, Section VII.A(1)(j).]

3 4

. List the type of emission control device or method for each engine, and the temperature and flow rate of the exhaust gas, and any auxiliary devices used with the main control device (i.e., air

- to

- fuel ratio controller, exhaust gas monitor, etc.), and the proposed installation completion date for each engine to

be controlled , stack modifications to facilitate continuous in

- stack monitoring and source testing

.



### [Note 69 : Providing the stack modification data is consistent with the ARB RACT/BARCT Determination, Section VII.A(1)(i).]

5. A n Engine I nspection and M aintenance P lan , as specified in Section F, or a t a minimum, a reference

to an d a statement incorporating the Engine I nspectio n and M aintenance P lan into the C ompliance

P lan

.



### [Note 70: Section VII.A(2) of the ARB RACT/BARCT Determination recommends that the Emission Control Plan include the I&M Plan.]

4 6

. List of all existing and operating engines planned for shutdown or electrification and the proposed

date of shutdown or electrification.



### [Note 71: The and operating engine text is no longer used in this rule.]

An owner or operator may modify a compliance Compliance plan Plan by submitting a modified plan t o the

District at least thirty ( 30 ) calendar days prior to modifying the equipment

, or control method or compliance See Note

64.

See Note

65.

See Note

66.STAFF REPORT

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[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 17 April 17, 1997 [ Date of revised rule adoption ] date for any engine. Modification of a compliance plan shall not alter the schedule of controlled horsepower required in Section I

.

Appro val of a compliance Compliance plan Plan does not relieve the owner or operator of engine(s) from the permitting requirements of District Rule 201.



### [Note 72: These changes are made for consistency with other parts of the rule and for improved rule clarit y.]

H. [Reserved]



### [Note 73: A previously proposed Section H covered the requirements for a Heat Input Verification Plan, which was integral to an earlier proposed Section B.3 exemption. The APCD proposed requirements to demonstrate that an engine rated greater than 50 brake horsepower operates at all times below 50 brake horsepower. After discussing the need for the exemption, Industry and APCD staff decided that the proposed exemption and its related plan could be deleted. Rather than revise the

prev iously assigned alphabetical designations of the successive rule sections, the APCD elected to simply “reserve” Section H.]

G I

. Requirements

- Source Testing

The owner or operator of any engine subject to the requirements of Section E shall comply with the following:



### [Note 74: The APCD added the lead

- in sentence to clarify that only engines subject to the Rule 333 emission limits are subject to the source testing provisions.]

1. Source test plans Except as otherwise provided in Section I. 8

, a n initial emissions source test shall be performed on each stationary internal combustion engine to verify compliance with Section E. A After the initial source test, source test s shall be performed biennially to demonstrate compliance with

Section D E

. S Th ese s ource tests shall be performed within 30 calendar days of the anniversary date of the initial source test, unless the Control Officer approves a period longer than thirty ( 30 ) calendar days. Emissions source testing shall be conducted at an engine's maximum achievable load or, at a minimum, under the engine's typical duty cycle as demonstrated by historical operational data. Source test loads shall be finalized in the source test plan approved by the District per Section I.2

. For facilities with mor e than 20 engines subject to Section E requirements, the Control Officer may,

on a case

- by

- base basis, approve a source‟s written request to exclude one or more engines from

biennial test ing. Such a request shall be submitted with the Plan required in Sec tion I. 2

.



### [Note 75: Section VII.B(1)(c) of the ARB RACT/BARCT Determination recommends that the source testing requirements include a provision on an initial source test.]

[Note 76: These provisions are currently in existing Rule 333, Section G.1.b. Staff relocated the 1.b biennial source testing requirements into the above paragraph and renumbered the subsections.]

[Note 77: The maximum achievable load or typical duty cycle have historically been addressed in the permit conditions and determined d uring the Source Test Plan review process.] See Note

75.

See Note

76.

See Note 77.STAFF REPORT

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[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 18 April 17, 1997 [ Date of revised rule adoption ] 2. a. An owner or operator of any engine shall A source test plan shall be submit ted to the District

and obtain the Control Officer's approval of a source test plan shall be obtained prior to the start of a

so urce test . The approved plan shall be on file d with the District at least thirty ( 30 ) calendar days

before the start of each source test ing . The District shall be notified of the date for source testing an engine at least fourteen ( 14 ) calendar days prio r to testing to arrange a mutually agreeable test date. In addition to other information, the source test plan shall describe which critical parameters will be measured, and how the ranges for these parameters shall be established and incorporated into th e Engine Inspection and Maintenance Plan described in Section F.



### [Note 78: These requirements are consistent with provisions recommended in the ARB RACT/BARCT Determination, Section VII.B(1)(c).]

b. A source test shall be performed biennially to dem onstrate compliance with Section D. Source tests shall be performed within 30 calendar days of the anniversary date of the initial source test, unless the Control Officer approves a period longer than thirty (30) calendar days.



### [Note 79: The APCD moved the biennial source testing frequency provision into Section I.1, above.]

3. c. Source testing shall be performed by a source test contractor certified by the California Air

Resources Board. District required S s ource testing shall not be performed by a source owner or operator unless approved by the Control Officer.



### [Note 80: These changes are made for clarity.]

4. For each source test performed, a Source Test Report shall be submitted to the District within 45 days of completing the test. Reactive Organic Compounds, oxides of nitrogen, and carbon monoxide concentrations shall be reported in parts per million by volume , corrected to 15 percent oxygen. For engines using either combustion modifications or exhaust controls , oxides of nitrogen shall be reported as a percent reduction from the combustion modification or control device.



### [Note 81: This is being added for clarity]

5. d. The owner or operator of For any engine which that is found not to be in compliance with

Section D E

. as a result of sou rce testing

, shall comply with the following shall apply :

a. i. A r R epeat a source test shall be performed to demonstrate compliance with Section

D. E within the time period specified by the District.

b. ii. Notwithstanding the provisions of Section G.1.b. I.1 , annual source tests shall be conducted on any noncompliant engine until two consecutive annual tests demonstrate the engine is in compliance with Section D E . When the engine is demonstrated to be compliance with Section D E by two consecutive annual source tests, the engine shall comply with the provisions of Section G.1.b I.1

.



### [Note 82: These changes are made for consistency with other parts of the rule and for improved rule clarity.]

2 6

. Engine operating parameters (e.g., timing, manifold vacuum pressure, valve set points, etc.) shall be established using the results of the source test carried out pursuant to Section G I.1

.

3 7

. Test MethodsSTAFF REPORT

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[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 19 April 17, 1997 [ Date of revised rule adoption ]

a. Source testing shall be performed in accordance with the following procedures:

NOx, CO, O 2 : CARB Method 1

- 100

ROC: EPA Method 18 or EPA Method 25

i. Stack gas oxygen: Environmental Protection Agency Method 3A or Air Resources

Board Method 100.

ii. Nitrogen oxides: Environmental Protection Agency Method 7E or Air Resources

Board Method 100.

iii. Carbon monoxide: Environmental Protection Agency Method 10 or Air Resources

Board Method 100.



### [Note 83: In ARB’s 1992 comments on Rule 333, ARB recommended that the source test method be changed from CARB Method “1

- 100” to “100.” Including the alternative EPA Methods 3A, 7E, and 10 is consistent with the ARB RACT/BARCT Determination.]

iv. Reactive organic compounds: Environmental Protection Agency Method 18 with gas chromatography

- flame ionization detection speciation analysis for C1, C2, C3, C4, C5, C6+ species.



### [Note 84: ARB pointed out that the rule should require the EPA Method 25 (for determination of total organics) “and” the EPA Method 18 (for determination of exempt compounds), not “or” as currently written. ARB’s basis for this recommendation was that the two EPA methods are not alternatives; they are used in combination to determine ROC emissions corrected for exempt compounds (non

ROCs).

The APCD has chosen EPA Method 18 as it allows for subtracting “exempt compounds” from t he total organic compound measurement.]

v. Pollutant Mass Emission Rate (e.g., pounds per hour) : Calculated from stack flow rate data obtained by either 1) the Environmental Protection Agency Methods 1 through 4, or 2) the Environmental Protection Agen cy exhaust concentration, fuel flow and fuel composition data as per EPA Method 19 , Sections 2.1 and 3.2.1. stack flow rate F factor (ratio of combustion gas volume to heat input), using fuel flow and fuel composition data.



### [Note 85: The pollutant mass emission rate test methods data is being relocated here to group the “method” tests together.]

v i

. Fuel rate: Appropriate District

- approved metering system, calibrated within 60 days of the test date. Public utility company regulated utility fuel me ters relied on by operators for testing may be allowed an alternative calibration schedule per the Control Officer‟s discretion. Results must be corrected for temperature and pressure ( standard conditions of 60°F and 29.92 inches of Mercury

.STAFF REPORT

- Regulation II/Rule 333 Page G

- 20

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[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 20 April 17, 1997 [ Date of revised rule adoption ]



### [Note 86: A dding District

- approved clarifies that the metering system needs to meet the APCD’s standards. Some sources rely on PUC meters, which are calibrated under different schedules with rigorous protocols. Thus, the APCD may allow the

calibration window to ext end beyond 60 days before the source test for such meters.

The text on temperature and pressure is not necessary as the standard condition definition in Rule 102 defines them.]

v i i. Determination of the Fuel Composition and Higher Heating Value : The following

a pplicable standards developed by ASTM International : ASTM Method

1) ASTM D

- 1945

- 81 03

, “Standard Test Method for Analysis of Natural Gas by Gas Chromatography

, ” ASTM International

,

2) ASTM Method D

- 3588

- 81 98 (2003)

, “Standard Practice for C alculating Heat Value, Compressibility Factor , and Relative Density of Gaseous Fuels, ” ASTM International

, and

3) ASTM Method D

- 1072

- 80

. 06

, “Standard Test Method for Total Sulfur

in Fuel Gases

, ” ASTM International,

4) ASTM D 240

- 02 (2007) , “Standard Te st Method for Heat of Combustion of Liquid Hydrocarbon Fuels by Bomb Calorimeter,”

ASTM International

,

5) ASTM D 4809

- 06 , “Standard Test Method for Heat of Combustion of Liquid Hydrocarbon Fuels by Bomb Calorimeter (Precision Method),”

ASTM International

, and

6) ASTM D 1826

- 94 (2003) , “Standard Test Method for Calorific (Heating) Value of Gases in Natural Gas Range by Continuous Recording Calorimeter,” ASTM International

.

The Control Officer may approve in writing alternative methods for determining

the fuel composition or fuel higher heating value.



### [Note 87: The APCD has included ASTM International methods typically used for fuel composition and the fuel’s HHV analysis. The last provision on the APCO

approved alternative methods is included to allow u se of other ASTM International methods or other similarly acceptable methods that a source may propose.]

Pollutant Emission Rate: Calculated from exhaust concentration, fuel flow and fuel composition dataas per EPA Method 19, Sections 2.1 and 3.2.1.



### [ Note 88: The pollutant mass emission rate provision is moved to Section I.7.a.v and it is being modified for improved rule clarity.]

b. The Control Officer may approve in writing an alternative source test method provided that

such method is comparable in accuracy to the procedure in G.3.a I.7.a and has been approved by the ARB Air Resources Board and the EPA Environmental Protection Agency

.



### [Note 89: These changes are made for consistency with other parts of the rule and for improved rule clarity.]STAFF REPORT

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[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 21 April 17, 1997 [ Date of revised rule adoption ]

c. At a minimum, three 30 minute test runs shall be performed, and the average concentration from the three runs shall be used for determining compliance unless alternative provisions are specified in an approved source testing plan.



### [Note 90: The ARB RA CT/BARCT Determination for Spark Ignition Engines specifies the following when indicating the RACT and BARCT limits:

[. . .] emissions, corrected to 15 percent oxygen on a dry basis and averaged over 15 minutes, shall not exceed the following limits for the appropriate engine type:

However, based on industry input, the APCD agreed to use a 30 minute averaging time instead of the 15 minute period recommended by ARB.]

8

. Initial and biennial source testing requirements shall not be applicable to any comp ression ignition engines that are subject to an exhaust emission standard in the:

a. California Code of Regulations, Title 13, Section 2423, for off

- road engines, or

b. 40 CFR, Part 89, for nonroad compression ignition engines.

However, a source t est shall be triggered for such engine if the result from a portable analyzer emissions monitoring reading (e.g., a result obtained during the monitoring required by Section F.3 ) exceeds a threshold of 560 parts per million of oxides of nitrogen at 15 perc ent oxygen, unless the engine is brought into compliance with this threshold value and a follow

- up portable analyzer monitoring inspection is conducted within 15 days of the initial over

- the

- threshold reading.

The owner or operator of the engine shall p rovide written notification to the Control Officer within two business days of a portable analyzer emissions monitoring reading in excess of the 560 parts per million of oxides of nitrogen at 15 percent oxygen threshold. In addition, portable analyzer

mon itoring results shall be reported to the APCD within three business days of any follow

- up quarterly portable analyzer monitoring.

Source testing of a Tier 1, 2, 3 or 4 engine, if triggered per the above criteria, shall be completed within 60 days of the initial over

- the

- threshold reading and shall comply with Sections I.2, I.3, I.4, I.5.a, and I.7.

Any compression ignition engine that triggers a source test, and demonstrates compliance with the oxides of nitrogen standard in Section E.4, shall not be subject to another source test for two years from the date of the initial compliant source test. Any compression ignition engine that does not comply with the oxides of nitrogen standard in Section E.4 based on any source test, shall thereafter be subject to source testing on a biennial schedule starting from the date of the initial failed source

test.



### [Note 91: The new Section I.8 provisions are being added to provide an exemption to diesel engines complying with the ARB/EPA tier limits. By adding th is exemption for the ARB/EPA tiered engines, the APCD avoids requiring source tests on these engines.]

[Note 92: The APCD decided on the 560 ppmv at 15 percent oxygen threshold since this level indicates the NOx Tier certification is not holding, and e missions levels could potentially be above the applicable emission limit considering the uncertainty of the portable analyzer.] See Note

92.STAFF REPORT

- Regulation II/Rule 333 Page G

- 22

June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 22 April 17, 1997 [ Date of revised rule adoption ] H J

. Recordkeeping

1. The owner or operator of any engine subject to the requirements of this rule Section E shall maintain a

written engine Engine operation Operation, Inspection, and Maintenance log Log containing the following information for each engine subject to an emission limit :



### [Note 93: The APCD added the subject to the requirements of Section E text to clarify

that only engines subject to the Rule 333 emission limits are subject to the Engine Operation, Inspection, and Maintenance Log requirements.]

a )

. Engine classification ( rich

- burn noncyclically

- loaded spark ignition, rich

- burn cyclically

loaded spark ignition

, lean

- burn spark ignition

, compression ignition, or dual

- fuel ), make, model, and serial number or the owner‟s or operator‟s unique identification number.



### [Note 94: Indication of the engine’s classification, make, model, and serial number or

the owner’s/ operator’s unique ID number is important for tracking purposes. (If the owner or operator chooses to use the APCD’s device identification number that

would suffice to fulfill the owner’s or operator’s unique identification number requirement.)]

b. h H ours of operation , as determined by a nonresettable elapsed operating time meter, each month for each engine since the last inspection ;

.



### [Note 95: Proposed amended Rule 333, Section D.2, requires that each engine subject to the rule be equipped with a nonre settable elapsed operating time meter. The each

month recording frequency is being changed to since the last inspection because the I&M Plan monitoring frequency is quarterly for compliant engines.]

b ) c. l L ocation and hours of engine operation of the e ngine a s determined by an hour meter for each engine which operates less than 200 hours per calendar year

.



### [Note 96: The recordkeeping provision on the operating hours for engines operating less than 200 hours per year is being moved to a separate sectio n (Rule 333.J.3). Thus, the text is being deleted from the above section.]

c ) d. a A summary of any maintenance performed on an emission control device ;

.

d ) e. a A summary of any maintenance performed on an engine which that affects the emission

contr ol device

. ; and

,

e ) f. the o O bservations made in during each monthly or quarterly inspection, pursuant to the requirements of Section E F .3

.



### [Note 97: The changes in the above three sections are made for consistency with other parts of the rule and fo r improved rule clarity.]

g. Date of each log entry and the printed or typed name of the person entering the log

information

.



### [Note 98: Documenting the date of each log entry is important for verifying compliance with the Section F.3 periodic I&M monito ring requirement. RequiringSTAFF REPORT

- Regulation II/Rule 333 Page G

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June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 23 April 17, 1997 [ Date of revised rule adoption ]



### that the person performing the monitoring/inspection print or type their name is needed to ensure accountability.]

h. For every engine that has been relocated, a notation to that effect identifying both the present and prior l ocatio n, the reason(s) for the engine relocation, and the elapsed operating time meter readings for both the relocated engine and the engine being displaced.



### [Note 99: Details on relocated and displaced engines help verify compliance with

Permit conditio ns.]

2. Copies of all engine Engine Operation, inspection Inspection

, and maintenance Maintenance logs Logs

shall be retained by the operator for a minimum of 2 years after the date of the last entry and shall be available to the District upon request. Th ereafter, the Logs shall be retained for an additional 3 years either at the stationary source or in a readily available location that allows for expeditious District inspection and review.



### [Note 100: The new additional 3 year log retention provision is made to comply with an EPA policy.]

3. For an y exemption claimed under Section B.2

, maintain a written Engine Exemption Log

c ontaining the following information for each engine subject of the claim in accordance with the compliance schedule in Section K :

a. Engine‟s classification ( rich

- burn noncyclically

- loaded spark ignition, rich

- burn cyclically

- loaded spark ignition, lean

- burn spark ignition

, compression ignition, or dual

fuel ), make, model, and serial number or the owner‟s or operator‟s unique identi fication

number

.



### [Note 101: Sources claiming the Rule 333.B.2 exemption need to comply with the Rule 333.D.1 engine identification requirement. Indication of the engine’s make, model, and serial number or the owner’s/operator’s unique ID number is impor tant for compliance and tracking purposes. (If the owner or operator chooses to use the

APCD’s device identification number that would suffice to fulfill the owner’s or operator’s unique identification number requirement.)]

b. H ours of operation per quar ter (or more often at the owner ‟s or operator‟s discretion), as determined by a nonresettable elapsed operating time meter

.



### [Note 102: Requiring the engine owner or operator to record the engine operating hours provides a method for verifying compliance with the 200 hours per year threshold.]

c. L ocation of operation of the engine

.



### [Note 103: Documenting the location of the engine is necessary for inventory and compliance purposes.]

d. D ate of each log entry and the printed or typed name of the person entering the log

information

.



### [Note 104: Documenting the date of each log entry is important for verifying compliance with these recordkeeping provisions. Requiring that the personSTAFF REPORT

- Regulation II/Rule 333 Page G

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June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 24 April 17, 1997 [ Date of revised rule adoption ]



### performing the monitoring/inspection print or type their name is needed to ensure accountability.]

e. For every engine that has been relocated, a notation to that effect identifying both the present and prior location, the reason(s) for the engine relocation, and the elapsed operating time meter readings for both the relocat ed engine and the engine being displaced.



### [Note 105: Details on relocated and displaced engines help verify compliance that the 200 hours per year threshold is not being exceeded.]

At a minimum, entries in the Engine Exemption Log shall be performed on the first day the engine is operated in a new quarter and when an y engine is relocated. Copies of all such Logs shall be retained at the stationary source for a minimum of 2 years after the date of the last entry and shall be available

to the District upon request. Thereafter, the Logs shall be retained for an additional 3 years either at the stationary source or in a readily available location that allows for expeditious District inspection

and review.



### [Note 106: Industry has indicated that under t he existing recordkeeping provisions they had to log the operating hours on an engine each quarter irrespective that the engine had not operated during the reporting period. Thus, the APCD is adding the first day the engine is operated in a new quarter to avoid unnecessary recordkeeping.]

[Note 107: This retention provision complies with an EPA policy on maintaining records for five years.]

I K

. Compliance Schedule

The owner or operator of any engine subject to this r ule shall meet the following compli ance schedule:

1. New engines : shall comply with this rule on the date of adoption

.

Commencing [ date of revised rule adoption ], any new engine shall comply with this rule the first time it is operated in the District or the outer continental shelf for which the District is the c orresponding

onshore area.



### [Note 108: The owner or operator of any new engine will need to comply with the requirements for engine identification, metering, and the I&M and Compliance Plans the first time the engine is operat ed in the APCD’s jurisdiction.]

2

. Owners or operators of existing noncyclic engines shall comply as follows:

a. by March 2, 1992 submit a Compliance Plan pursuant to Section F.; and

b. by September 3, 1992 control a sufficient number of engines to meet the requirements of Section D. for a minimum of 33% of the total rated brake horsepower of the engines at the stationary source; and

c. by June 3, 1993 control a sufficient number of engines to meet the requirements of Section

D. for a minimum of 66% of the total rated brake horsepower of the engines at the stationary source; and

d. by March 8 , 1994 control a sufficient number of engines to meet the requirements of Section D. for all engines. See Note

106.

See Note

107.STAFF REPORT

- Regulation II/Rule 333 Page G

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June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 25 April 17, 1997 [ Date of revised rule adoption ] 3. Owners or operators of existing cyclic engine s shall comply as follows:

a. by March 2, 1992 meet the requirements of Section D.3.a.

b. Within one year or sooner from date of adoption the Board of Directors of the Air Pollution Control District shall notice a public hearing at least thirty (3 0) days prior to the hearing date. The hearing will be held to review additional information pertaining to the requirements of Section D.1., D.2. and D.3.b.

c. by March 3 , 1993 submit a Compliance Plan pursuant to Section F.; and

d. by March 3 , 1994 all engines shall be controlled to the limits established by the Board of

Directors of the Air Pollution Control District.

4. An existing and operating engine that is permanently shut down or electrified after the date of rule adoption can be included i n determining the percent of total horsepower that meets the requirements

of Section D.

5. An application for an ATC shall be filed 120 days before the compliance date for each engine set forth in I.2.b. and 180 days for engines set forth in I.2.c., I.2. d., and I.3.d.

2. Existing Engines:

a. For any engine subject to an e mission l imit:

The Rule 333 [ date of revised rule adoption ] revisions resulted in changes in the oxides of nitrogen (NOx) emission limits and the addition of reactive organic compound (ROC) and

carbon monoxide emission limits as summarized in the attached Tables 1 and 2

.

Any engine previously subject to any emission limit in the April 17, 1997 adopted Rule 333, shall continue to comply with th e emission limit (s) until such time th at compliance with a

re vised emission limit is required . Further, any engine subject to a revised emission limit

, as indicated in attached Tables 1 or 2 , shall comply with the Rule 333 Section E emission limits by [ two years from the date of revised rule adoption ] unless the engine is permanently

removed

.

Any engine that was previously exempt from Rule 333

, but became subject to Rule 333

emission limits through the [ date of revised rule adoption ] Rule 202 revisions shall comply

with the Rule 333 Section E emission limits by [ two years from the date of revised rule adoption ] unless the engine is permanently removed.

An initial source test demonstrating compliance with a new or revised emission limit shall be completed in accordance with Section I prior to [ two years from the date of revised rule adoption ]. The owner or operator of a ny engine to be modified or replaced to comply with

the Section E emission limits shall submit an Authority to Construct application to the Control Officer by [ one year from the date of revised rule adoption ]

.



### [Note 109: Existing engines previously complying with the rule’s emission limits are required to continue complying with the emission limits until a revised rule limit becomes effective. Thus, for Category 1 and 3 en gines complying with the emission limits, implementation of the revised rule limits is seamless between the old and the

new rule. See Note

109.

See Note

110.STAFF REPORT

- Regulation II/Rule 333 Page G

- 26

June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 26 April 17, 1997 [ Date of revised rule adoption ]



### Category 5 engines previously complying with the NOx limit will need to 1) continue to comply with the 797 ppmv NOx at 15 %O 2 limit and 2) comply with the revised NOx limit and the new ROC and CO limits by two years from the date of the rule

revision. ]

[Note 110: The two

- year compliance deadlines for complying with the emission limits and for performing source tests are consi stent with the deadlines recommended in the ARB RACT/BARCT Determination.]

b. For any engine that will be permanently removed from service:

i. by [ one month from the date of revised rule adoption ], comply with the engine identification requirements in Se ction D.1;

ii. by [ six months from the date of revised rule adoption ], submit a statement to the Control Officer identifying the engine to be removed; and

iii. by [ two years from the date of revised rule adoption ], remove the engine.



### [Note 111: The Sec tion K.2.b provision establishes an alternative compliance method to meeting the emission limits and a compliance schedule that are similar to those recommended in the ARB RACT/BARCT Determination.]

c

. For any engine subject to the exemption in Section B. 2 (operating less than 200 hours per year):

i. by [ one month from the date of revised rule adoption ], comply with the engine identification requirements in Section D.1 and the recordkeeping provisions in Section J.3; and

ii. by [ six months from the date of revised rule adoption ], install and comply with the metering requirements in Sections D.2

.



### [Note 112: The APCD is establishing deadlines for sources claiming the exemption to ensure timely compliance with the requirements. This approach should minim ize engine owners and operators claiming this exemption only after the APCD has identified potential Rule 202 and/or Rule 333 compliance problems with an engine.]

d

. For any engine subject to engine identification, plans, or metering requirements in Secti on
D :

i. by [ one month from the date of revised rule adoption ], comply with the engine identification requirements in Section D.1 and the recordkeeping provisions in

Section J ;



### [Note 113: The majority of the engines have been subject to identification

r equirements implemented either through the APCD permitting process as a permit condition, documentation of permit exemptions, and/or through the documentation of the APCD emission inventory. Likewise, the recordkeeping provisions should not be a new requi rement for most engine owners and operators.]STAFF REPORT

- Regulation II/Rule 333 Page G

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June 19, 2008

[ Annotated draft of June 19, 2008 ]

Santa Ba rbara County APCD Rule 333 333

- 27 April 17, 1997 [ Date of revised rule adoption ] ii. by [ six months from the date of revised rule adoption ]:

1) submit a new/revised Engine Inspection and Maintenance Plan for the Control Officer‟s approval pursuant to Section F. Any previously approved Engine Inspection and Maintenance Plan will continue to be in force until the Control Officer approves a revised plan ; and

2) e xcept as specified in Section B.3, submit a new/revised Compliance Plan for the Control Officer‟s approval pursuant to Section G. Previously approved Compliance Plans will continue to be in force until the Control Officer approves a revised Compliance Plan ; and

iii. by [ nine months from the date of revised rule adoption ]

, install and comply with the metering requirements in Se ctions D.2 and D.3

.



### [Note 114: The ARB RACT/BARCT Determination, Section V.B(1) recommends a six month deadline for submitting an Emission Control Plan. Also, the Determination’s Section VII.A(2) recommends that the Compliance Plan include the

I&M Plan .]

[Note 115: Compliance with the operating hour metering and the fuel consumption metering/quantification requirements is consistent with the ARB RACT/BARCT Determination Section VII.B(2) provisions.] See Note

114.

See Note

115.STAFF REPORT

- Regulation II/Rule 333 Page G

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June 19, 2008

[ Annotated draft of June 19, 2008 ] Santa Barbara County APCD Rule 333 333

- 28 April 17, 1997 [ Date of revised rule adoption ] ATTACHMENT

Table 1: Summarized Oxides of Nitrogen Emission Limit Changes Resulting from the [

date of revised rule adoption ] Rule 333 Revision

Engine Type Category

Number April 17, 1997

Adopted Rule 333

NOx Limits [

Date of Revised Rule Adoption ] Adopted Rule 333

NOx Limits Effect of Change

%

Control p pmv (at

15% O2) %

Control ppmv (at

15% O2)

Rich

- Burn Noncyclically

Loaded Spark Ignition Engines 1 90 50 90 50 No change

Lean

- Burn Spark Ignition Engines in the 50 to less than 100 bhp Range 2 80 125

- 200 Increased emission

limit

Lean

- Burn Spark Igni tion Engines Rated 100 bhp or

Greater 3 80 125 80 125 No change

Rich

- Burn Cyclically

- Loaded Spark Ignition Engines 4 90 50

- 300 Increased emission

limit Compression Ignition Engines

and Dual

- Fuel Engines 5

- 797 40 700 Decreased emission

limit

Table 2: Summarized Reactive Organic Compound and Carbon Monoxide Emission Limit Changes Resulting from the [date of revised rule adoption] Rule 333 Revision



### [Note 116: Tables 1 and 2 restate the emission limits from the April 17, 1997 adopted Rule 333, Section D, and the proposed revised Rule 333, Section E. For some categories (e.g., 1 and 3), there is no change in the emission limits. Other categories (e.g., 2 and 4) have emission increases. However, it should be noted that there are no Engine Type Category

Number April 17, 1997

Adopted Rule 333 Limits, ppmv (at 15% O2) [

Date of Revise d Rule Adoption ] Adopted Rule 333 Limits, ppmv (at 15% O2) Effect of Change

ROC CO ROC CO

Rich

- Burn Noncyclically

Loaded Spark Ignition Engines 1 250 4,500 250 4,500 No change

Lean

- Burn Spark Ignition Engines in the 50 to less than 100 bhp Range 2 750 4,500 750 4,500 No change

Lean

- Burn Spark Ignition Engines Rated 100 bhp or

Greater 3 750 4,500 750 4,500 No change

Rich

- Burn Cyclically

- Loaded Spark Ignition Engines 4 250 4,500 250 4,500 No change

Compression Ignition Engines

and Dual

- Fuel Engines 5

- - 750 4,500 New emission limit sSTAFF REPORT

- Regulation II/Rule 333 Page G

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June 19, 2008

[ Annotated draft of June 19, 2008 ] Santa Barbara County APCD Rule 333 333

- 29 April 17, 1997 [ Date of revised rule adoption ]



### Category 2 or 4 engines currently subject to the April 17, 1997 adopted emission limits. Thus, the APCD does not expect that the re will be any increase in emissions from the changes to those emission limits.

Rule 333 Section K.2.a refers to the limits in these tables and requires that:

1. engines previously subject to the April 17, 1997 emission limits continue to comply with t he emission limits until such time that a revised emission limit is required, and

2. engines becoming subject to a new or stricter emission limit comply within two years of the adoption of the modified rule.

Tables 1 and 2 are therefore an integral exten sion of the Section K Compliance Schedule provisions.]

### THIS PAGE INTENTIONALLY LEFT BLANKSTAFF REPORT

- Regulation II/Rule 333 Page H

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Santa Barbara County APCD 

### Appendix H

Santa Barbara County Summarized Data on Emission Reductions, Cost

- Effectiveness, and

Incremental Cost

- Effectiveness

Table 1. EMISSION REDUCTIONS a

SOURCE AND EQUIPMENT

DESCRIPTION STATIONARY

SOURCE No. FACILITY

No. DEVICE

No. ESTIMATED EMISSION REDUCTIONS (INCREASES)

NOx (tons/day) NOx

(tons/year) ROC

(tons/day) ROC

(tons/year)

County of Santa Barbara

- Foxen Canyon, two 78 bhp compression igni tion engines 03706 03706 104269 &

106429 0.0019 0.7000 (0.0000) (0.0113)

Pacific Operators Offshore, Inc., PF Hogan, 440 bhp compression ignition engine for well drilling 08001 08001 007107 0.0057 2.0821 (0.0000) (0.0040)

Pacific Operators Offshore,

Inc ., PF Houchin, 440 bhp compression ignition engine for well drilling 08001 08002 007108 0.0040 1.4542 (0.0000) (0.0028)

Purisima Hills LLC

- Barham Ranch, H.P. Boyne Lease, six 65 bhp uncontrolled spark ignition engines 01153 03777 005908, 005909,

005910

, 005911, 005912, &

009015 0.0062 2.2742 (0.0018) (0.0168)

TOTALS 0.0178 6.5105 (0.0001) (0.0349)

a Based on engines in the 2005 Emission Inventory.STAFF REPORT

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June 19, 2008

Santa Barbara County APCD THIS PAGE INTENTIONALLY LEFT BLANKSTAFF REPORT

- Regulation II/Rule 333 Page H

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June 19, 2008

Santa Barbara County APCD 

### Table 2. COST

- EFFECTIVENESS a

SOURCE TYPE

ENGINE RATING

(Bhp) UNCONTROLLED

NOx EMISSIONS (tons/year) PROPOSED

NOx LIMIT (ppmv @ 15% O2) NOx

EMISSIONS

REDUCED (tons over a

ten

- year period) INITIAL

TUNING

COSTS ($) NPV OF

INCREASED

ANNUAL

OPERATING

AND MAINT. COSTS ($) INITIAL

TUNING COSTS

PLUS NPV OF

THE ANNUAL

O & M COSTS ($) COST

EFFECTIVENES S ($/ton)

County of Sant a Barbara

- Foxen Canyon (SSID 03706, DID 104269) CI 78 8.99 700 27.37 2000 40,437 42,437 1,550

County of Santa Barbara

- Foxen Canyon (SSID 03706, DID 106429) CI 78 1.21 700 3.68 2000 40,437 42,437 11,532

Pacific Operators Offshore, LLC, Platform Hogan (SSID 8001, DID 007107) CI 400 4.81 700 10.95 2000 57,609 59,609 5,444

Pacific Operators Offshore, LLC, Platform Houchin (SSID 8001, DID 007108) CI 400 3.36 700 7.65 2000 57,609 59,609 7,795

Purisima Hills LLC (SSID 01153, DID No. 005908, 005909, 005910, 005911, 005912, & 009015) SI 65 1.13 300 3.79 2000 38,646 40,646 10,724

a Based on engines in the 2005 Emission Inventory.STAFF REPORT

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June 19, 2008

Santa Barbara County APCD 

### Table 3. INCREMENTAL COST

- EFFECTIVENESS a

SOURCE TYPE

ENGINE RATING

(Bhp) INITIAL

TUNING

COSTS ($)

LOW EMISSION TUNING NPV ($) LOW EMISSION TUNING NOx TOTAL EMISSION REDUCTIONS (tons) LOW EMISSION TUNING METHOD

COST - EFFECTIVENESS
($/ton) ELECTRIFICATION NPV ($) ELECTRIFICATION NOx TOTAL EMISSION REDUCTIONS (tons) ELECTRIFICATION METHOD COST - EFFECTIVENESS ($/ton)

INCREMENTAL

COST

EFFECTIVENESS ($/ton)

Purisima Hills LLC (SSID 01153, DID No. 005908, 005909, 005910, 005911, 005912, & 009015) SI 65 2000 40,646 3.79 10,724 44,270 11.35 3,900 479

a Based on engines in the 2005 Emission Inventory.STAFF REPORT

- Regulati on II/Rule 333 Page I

- 1

June 19, 2008

Santa Barbara County APCD 

### Appendix I

Santa Barbara County Identification of Existing Federal and APCD Regulations that Apply to the Same Equipm ent or Source Type Covered in Rule 333

This section is included to comply with the California Health & Safety Code Section 40727.2 requirements.

F EDERAL 

### A IR 

### P OLLUTION 

### C ONTROL 

### R EQUIREMENTS



### T here are several federal air pollution control requirements t hat apply to the same equipment or source types covered by Rule 333. In general, engines subject to Rule 333 may be subject to one or more of the following federal requirements.

1. 40CFR60, Standards of Performance for New Stationary Sources, Subpart III I, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
2. 40CFR60, Standards of Performance for New Stationary Sources, Subpart JJJJ, Standards of Performance for Stationary Spark

- Ignition Internal Combustion Engines 3

. 40CFR63, National Emission Standards for Hazardous Air Pollutants for Source Categories, Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
4. 40CFR89, Control of Emissions from New and In

- Use Nonroad Compression

- Ignition Engines a


### 5. 40CFR91, Control of Emissions from Marine Spark

- Ignition Engines
6. 40CFR94, Control of Air Pollution from Marine Compression

- Ignition Engines
7. 40CFR1048, Control of Emissions from New, Large Nonro ad Spark

- Ignition Engines

________________________

S ANTA 

### B ARBARA 

### C OUNTY 

### A IR 

### P OLLUTION 

### C ONTROL 

### D ISTRICT 

### R EQUIREMENTS



### Table 1 shows the rules that apply to internal combustion engines.

Table 1. RULES THAT APPLY TO INTERNAL COMBUSTION ENGINES

GENERIC R EQUIREMENTS AFFECTED EMISSION
UNITS BASIS FOR APPLICABILITY

R ULE 201 : Permits Required All emission units Emission of pollutants

R ULE 202 : Exemptions to Rule 201 Applicable emission units Insignificant activities/emissions, per size/rating/function

R U LE 210 : Fees All emission units Administrative

R ULE 212 : Emission Statements All emission units Administrative

R ULE 302 : Visible Emissions All emission units Particulate matter emissions

a Compression ignition emergency standby engines are not subject to Rule 333.STAFF REPORT

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June 19, 2008

Santa Barbara County APCD GENERIC R EQUIREMENTS AFFECTED EMISSION
UNITS BASIS FOR APPLICABILITY

R ULE 303 : Nuisance All emission units Emissions that can injure

, damage or offend.

R ULE 304 : PM Concentration

– North Zone Each PM source Emission of PM in effluent gas

R ULE 305 : PM Concentration

– South Zone Each PM source Emission of PM in effluent gas

R ULE 309 : Specific Contaminants All emission units Combustio n contaminants

R ULE 310 : Odorous Org. Sulfides All emission units Emission of organic sulfides

R ULE 311 : Sulfur Content of Fuel All combustion units Use of fuel containing sulfur

R ULE 333 : Control of Emissions from Reciprocating IC Engines. Internal c ombustion engines Engines rated at 50 brake horsepower and greater

R EGULATION VIII : New Source
Review All emission units Addition of new equipment or modification to existing equipment. Applications to generate ERC Certificates.

R EGULATION XIII (R ULES 1 301

- 1305) : Part 70 Operating Permits All emission units A stationary source is a major

source.



### A review of Table 1 indicates that there are no overlapping or conflicting averaging provisions, units, or any other pertinent provisions associated with emis sion limits.Note: Attachment J , Public Comments and the APCD Responses, is omitted from this Staff Report to reduce

redundancy. Attachment 6 of the SIP submittal package includes the Public Comments.THIS PAGE INTENTIONALLY LEFT BLANKSTAFF REPORT

- Regulation II/Rule 333 Page K

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June 19, 2008

Santa Barbara County APCD 

### Appendix K

Santa Barbara County Comparison of the Proposed Amended Rules to the Rules in the Adjoining Air Districts

The Air Pollution Control Districts that border the Santa Barbara County APCD (SBC) include the San Joaquin Valley Unified APCD (SJV), the San Luis Obispo County APCD (SLO), and the Ventura County APCD (VC). For performing the comparisons of the proposed revised rules, rulemaking staff considered the following categories:

1. Definitions,

2. Authority to Construct Requirement,

3. Exemptions and General Provisions for Permit Exemptions, and

4. Internal combustion engine prohibitory rule requirements.

The following provides summaries of the comparison findings for each of these categories.



### D EFINITIONS 

### (SBC R ULE 

### 102)

In general, the SJV, SLO, a nd VC engine rules include definitions that are similar to the ones we are proposing for Rule 102. However, the Santa Barbara County Air Pollution Control District prefers to locate the definitions in the general definition rule (Rule 102) instead of Rule 333. Thus, our approach to the location of the definitions differs from the adjoining air districts. Their general definition rules do not contain the terms being proposed for addition to our general definition rule. The APCD is proposing that the new definitions be added to Rule 102 because the terms are used in more than one rule. Where a definition is applicable to only one rule, the SBC places the definition in that rule only. Generally, the definitions being added to Rule 102 are needed to clarif y terms that are used in Rule 202 (Exemptions to Rule 201) and Rule 333 (Control of Emissions from Reciprocating Internal Combustion Engines).



### A UTHORITY TO 

### C ONSTRUCT 

### (ATC) R EQUIREMENTS 

### (SBC R ULE 

### 201.D)

The changes to SBC Rule 201.D include:

1. clarify ing the ATC required provision by including the “using” and “use” terms, and

2. removing the potential ATC/PTO requirement for the use of pile drivers, dredges, pipe

- laying, and derrick barges (Section 201.D.2) and adding exemption language to Rule 202.

Regarding the above item 1, the SBC is the first air district to add the “using” and “use” terms. We are adding these terms for consistency with the Health and Safety Code and to allow for clearer exemptions. On item 2 above, the adjoining air districts do not exempt pile drivers, dredges, pipe

- laying, and derrick barges.



### P ERMIT 

### E XEMPTIONS 

### (SBC R ULE 

### 202)

These are in several categories.

 Exceptions to Permit Exemptions. Currently, SBC has one exception to the permit exemptions. It indicates any equ ipment, activity, or operations proposed by an application to be subject to an Emission Reduction Credit is not exempt.

SJV and SLO have several exceptions to their permit exemptions. Their exceptions range from negating the exemption for an emission u nit subject to New Source Performance Standards to negating an exemption where the owner of an otherwise exempt emission unit specifically requests a permit to operate. VC does not have any exceptions to its exemption rule.STAFF REPORT

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June 19, 2008

Santa Barbara County APCD  Temporary Equipment Exemption. SBC Rule 202.D.5 exempts temporary equipment provided certain conditions are met (e.g., emissions are 1 ton per year or less). SJV, SLO, and VC do not have an exemption provision for temporary equipment.

 Exemption for Stationary Sources that have Unc ontrolled Actual Emissions less than 1 Ton per Year. This is an existing permit exemption in SBC Rule 202. SJV, SLO, and VC do not have a stationary source exemption provision.

 General Provision to Accumulate Ratings When Several Equipment Units are U sed in the Same

Process. The SBC permit exemption rule does not currently include a provision on accumulating the ratings of equipment used in the same process for determining exemption applicability. The SJV and VC rules do not have such a provision eit her. However, the SLO Rule 201 Sections B.1 and B.2 include such a provision. SBC staff proposes a new provision that is similar to the SLO provision for SBC Rule 202, general provision D.15 and reflects our long

- standing implementation.

 General Provisi on to Require Emission Offsets for Equipment Used in Construction Activities. This provision, currently found in SBC Rule 202.F.3, requires emission offsets if the combined emissions from all construction equipment used to construct a stationary source th at requires an Authority to Construct or Permit to Operate exceed 25 tons of any pollutant (CO not included) in a 12 month period. The APCD proposes relocating the provision into the general provisions of Rule 202 (new Section D.16).

None of the adjoinin g air districts have a similar general provision to require offsets if emissions from construction equipment used to construct a stationary source requiring an Authority to Construct or Permit to Operate exceeds 25 tons per 12 month period.

 General Prov ision on not Allowing Derated Equipment to be Exempt . SBC staff propose adding provisions to Rule 202 specifying that no compression/spark ignition engine, gas turbine engine or combustion equipment otherwise subject to permit shall be exempt because it h as been derated. The basis for this approach is that permitting derated equipment provides a method to ensure that the derating is enforceable and permanent.

SJV and VC rules do not have provisions that address equipment derating. SLO Rule 4701, Section 3.6, infers that derated engines are required to be permitted.

 Single

- Engine Exemption Cut Off Rating. The SBC Rule 202 exemption cut

- off on a single engine basis is currently 100 brake horsepower. The EPA recommends that this cut off be less than 50 brake horsepower. Also, the state Airborne Toxic Control Measure for Portable Compression Ignition Engines applies to engines rated at 50 brake horsepower and greater. Therefore, for consistency with the ATCM, the APCD proposes that the permit requireme nts also apply to engines rated 50 brake horsepower or greater. (The multiple small spark ignition engine exemption/permitting provision

- see next bulleted item

- supersedes the single

- engine exemption provision for sources with multiple spark ignition e ngines.)

SJV exempts engines with horsepower ratings of 50 or less. VC and SLO rules exempt engines rated less than 50 brake horsepower.

 Stationary Sources with Multiple Small (Greater Than 20 to Less Than 50 Brake Horsepower) Spark Ignition Engine Exemption/Permitting Provision. Currently, the SBC Rule 202 exempts spark ignition engines in the 20 to 100 brake horsepower range, if the aggregate rating of all such engines at a stationary source is 500 brake horsepower or less. Conversely, if the agg regate of such engines exceeds 500 brake horsepower, permits are required.

Under the proposed revised Rule 202 provision, if spark ignition engines in the greater than 20 to less than 50 brake horsepower range have an aggregate rating less than 400 brak e horsepower (approximately an uncontrolled potential to emit less than 40 tons of NOx per year) at a stationary source, the engines areSTAFF REPORT

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June 19, 2008

Santa Barbara County APCD exempt. Conversely, under the proposed revised rule, if the engines in this range have an aggregate rating

of 400 brak e horsepower or greater, then permits are necessary.



### SJV, SLO, and VC do not have an exemption or permitting provision for multiple small spark ignition engines at a stationary source.

 Exemption for Gas Turbine Engines . The existing SBC Rule 202, Sect ion F.1.f provision indicates gas turbines with a maximum heat input rate of 3 million British thermal units per hour or less are exempt. Staff plan to maintain this threshold and allow limited same

- process additions of natural gas

- fired microturbines

tha t have been certified by the ARB, provided the potential annual emissions of each affected pollutant does not exceed 1 ton (except carbon monoxide, which shall not exceed 5 tons).

SJV has a specific exemption for gas turbines that have a maximum heat inpu t rating of 3.0 million British thermal units per hour or less and a general provision to exempt low emitting units. Low emitting units are emission units that have an uncontrolled emission rate of any single contaminant that is less than or equal to 2 po unds per day or, if greater than 2 pounds per day, less than or equal to 75 pounds per year.

SLO exempts gas turbines rated 3.0 million British thermal units per hour or less. VC exempts gas turbines that have a rated full load output of less than 0.30 megawatts (300 kilowatts).

 Exemption for Engines Rated at Less than 50 Brake Horsepower Used in Military Tactical Support Operations and Other Miscellaneous Operations . This is an existing provision in SBC Rule 202. Unlike SBC, SJV, SLO, and VC exemp t all engines rated less than 50 brake horsepower, regardless of the use of multiple small engines at a stationary source. Hence, the adjoining air districts do not have a need for an exemption for small engines (less than 50 brake horsepower) used in mil itary tactical support operations and other miscellaneous operations.

 Exemption for Engines Used in Conjunction with Offshore Drilling Equipment. The current SBC provision exempts offshore drilling equipment, provided the emissions from such equipment ar e less than 25 tons per stationary source of any affected pollutant during any 12 month period. The APCD proposes to delete this exemption.

Due to its geographical location, SJV does not regulate an area that could potentially have offshore drilling.

SL O and VC do not have exemptions for offshore drilling equipment.

 Exemption for Specialty Equipment. The SBC is proposing to add a new “specialty equipment” exemption for limited emergency situations located in the Outer Continental Shelf or State Terri torial Waters. SJV does not regulate activities in the OCS or STW. SLO and VC do not have exemptions for the use of specialty equipment in the OCS or STW.

 General Permitting Provisions or Exemption for Equipment Used in Dredging, Pile Driving, Pipe

Layi ng Barges and Derrick Barges. Currently SBC Rule 201.D.2 includes a provision that such equipment will require a permit if the potential to emit is 25 tons per any 12 month period or greater. Conversely, the equipment is exempt if the potential emissions are less than 25 tons per any 12 month period. The SBCAPCD proposes to modify and move the Rule 201.D.2 provisions to Rule 202.F.7. The provision is being expanded to include cable

- laying vessels/barges. However, the exemption for dredges is being elim inated as these units are considered erected and subject to Rule 201.D.1.

SJV Rule 2020, Section 4.4, and SLO Rule 201, Section C.2 indicate, “Locomotives, airplanes, and watercraft used to transport passengers or freight. This exemption is not intended t o apply to equipment used for the dredging of waterways or to equipment used in pile driving adjacent to or in waterways.” In addition to exempting locomotives, aircraft, and recreational watercraft, VC Rule 23.D.2 exempts marine vessels. (But not equipm ent mounted on them that would otherwise require a permit.)STAFF REPORT

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June 19, 2008

Santa Barbara County APCD To summarize this permitting/exemption category comparison, the SJV, SLO, and VC rules do not exempt equipment used in pile driving, or cable and pipe

- laying vessels/barges or derrick barges, r egardless of the equipment‟s potential to emit. However, the SBC will provide exemptions for such equipment, provided certain requirements are met.

 Marine Vessel Engine Exemptions from New Source Review. The APCD is proposing this exemption (Rule 202. F.8) to address concerns stemming from the deletion of the construction engine exemption. None of the adjoining air districts have a similar exemption.

 Provision on a General Category Exemption not Applying to any Component which Otherwise Requires a Per mit. The general provision of SBC Rule 202.D.11 disallows exemptions in cases where individual components are permitted. The current SBC Rule 202.G.2 provision needs to be revised for improved clarity in light of the Rule 202.D.11 provision.

SJV and VC exemption rules do not have this provision. The SLO Rule 201.A.2 indicates, “An otherwise exempt piece of equipment requires a permit if it is part of a process that requires a permit.”

 Exempting Powder Coating Operations. The existing SBC Rule 202.I.5 exempts only polyurethane powder coating operations. Staff proposes expanding this exemption to include all powder coating operations, provided the ROC content of the powder coatings does not exceed five percent, by weight.

The SJV Rule 2020, §6.8.3 exem pts powder coating operations that use less than five pounds of coating material per day or less than fifty pounds of coating material per year. SLO staff exempt powder coating operations by their two pounds per day exemption. VC staff exempts powder coa ting operations via their Rule 23.F.11.b (use of coating materials less than 200 pounds per 12 month rolling period).

 Exemptions for Wineries, Breweries, Distilleries and Similar Facilities. The adjoining air districts do not have a specific exemption fo r these facilities.

 Exemption for Portable Water Heaters Used for Underwater Diving Activities. None of the adjoining air districts have a specific exemption for these boilers.

 Airborne Laser Program Exemption from New Source Review. This new exemp tion (Rule 202.P.14) is a limited provision being proposed in response to a request by Vandenberg Air Force Base. Thus, LSO, SJV, and VC rules do not have a similar exemption.

 Exemption for Solvent Wipe Cleaning Operations. The SBC is proposing changes to the existing solvent wipe cleaning exemption. Sources using 55 gallons per year or less are exempt from the SBC permitting requirement. The SJV Rule 2020, Section 6.9.3, and the SLO Rule 201, Section J.2.c, provide an exemption for solvent cleaning op erations using less than 25 gallons of solvent per year (with a monthly recordkeeping requirement). The VC Rule 23.10.d provides an exemption for solvent cleaning operations having emissions less than 200 pounds per rolling 12

- month period per source. T he VC 200 pound limit is for each ROC, methylene chloride, 1,1,1 trichloroethane, and perchloroethylene. Also, the exemption does not apply for coating, graphic arts, adhesive/sealant and polyester resin operations.

In summary:

1. The maximum allowable solvent usage under the SJV and SLO exemptions is about fifty percent less

than the SBC limit.

2. The VC exemption is based on meeting an emissions rate criteria on a per ROC (and a limited per hazardous air pollutant) basis. The exemption excludes cert ain processes from the exemption.STAFF REPORT

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Santa Barbara County APCD 

### E NGINE 

### P ROHIBITORY 

### R ULE 

### R EQUIREMENTS 

### (SBC R ULE 

### 333)

The SBC and SLO engine rule provisions can be regarded as “reasonably available control technology” requirements, whereas SJV and VC rules are stricter and are consider ed “best available retrofit control technology.” This results in the SJV and VC engine emission limits being lower (stricter) than the SBC and SLO rules.

The engine prohibitory rule requirements have several components, as outlined below.

 Applicability. SBC staff proposes to make the engine prohibitory rule applicability similar to SLO and VC: the requirements apply to engines rated at 50 brake horsepower and greater. The SJV engine rules apply to engines rated greater than 50 brake horsepower.

 Exemp tions. As is the case for general permit exemptions, the adjoining air districts have a wide range of exemptions in their engine rules. For the engine prohibitory rule exemptions, there are two types of exemptions:

a) Total Exemption: Engines are exe mpt from the prohibitory rule in its entirety, and

b) Partial Exemption: Engines are partially exemption from the prohibitory rule requirements (e.g., exempt from the emission limits, but not from the recordkeeping provisions).

The following summariz es comparisons of the different SBC Rule 333 exemptions.

1. Engines Burning Landfill Gas (SBC Partial Exemption). A source claiming this exemption in Santa Barbara County needs to maintain fuel monitoring information and other documentation to support th e claim of exemption. SJV, SLO, and VC engine rules do not exempt engines burning landfill gas.

2. Engines Exempt from Permit (SBC Total Exemption). SJV engine Rule 4701 (Phase 1) infers engines exempt from permit are exempt from the prohibitory rule in the rule‟s applicability provision. The SJV engine Rule 4702 (Phase 2) and the SLO and VC engine rules do not have this exemption.

3. Engines Derated to Less Than 50 Brake Horsepower (SBC Rule 333 Total Exemption). For derated engines, the SJV Rule 47 01 provides a partial exemption and the SJV Rule 4702 provides a total exemption. The SLO and VC rules do not have any exemptions for derated engines.

4. Compression Ignition Emergency Standby Engines (SBC Total Rule 333 Exemption). Except for

administr ative provisions necessary to substantiate the exemption, SJV and SLO rules exempt emergency engines. VC exempts emergency standby engines, provided their maintenance operations do not exceed 50 hours per calendar year. Exempting spark ignition emergency standby engines from the prohibitory rule is consistent with the ARB RACT/BARCT Determination. Also, compression ignition emergency standby engines are subject to the state ATCM. By exempting these engines from Rule 333 in its entirety, the APCD is elim inating the engine owner and operator‟s Rule 333 compliance

burden.

5. Engines that Operate Less than 200 Hours per Year (SBC Partial Exemption). All of the adjoining air districts have this exemption; the VC rule exempts these engines from their entire engine

rule.

6. Compression Ignition ARB or EPA Tiered Engines (SBC Partial Exemption). None of the adjoining air districts have the provision proposed in new Section 333.B.3. This section will provide a partial exemption for ARB

- or EPA

- tiered diesel

- f ueled engines. Assuming the routine monitoring checks with a portable analyzer do not exceed 560 parts per million of NOx at 15% oxygen, these engines will not need to submit a compliance plan. Further, they will not be subject to initial andSTAFF REPORT

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Santa Barbara County APCD

biennial so urce testing provisions.

 Definitions. Generally, the definitions are the same between the air districts. SBC is recommending the relocation of some of the definitions currently found within the prohibitory rule be moved into the general

definition rule (102). The recommendation is made only for those terms that appear in more than one SBC

rule.

 Requirements. There are several components to the engine rule requirements, as shown in the following

summaries.

1. Engine Identification. Historically, iden tification of permitted engines has been required through a permit condition. Except for SLO, none of the adjoining air districts has the requirement that the owner or operator identify the engines. SLO incorporates the engine identification requirement within

the Engine Operator Inspection Plan.

2. Elapsed Operating Time Meters and Fuel Meters. SBC Rule 333 currently requires elapsed operating time meters. Also, fuel meters are required for engine fired on landfill gas and engines subject to source te sting. SBC staff proposes that all engines subject to Rule 333 be equipped with fuel meters. This requirement is consistent with the ARB RACT/BARCT Determination.

SJV requires engines to be equipped with these meters, but SLO and VC do not.

3. Cont inuous Monitoring Systems. For qualifying new engines (rated ≥ 1,000 bhp, with > 2,000 hours per year allowable operating schedule), the amended Rule 333 will require the use of a continuous emissions monitoring system. The SJV rule and the ARB RACT/BARC T Determination require a continuous monitoring system, which may be a continuous emissions monitoring system (CEMS), a parametric emissions monitoring system (PEMS), or an alternative monitoring system approved by the APCO. Unlike the proposed SBC requir ement (which applies only to new engines), the SJV and ARB RACT/BARCT Determination provisions apply to existing and new engines. SLO and VC rules do not include a requirement for and continuous monitoring system.

4. Emission Limits. All adjoining air d istrict engine rules have emission limits that vary due to the level of control (RACT vs. BARCT) as described earlier. SBC proposes to use the diesel engine RACT limit from San Diego and the limits from the ARB RACT/BARCT Determination for the spark ignit ion engines.

5. Alternative Emission Control Plans. The SBC engine rule currently has an outdated Alternative Emission Control Plan (AECP) provision. SBC staff recommends that the existing AECP be deleted as the deadline for submitting such plan has p assed and the APCD did not receive any plans.

SJV includes an AECP provision, but SLO and VC do not.

6. Limiting use of Anhydrous Ammonia to Meet Emission Limits. The SBC Rule 333 currently prohibitions the use of anhydrous ammonia. At the request of the regulated community, this prohibition is being modified to allow its use provided certain safety and potential environmental impact issues are addressed. None of the adjoining air districts have a prohibition on the use of anhydrous ammonia. (The SL O and VC rules limit the amount of ammonia from an emission control system to 20 parts per million by volume. Neither the SBC or the SJV engine rules have such a limit.)

7. Engine Inspection and Maintenance Plans. The existing and proposed revised SBC e ngine rule includes an engine Inspection and Maintenance Plan. Also, all adjoining air districts require such plans.

VC and SLO requirements indicate inspections shall be conducted every quarter or after every 2,000STAFF REPORT

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Santa Barbara County APCD

hours of engine operation; and, in n o event, shall the frequency of inspection be less than once per year. SJV Rule 4701 (Phase 1) and portions of the SJV Rule 4702 (Phase 2) require quarterly inspections. a However, the SJV Rule 4702 (Phase 2) requires monthly inspections for prime engines operating in excess of 200 hours per year and other engines not subject to the quarterly inspection frequency.

None of the adjoining air district rules have a provision that an excessive portable analyzer instrument reading will not be a violation if cor rective action is taken within 15 days of finding. This is a provision in the current and the proposed modified Rule 333.

8. Compliance Plans. The existing and proposed revised SBC engine rule includes a requirement for Compliance Plans. The SJV engine rule has a section on Emission Control Plans that requires the owner to inform the Control Officer of the actions to be taken to satisfy the emission requirements of the rule. The SJV provision on Emission Control Plans is essentially the same as the SBC provisions on Compliance Plans.

The SLO and VC Engine Operator Inspection Plan provisions include a requirement for identification of the type of NOx control system to be used for compliance. Other than these requirements for identification, SLO, and VC do not have specific requirements for a Compliance Plan or an Emission

Control Plan.

9. Source Testing. The existing and proposed revised SBC engine rule includes requirements for testing. All of the adjoining air districts have a requirement for condu cting source tests, with specificity on the source test methods. The source testing frequency ranges from annually to every 8,760 hours of operation or 3 years, whichever occurs first. The ARB RACT/BARCT Determination specifies a source testing frequency of at least once every 24 months. The SBC biennial source testing frequency

is consistent with the ARB

- recommended testing frequency.

10. Recordkeeping. SJV, SLO, SBC, and VC engine rules have recordkeeping provisions on engine operating logs, inspecti on and maintenance, and CEMS data. SBC also includes recordkeeping provisions for engines subject to the less than 200 hours per year exemption and Engine Heat Input

Verification Plans.

11. Compliance Schedule. The existing and proposed modified SBC Rul e 333 includes a provision on compliance schedules. The proposed amended SBC Rule 333 compliance schedule is complicated somewhat by the fact that some engine categories have new and stricter requirements being phased in by the same rule. All of the adjo ining air district engine rules include a compliance schedule. SJV has taken the approach of issuing separate rules for phased approaches when implementing new emission limits (e.g., Rule 4701 and Rule 4702).

12. Reporting. The existing and proposed mod ified SBC Rule 333 do not require annual reporting. Likewise, the SJV engine rules do not have annual reporting provisions. However, the SLO and VC engine rules require annual reports.

a SJV Rule 4702 (Phase 2) allows quarterly engine inspections for engines that are used for emergency purposes that have no more than 200 hours per year of maintenance operations and engines that operate no more than 200 hours

per year.THIS PAGE INTENTIONALLY LEFT BLANKSTAFF REPORT

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### Appendix L

Santa Barbara Cou nty Impacts of the Revised Rules to Industry and the APCD

Industry Impacts

The revised engine exemptions and rules will cause varying degrees of impacts depending on the engine size, engine type, and its operating schedule. Sources with permitted engi nes rated at less than 50 brake horsepower are not subject to Rule 333 and will experience fewer impacts than sources with engines needing to comply with Rule 333. The following provides information on the impacts from the various rule revisions and the s ources potentially
impacted by the changes



### .

R ULE 

### 102, D EFINITIONS

The APCD is unaware of any source that will be impacted by the addition of the new definitions.



### R ULE 

### 201, P ERMITS 

### R EQUIRED

Impacts from the Rule 201.D changes are interrelated with the d eletion of the Rule 202 construction engine exemption and the new Rule 202 exemptions for 1) pile drivers, cable

- laying and derrick barges and their associated marine vessels, and 2) specialty equipment. There are no known sources that will be specificall y impacted by the proposed revisions to Rule 201.



### R ULE 

### 202, E XEMPTIONS TO 

### R ULE 

### 201

In general, the APCD is unaware of specific sources that will be impacted by the numerous minor and

administrative

- type Rule 202 changes. Some of the new exemptions were added in response to requests by the regulated community. Thus, these are expected to provide beneficial impacts to industry.

The removal of the construction exemption will require construction engine owners to either register in the statewide portable equipment registration program or obtain an APCD Permit to Operate. Due to construction engines being currently exempt from permitting, the APCD has no data available to determine which owners will be impacted by this change.

Other exemption changes th at will cause engine permitting impacts include the revisions to the spark ignition engine exemption and the repeal of the offshore well drilling exemptions. The following provides information on the impacts from those changes.

Some sources will be aff

ected by the 202.F.1.f general spark ignition engine exemption threshold revisions and the 202.F.6 offshore drilling equipment exemption deletion. The APCD does not know the exact number or location of the engines that will require permits as a result of the rule revision because of the current “permit exempt” status for these engines. Under the proposed amendments, there will be several sections in Rule 202.F that will make currently exempt engines subject to permitting. As shown in Appendix B, 89 engin es in the following categories will become subject to permitting due to the various Rule 202 changes:

1. 16 spark ignition engines in the 50 to 100 brake horsepower range (reference Rule 202.F.1.f).

2. 26 spark ignition engines in the greater than 20 to l ess than 50 brake horsepower range where the aggregate rating is 400 bhp (reference Rule 202.F.1.f).

3. 40 spark ignition engines that have been derated (reference Rule 202.F.1.f). a

a The removal or modification of an engine derating mechanism will constitute a modification requiring APCD approval in the form of an Authority to Construct. Such a proposal will be subject to Regulation VIII , New Source

Review.STAFF REPORT

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June 19, 2008

4. 7 well drilling engines (reference deleted Rule 202.F.6).

Based on ou r 2005 inventory (and as detailed in Appendix B), 9 companies (all associated with oil and gas production or processing) will need to obtain permits for 89 engines due to changes to Rule 202.F.

Table 1 summarizes the anticipated fee impacts due to the i nitial permitting, equipment modifications, and the initial source testing of the engines becoming subject to Rule 333 limits for the first time. a The fee impact from the initial permitting of the 89 engines that lose their exemption is $51,118. b The to tal fee for the ten engines to be modified to comply with Rule 333 emission limits is $6,4589 c One facility, Venoco‟s Platform Holly, has three well drilling engines that are already controlled, but will require a source test. The fee associated with the testing of those engines is estimated to be $2,237. Three other sources have engines that will require source testing:

1. Pacific Operators Offshore, Inc. (SSID 08801)

– fee to be assessed on the cost reimbursement basis.

2. Purisima Hills LLC

– Barh am Ranch, H.P. Boyne Lease (SSID 01153)

– the total fee for the source testing of the six engines is $3,404.

3. SBC Resource Recovery and Waste Mgmt Div., County of Santa Barbara

– Foxen Canyon (SSID 03706)

– the total fee for the source testing of the tw o engines is $1,849.

There are nine currently permitted engines rated less than 50 brake horsepower that will no longer be subject to permitting under the proposed amended Rule 202.F.1.f exemption. Table 2 (on page L

- 5) lists the engines and

indicates th ere will be an overall reduction of $1,771 in triennial reevaluation fees for the two sources.

Table 3 (on page L

- 7) provides a summary of the estimated company compliance cost impacts associated with engines needing to comply with the emission limits for the first time or needing to comply with the revised emission limits. These costs are in addition to the source testing, permitting, and/or permit modification fees

shown in Table 1.

a Sources will have additional ongoing fee impacts (e.g., increased annual fees, reevaluation fees for engines that become subject to permitting, and recurring source test fees if subject to the emission limits).

b Includes the applica tion filing fee and the PTO fee as shown in Table 1. Some sources have their fees assessed on a cost reimbursement basis for which there is no present estimate.

c Includes the ATC and PTO filing fees, the ATC modification fee, and the PTO modification fee as shown in Table 1. The three sources anticipated to have the ten engines requiring modification are shown in Appendix H and include: 1) County of Santa Barbara

– Foxen Canyon (SSID 3706), 2) Pacific Operators Offshore, Inc.

– Platforms Hogan and Houc hin (SSID 8001), and Purisima Hills

– Barham Ranch, H.P. Boyne Lease (SSID 01153). Some sources have their fees assessed on a cost reimbursement basis for which there is no present estimate.STAFF REPORT

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Santa Barbara County APCD



### Table 1. SUMMARY OF THE ANTICIPATED FEE IMPACTS DUE TO INITIAL ENGIN E PERMITTING, PERMITS FOR ENGINE MODIFICATIONS, AND THE INITIAL ENGINE SOURCE TESTS a

Col.1 Col.2 Col.3 Col.4 Col.5 Col.6 Col.7 Col.8 Col.9 Col.10 Col.11 Col.12

Company Description and Stationary Source Description Stationary Source No. Initial App'n Fee Initial PTO Fee Increased Annual Emission Fee Increased Air Toxic Program

Fee Increased AQAP Fee App'n Fee for ATC Mod'n ATC Mod'n Fee Source Test Fee App'n Fee for PTO Mod'n PTO Mod'n Fee Source's

Overall

Fee Impacts

B.E. Conway Energy, Inc., Conway Oil, Inc.

- Magenheimer 01944 $325 $219 $0 $0 $0

- - - - - $544

Catco Energy 01510 $325 $1,900 $3,657 $286 $1,553

- - - - - $7,721

Elysium Russell, LLC., Elysium Russell, LLC. 04639 $325 $2,115 $5,353 $326 $2,403

- - - - - $10,522

ExxonMobil Production Company, Exxon

- SYU Project 01482 $325 Reimb. $448 $0 $900

- - - - - $1,673

Greka Oil & Gas, Inc., Clark

Avenue Source 02200 $325 $1,967 $111 $8 $607

- - - - - $3,018

Greka Oil & Gas, Inc.,

Continental 05032 $325 $286 $0 $0 $0

- - - - - $611

Greka Oil & Gas, Inc., Gato Ridge 02680 $325 $1,415 $92 $10 $40

- - - - - $1,882

Greka Oil & Gas, Inc., Los

Flores 08678 $325 $1,955 $0 $0 $0

- - - - - $2,280

Greka Oil & Gas, Inc., SMV

East 08675 $325 $1,543 $1,169 $0 $517

- - - - - $3,555

Greka Oil & Gas, Inc., Zaca

Field 08702 $325 $669 $698 $77 $311

- - - - - $2,079

Pacific Operators Offshore, LLC., Pacific Operators

- Carpinteria 08001 $325 Reimb. $1,606 $0 $1,120 $325 Reimb. Reimb. $325 Reimb. $3,700

a Based on the 2005 Emission Inventory. Data for sources with m ultiple engines is summarized and shown in a single row.STAFF REPORT

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Santa Barbara County APCD Col.1 Col.2 Col.3 Col.4 Col.5 Col.6 Col.7 Col.8 Col.9 Col.10 Col.11 Col.12

Company Description and Stationary Source Description Stationary Source No. Initial App'n Fee Initial PTO Fee Increased Annual Emission Fee Increased Air Toxic Program

Fee Increased AQAP Fee App'n Fee for ATC Mod'n ATC Mod'n Fee Source Test Fee App'n Fee for PTO Mod'n PTO Mod'n Fee Source's

Overall

Fee Impacts

Plains Exploration &
Production Company a 04632

- - - $2,4 04

- $162

- $1,076

- - - - - - $3,642

Purisima Hills LLC, Purisima

Hills LLC

- H.P. Boyne,

Barham Ranch 01153 $325 $1,741 $725 $0 $323 $325 $1,741 $3,404 $325 $1,741 $10,651

Santa Maria Refining Company, Santa Maria Refining

- Armelin 03736 $325 $1,107 $0 $ 0 $0

- - - - - $1,432

SBC Resource Recovery & Waste Mgmt Div., County of

Santa Barbara

- Foxen Canyon 03706

- - - - - $325 $513 $1,849 $325 $513 $3,525

Venoco, Inc., Venoco

- Ellwood, Platform Holly 01063 $325 $11,872 $596 $282 $204

- - $2,237

- - $15,51 6

Subtotals $4,550 $26,789 $12,051 $827 $6,901 $975 $2,254 $7,490 $975 $2,254

Fee Impact from the Initial Permitting of the ICEs Becoming Subject to Rule 201, Permits Required: $51,118 b Fee Impact from Engine Modifications to Comply

with the Emiss ion Limits: $13,949 c

Total $65,067

a The fee decreases are due to 8 currently permitted engines becoming exempt under the proposed amended Rule 202.F.1.f provisio ns.

b Sum of Columns 2

– 6.

c Sum of Columns 7

– 11.STAFF REPORT

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Santa Barbara County APCD



### Table 2. SUMMARY OF ANTICIPATED PERMIT REEVALUATION FEES REDUCED

DUE TO CURENTLY PERMITTED ENGINES BECOMING EXEMPT

BY THE PROPOSED AMENDED RULE 202 a

STATIONARY SOURCE FACILITY SSID FID DEVICE No. DEVICE

DE SCRIPTION RATING (Bhp) REDUCED

REEVAL FEES

E & B

- South Cuyama E & B IC Engines 01073 08916 006338 IC Engine: W

- 40 24 $93
Pt. Pedernales/Lompoc Oil

Fields Lompoc IC Engines 04632 04218 004495 IC Engine: #12020 46 $216

Pt. Pedernales/Lompoc Oil

Fields Lompoc IC Engines 04632 04218 004498 IC Engine: #7440 46 $216

Pt. Pedernales/Lompoc Oil

Fields Lompoc IC Engines 04632 04218 004504 IC Engine: #11605 39 $175

Pt. Pedernales/Lompoc Oil

Fields Lompoc IC Engines 04632 04218 004505 IC Engine: #9709 46 $216

Pt. Pedernales/Lompoc Oil

Fields Lompoc IC Engines 04632 04218 004506 IC Engine: #9305 46 $216

Pt. Pedernales/Lompoc Oil

Fields Lompoc IC Engines 04632 04218 004508 IC Engine: #8501 46 $216

Pt. Pedernales/Lompoc Oil

Fields Lompoc IC Engines 04632 04218 0 04509 IC Engine: #8483 46 $216

Pt. Pedernales/Lompoc Oil

Fields Lompoc IC Engines 04632 04218 007034 IC Engine: #9229 46 $205

TOTAL $1,771

a Engines shown in Table 2 are currently permitted because the total aggregate of engines in the range of 20 to 100 bhp at the source exceeds 50 0 bhp. These engines are slated to become exempt because the total aggregate brake horsepower rating of the engines in the range o f 20 to < 50 bhp at the source does not exceed 400 bhp.STAFF REPORT

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Santa Barbara County APCD 

### Table 3. SUMMARY OF THE ANTICIPATED COMPLIANCE COST IMPACTS a

Company Des cription and Stationary Source Description Stationary Source No. Initial Source Test Cost Total Capital Investment Annual Inspection and Monitoring Costs Increased Annual Operating & Maintenance

Cost Sum of the

Listed Cost Impacts to

the Source

Pacific Operators Offshore, LLC, Pacific Operators

- Carpinteria 08001 $5,200 $4,000 $9,600 $4,000 $22,800

Purisima Hills LLC

- Barham Ranch, H.P. Boyne Lease 01153 $12,480 $12,000 $14,400 $12,000 $50,880

SBC Resource Recovery & Waste Mgmt Div., County of Santa Barbara

- Foxen Canyon 03706 $5,200 $4,000 $4,800 $4,000 $18,000

Venoco, Inc., Venoco

- Ellwood, Platform Holly 01063 $7,800 $0 $14,400 $0 $22,200

Total $113,880



### R ULE 

### 333, C ONTROL OF 

### E MISSIONS FROM 

### R ECIPROCATING 

### I NTERNAL 

### C OMBUSTION 

### E NGINES

Impacts from the proposed amended Rule 333 will occur for two general reasons: 1) the population of engines subject to Rule 333 is increasing and 2) Rule 333 requirements are being revised. Table 4 lists the engines that are or will become subject Rule 333. Eng ines that are/will be subject to the less than or equal to 200 hour per year recordkeeping provisions of Rule 333 are included in this table as well.

Table 5 summarizes the revised Rule 333 provisions that will apply. The requirements are broken out bas ed on engines being subject to certain exemptions or being subject to the Rule 333 emission limits. Table 5 includes notes on the requirements that are new and revised.

a Based on the 2005 Emission Inventory. These costs are in addition to any permitting or source testing fees assessed by the APCD.STAFF REPORT

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Santa Barbara County APCD 

### Table 4. ENGINES THAT ARE OR WILL BECOME SUB JECT RULE 333 a

Company Description and Stationary Source Description Stationary Source

No. Device No. Device Becoming Subject to Rule 333 Currently Subject to Emission Limits Becoming Subject to Emission Limits Engine is Exempt from Emission Limits Becau se it Burns Landfill Gas Current Permit has a "< 200 Hours per Year" Limit Engines Becoming Subject to Rule 333 with Operations < 200 Hours per Year per 2005 Emission Inventory b

Adams Services, Inc., Adams

Services

- Degassing 10242 009953 IC Engine: Deg assing Unit X

BreitBurn Energy Company LP, BreitBurn Energy

- Orcutt Hill 02667 004305&

004306 IC Engines: (#12205 & #12195) X

BreitBurn Energy Company LP, BreitBurn Energy

- Orcutt Hill 02667 004434 &

004435 IC Engines: (#19766 & #12163

-

Fox In jection) X

City of Lompoc, City of Lompoc

- WWT Plant 01708 001192, 001193,

& 001194 IC Engines: Air Compressors X

DCOR, LLC, Platform Habitat 08012 004972, 004973,

& 004985 IC Engines: South Crane, North

Crane, & Compressor X

DCOR, LLC , South County/Dos Cuadras, PF A 08003 004872 &

004873 IC Engines: South Crane & North

Crane X

DCOR, LLC, South County/Dos Cuadras, PF B 08003 004886 &

004887 IC Engines: 15

- Ton Pedestal

Crane (South Crane) & 25

- Ton Pedestal Crane (North Crane) X

DCOR, LLC, South County/Dos Cuadras, PF

Hillhouse 08003 004904 IC Engine: 15

- Ton Pedestal (South) Crane X

DCOR, LLC, South County/Dos Cuadras, PF

Hillhouse 08003 004905 IC Engine: 25

- Ton Pedestal (North) Crane X

DCOR, LLC, South County/Do s Cuadras, PF C 08003 004923 IC Engine: 15

- Ton Pedestal Crane (South Crane) X

a Based on the 2005 Emission Inventory.

b The APCD assumes that thes e engines will be subject to Rule 333 but exempt from the emission limits and the permit will have a condition limiting opera tions to less than 200 hours per year.STAFF REPORT

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June 19, 2008

Santa Barbara County APCD Company Description and Stationary Source Description Stationary Source

No. Device No. Device Becoming Subject to Rule 333 Currently Subject to Emission Limits Becoming Subject to Emission Limits Engine is Exempt from Emission Limits Becau se it Burns Landfill Gas Current Permit has a "< 200 Hours per Year" Limit Engines Becoming Subject to Rule 333 with Operations < 200 Hours per Year per 2005 Emission Inventory b

DCOR, LLC, South County/Dos Cuadras, PF C 08003 004924 IC Engine: 25

- Ton Pedestal Crane (North Crane) X

DCOR, LLC, South County/Dos Cuadras, PF Henry 08003 004938 IC Engine: 15

- Ton Pedestal (South) Crane X

DCOR, LLC, South County/Dos Cuadras, PF Henry 08003 004939 IC Engine: 25

- Ton Pedestal (North Crane) X

E & B Natural Resources Mgt. Corp., E & B

- South Cuyama 01073 006388, 006389, 006390, 006391, 006392, 006393, 006394, 006395, 006396, 006397, 006400, 006401, 006402, 006403,

& 006404 15 IC Engines: W

- 2, W

- 3, W

- 8,

W

- 4, W

- 12 Wastewater Inj., W

- 11,

W

- 15, W

- 42 Wastewater Inj., B

- 5 Wastewater Inj., B

- 6, HRA #9, HRA #10, HRA #11, HRA #12, &

Diesel Fired Unit X

ExxonMobil Production Company, Exxon

- SYU Project, PF Hondo 01482 004956 &

004957 IC Engines: West and East Cranes X

ExxonMobil Production Company, Exxon

- SYU Project, PF Harmony 01482 005326 Pedestal Crane East X

ExxonMobil Producti on Company, Exxon

- SYU Project, PF Harmony 01482 005346 Auxiliary Drill Generator X X

ExxonMobil Production Company, Exxon

- SYU Project, PF Heritage 01482 005350 Pedestal Crane East X

ExxonMobil Production Company, Exxon

- SYU Project, PF Heri tage 01482 005370 Auxiliary Drill Generator X X

Greka Oil & Gas, Inc., Casmalia 04630 004471 IC Engine: (#4gv1401) XSTAFF REPORT

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Santa Barbara County APCD Company Description and Stationary Source Description Stationary Source

No. Device No. Device Becoming Subject to Rule 333 Currently Subject to Emission Limits Becoming Subject to Emission Limits Engine is Exempt from Emission Limits Becau se it Burns Landfill Gas Current Permit has a "< 200 Hours per Year" Limit Engines Becoming Subject to Rule 333 with Operations < 200 Hours per Year per 2005 Emission Inventory b

Greka Oil & Gas, Inc., Cat Canyon 02658 006466, 006467, 006468, &

007289 IC Engines: Gas Compressor

(12253), Waukesha (110007

- Inj. #2), #20 6LRZ (#912330) (NSCR), & Compressor #1

#F3521GSI X

Greka Oil & Gas, Inc., Clark

Avenue Source 02200 004178 &

004179 IC Engine: #912330 & IC Engine:

#912331 X

Greka Oil & Gas, Inc.,

Continental 05032 003155 IC Engine: Well #2: (1 1705) X X

Greka Oil & Gas, Inc., Gato Ridge 02680 005203, 005204, 005205, 005206,

& 005207 IC Engines: Pumping Units X X

JEM Degassing, JEM Degassing 08685 006028 &

006029 IC Engines: Degassing (#16828

䆽) X

Lash Construction, Lash Con st. (5 S. Calle Cesar Chavez ) 10309 010082 Diesel IC Engine (may be superseded by DID 107679) X

Mafi

- Trench Corporation, Mafi

Trench 01717 001195 IC Engine: Air Compressor X

MM Tajiguas Energy LLC/NEO Tajiguas LLC, County of SB

Tajiguas Landfi ll 03707 006523 IC Engine / Generator X

Nieto & Sons, Incorporated,

Nieto & Sons

- Degassing 08727 006027 IC Engine: Degassing Unit X

Pacific Operators Offshore, LLC, Pacific Operators

- Carpinteria, PF Hogan 08001 004848 IC Engine: South Crane X

Pacific Operators Offshore, LLC, Pacific Operators

- Carpinteria, PF Hogan 08001 004849 IC Engine: North Crane X

Pacific Operators Offshore, LLC, Pacific Operators

- Carpinteria, PF Houchin 08001 004860 IC Engine: South Crane XSTAFF REPORT

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Santa Barbara County APCD Company Description and Stationary Source Description Stationary Source

No. Device No. Device Becoming Subject to Rule 333 Currently Subject to Emission Limits Becoming Subject to Emission Limits Engine is Exempt from Emission Limits Becau se it Burns Landfill Gas Current Permit has a "< 200 Hours per Year" Limit Engines Becoming Subject to Rule 333 with Operations < 200 Hours per Year per 2005 Emission Inventory b

Pacific Operators Offshore, LLC, Pacific Operators

- Carpinteria, PF Houchin 08001 004861 IC Engine: North Crane X

Pacific Operators Offshore, LLC, Pacific Operators

- Carpinteria, PF Hogan 08001 007107 IC Engine: Well Service Rig X X a

Pacific Operator s Offshore, LLC, Pacific Operators

- Carpinteria, PF Houchin 08001 007108 IC Engine: Well Service Rig X X a

Plains Exploration & Production Company, Pt. Pedernales/Lompoc Oil Fields 04632 004494 IC Engine: Purisima # 86 (#12130) X

Plains Explor ation & Production Company, Pt. Pedernales/Lompoc Oil Fields,

PF Irene 04632 005082 &

005083 IC Engine: North Crane & IC

Engine: South Crane X

Purisima Hills LLC

- Barham Ranch, H.P. Boyne Lease 01153 005908, 005909, 005910, 005911, 005912, &

009015 IC Engines: Well Pumps &

Natural Gas

- Fired Unit X X a

Santa Barbara Sand & Top Soil Corp., Santa Barbara Sand & Top Soil

- Ellwood 03695 003318 Material Plant Diesel Engine X

Santa Maria Refining Company, Santa Maria Refining

- Armelin 03736 0059 47, 005949, 005950, &

006231 IC Engines X X

SBC Resource Recovery & Waste Mgmt Div., County of

Santa Barbara

- Foxen Canyon 03706 104269 &

106429 Diesel Fired IC Engines (Gen 4

and 5) X b

a Requires the use of an emission control technique.

b Requires the application of an enhan ced emission control technique to both engines.STAFF REPORT

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Santa Barbara County APCD Company Description and Stationary Source Description Stationary Source

No. Device No. Device Becoming Subject to Rule 333 Currently Subject to Emission Limits Becoming Subject to Emission Limits Engine is Exempt from Emission Limits Becau se it Burns Landfill Gas Current Permit has a "< 200 Hours per Year" Limit Engines Becoming Subject to Rule 333 with Operations < 200 Hours per Year per 2005 Emission Inventory b

SBC Resource Recovery & Waste Mgmt Div., County of

SB

- Taji guas Landfill 03707 106679 Diesel Fired IC Engine (WP01) X

Southern California Gas Company, So Cal Gas

- La

Goleta 05019 001199, 001200, 001201, 001202, 001203, 001204, 001205, 001206, 005666, 005667, 005668, &

005669 Eight Gas Compressor IC Engines:

Number 2, 3, 4, 5, 6, 7, 8, & 9

and four Electrical Generators: Number 1A, 2A, 3A, & 20A X

The Point Arguello Companies, The Point Arguello Project, PF

Harvest 01325 005000, 005001,

& 00502 IC Engines: Cranes (800A, 800B,

&CR801) X

The Point Arguello Companies, The Point Arguello Project, PF

Hermosa 01325 005029 &

005030 IC Engines: West & East Crane X

The Point Arguello Companies, The Point Arguello Project, PF Hidalgo 01325 005058 &

005059 IC Engines: West & East Crane X

Un ited States Air Force, Vandenberg Air Force Base 01195 006088 IC Engine: (Building 511) X

United States Air Force, Vandenberg Air Force Base 01195 006182 IC Engine: Electrical Generator (Building 7425) X

Vandenberg Air Force Base, 30 CES/CEV, V andenberg Air

Force Base 01195 006184, 006185,

& 006202 IC Engine (Hercules): Compressor,

IC Engine (Deere): Compressor, & IC Engine: Diesel (Building 7437) X

Venoco, Inc., Venoco

- Carpinteria 00027 000201, 000202, 000203, 000204, 000205, 00206,

100 222, &

008166 Gas Compressor ICEs: IR #1,

SACS Cooper (CA

- 83), IR #3, IR #4, IR #5, IR #6 & G

- 1; and a

Diesel

- Fired ICE X

Venoco, Inc., Venoco

- Ellwood 01063 002336 IC Engine: Pedestal Crane X

Venoco, Inc., Venoco

- Ellwood 01063 009130, 00913 1,

& 009132 IC Engines: Drilling Rig

Generators #1, #2, & #3 X XSTAFF REPORT

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Santa Barbara County APCD Company Description and Stationary Source Description Stationary Source

No. Device No. Device Becoming Subject to Rule 333 Currently Subject to Emission Limits Becoming Subject to Emission Limits Engine is Exempt from Emission Limits Becau se it Burns Landfill Gas Current Permit has a "< 200 Hours per Year" Limit Engines Becoming Subject to Rule 333 with Operations < 200 Hours per Year per 2005 Emission Inventory b

Venoco, Inc., Venoco

- Ellwood

Marine Terminal 01085 002437 &

002438 IC Engine: VRU & IC Engine:

Generator X

Totals 23 78 11 a 1 20 12

a Some of these engines already comply with the emission limits (e.g., Venoco‟s devices numbered 009130

– 009132). For a list of engines requiring an emission control technique or an enhanced emission contro l technique, see Appendix H, Table 1, Emission Reductions or see the items with footnotes “a” and “b” on page

L

- 10.STAFF REPORT

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Santa Barbara County APCD 

### Table 5. SUMMARIZED RULE 333 REQUIREMENT S FUEL MONITORING AND RECORDKEEPING (333.B.1.a) ENGINE IDENTIFICATION METHOD (333.D.1) NONRESETTABLE ELASPED OPERATING TIME METER

(333.D.2) NONRESETTABLE FUEL METER (333.D.3) RECORDKEEPING (333.J) ONGOING USE OF AN EMISSION CONTROL TECHNIQUE (333.E) NEW EMISSION CONTROL TECHNIQUE (333.E) CONTINUOUS MONITORING SYSTEM (333.D.4) INSPECTION AND MAINTENANCE PLAN (333.F) REVISED I&M PLAN (333.F) COMPLIANCE PLAN (333.G) REVISED COMPLIANCE PLAN (333.G) SOURCE TESTING (333.I)

ENGINE S EXEMPT FROM RULE 333 EMISSION LIMITS

1. ENGINES BURNING 75% LANDFILL GAS (333.B.1.a) X

2. PERMITTED ENGINES OPERATING < 200 HOURS/YEAR (333.B.2) X X X

ENGINES SUBJECT TO RULE 333 EMISSION LIMITS a

3. TIERED COMPRESSIO N IGNITION ENGINES (333.B.3)

- New Provision X X X X X b X X X X a

4. EXISTING ENGINES PREVIOUSLY

SUBJECT TO RULE 333 EMISSION

LIMITS X X X X X X a X X X a

5. EXISTING ENGINES BECOMING

SUBJECT TO RULE 333 EMISSION

LIMITS X X X X X a X X c X a

6. NEW ENGINES X X X X X a X X X c X a

Table 6 is a summary of the proposed NOx emission limit changes.

a Emission limits for the following are being revised: Compression ignition engine NOx limits are being lowered slightly and n ew ROC and CO limits are being

established for the first time. Lean

- burn spark ignition engines rated in the 50 to less than 100 bhp range will have an increase in the NOx limit. Cyclically

loaded rich

- burn spark ignition engines will have an increased NOx limit. Se e Table 5 for additional details.

b For ARB or EPA Tiered compression ignitions, this requirement is triggered if a portable analyzer reading exceeds 560 part pe r million of NOx at 15% oxygen on a dry basis.

c ARB or EPA Tiered compression ignitions are ex empt from the requirement for a Compliance Plan per Rule 333.B.3. RE QUIREMENTS

S

CATEGORIESSTAFF REPORT

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Santa Barbara County APCD 

### Table 6. SUMMARY OF THE PROPOSED NOx EMISSION LIMIT CHANGES

Engine Type Category

Number Current NOx Limits Proposed NOx Limits Effect of Change

% Control ppmv a % Control ppmv a

Rich

- Burn Noncyclically

Loaded Spark Ignition Engines 1 90 50 90 50 None

Lean

- Burn Noncyclically

Loaded Spark Ignition Engines in the 50 and greater to less than 100 bhp Range 2 80 125

- 200 Increased emission

limit

Lean

- Burn Noncyclically

Loaded Spark Ignition Engines Rated 100 bhp or Greater 3 80 125 80 125 None

Cyclically

- Loaded Spark Ignition Engines 4 90 50

- 300 Increased emission

limit Compression Ignition Engines

and Dual

- Fuel Engines 5

- 797 40 700 Decreased emission

limit

Categories 1 and 3 have no changes to the NOx emission limits; therefore, there will be no impacts to engines in those catego ries.

Categories 2 and 4 have increases to their emission limits. Without knowing if there are engin es affected by these changes, these limit increases would seem to equate to higher emissions. However, the APCD inventory indicates that there are no currently permitted engines in Categorie s 2 or 4 that are subject to the Rule 333 NOx limits. Therefore, there will be no increases in NOx emissions from Category 2 and Category 4 engines as a result of increasing the Rule 333 emi ssion

limits.

Category 5 has a slight decrease in the NOx emission limit, but all engines currently subject to the emission lim it are expected to comply with the lower limit by using low emission tuning techniques.

On existing engines becoming subject to Rule 333 emission limits due to the permit exemption change, staff anticipates that t he six engines in the 50 and greater

to less than 100 brake horsepower range will be in Category 4. Further, these engines will comply with the emission limits by using the lean

- burn tuning technique. The three offshore well drilling spark ignition engines becoming subject to the emission limi ts are expected to already comply with the Category 1 limits. The two offshore well drilling compression ignition engines becoming subject to the emission limits are expected to comply by retarding the fuel injection timing and/or performing engine mainte nance, if these engine do not already meet the Category 5 limits. Other Category 5 engines are expected to either already comply with the stricter emission limits or will be able to with additional injection timing retard tuning.

a Dry, at 15% oxygen.STAFF REPORT

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Santa Barbara County APCD 

### APCD Impacts

The infl ux of permit applications required by the Rule 202 engine exemption revision will create a short

- term spike in workload. However, we will not be able to assess long

- term impacts on workload until the applications have actually been submitted and we have i ssued the permits. Based on our emission inventory, we expect to receive 14 applications for 89 existing engines requiring permits due to the rule revision. The known engines that will require permits from the Rule 202 revision are identified in Appendix B

.

In addition to the initial engine permits necessary because of the Rule 202 revision, there will be applications needed for the control techniques or enhanced control techniques to comply with the Rule 333 emission limits. Staff analysis indicates th at there will be three applications for such control techniques on 10 engines. The engines requiring new or enhanced control techniques are listed in Appendix H , Table 1, Emission Reductions.

Adding engines to the population of engines subject to Rule 33 3 and enhancing the compliance requirements for engines subject to the emission limits will cause APCD workload impacts. Staff anticipates that 19 sources will need to submit revised Inspection and Maintenance Plans and Compliance Plans. Three stationary sources (01063, 01153, and 08001) will need to submit these plans for 11 engines that are becoming subject to Rule 333 emission limits for the first time (as sho wn in Appendix C or Appendix L , Table 3).

There will also be impacts due to additional engine s needing to be inspected and source tested. Engines located offshore will require additional compliance logistics. Based on the APCD inventory, five of the engines becoming subject to the Rule 333 source testing requirements are located offshore. The o ther six engines are located at the Barham Ranch site (Northern Santa Barbara County).

Staff may encounter additional permit exemption requests that do not relate to Rule 202.F.1.f. For example, sources may apply for the new specialty equipment exemptio n, the revised gas turbine exemption, or the new winery exemption. Staff expects that the applications for the specialty equipment exemption will occur infrequently due to the availability of equipment registered in the portable equipment registration pro gram. Further, the number of sources seeking the revised gas turbine exemp tion or the winery exemption is anticipated to be in the one to three

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### Appendix M

Santa Barbara County Overviews of Proposed Amended Rule 333 Provisions on Applicability; Engine Identification, Meters, and Continuous Monitoring Systems; Emission Limits; and Compliance ScheduleSTAFF REPORT

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### Appendix N

Santa Barbara County Frequently Asked Questions (Ver. 1.5) a



### Frequently Asked Questions
Rule 202

- Exceptions to Rule 201

 Temporary Equipment

 Temporary Equipment

– Short Term Use

 Temporary Equipment

– Examples*

 Temporary Equipment

– Method for Determination Compliance with the 60

- day and 1 ton per 12 Months
Provision

 Equipment “Stacking”

 Construction

 Construction

– Projected Actual Emissions and Offsets

 Construction Engines

 Derated Engines

- Permitting Requirements

 Derated Engines

- Certificat ions and Enforceable Deratings

 Solvent Wipe Cleaning Exemption Recordkeeping

 Engine Electronic Fuel Metering

 Various Location Equipment Exemption

Temporary Equipment [Existing FAQ on the SBCAPCD Web Site ]

Q: Please clarify the temporary equipment exemption. What is the distinction between the 60 day period limit and the consecutive 12 month peri od? For adding up the emissions for a source to comply with the 1 ton limit, do we total all the temporary equipment emissions or do we treat each emissions unit separately with its own emission limit?

A: The 60 day period applies to individual emission units and limits any one unit from operating under the exemption for any time period exceeding 60 days. This 60 day period must be within a consecutive time frame and is not intended to allow for sporadic use through out the year. The 12 month consecutive time period ensures that the intent of the exemption is maintained by disallowing use of the same emission unit for a 120 day period if the calendar year basis was used. The 1 ton limit applies all emission units within a consecutive 12 month period.

Temporary Equipment

– Short Term Use [Existing FAQ on the SBCAPCD Web Site ]

Q: Does the Temporary Equipment exemption (Section D.5) include short term o peration of permitted equipment in a way that is not permitted, say a short term trial of equipment limits, or a "fault finding" search to determine why equipment can't quite meet BACT requirements under certain conditions?

A: No. The exemption is for n ew equipment only. Testing, shake

- down and debugging activities for compliance with BACT standards is why the APCD has a Source Compliance Demonstration Period during the construction phase (i.e., with ATC permit issuance). Once the source has a Permit to Operate, they may seek administrative relief via APCD Regulation V (Variances).

a Upon adoption of the proposed amended Rule 202, the APCD intends to place these proposed FAQs on the SBCAPCD Web Page (i.e., the Web Page at: http://www.sbcapcd.org/eng/nsr/faq_202.htm#201

- 1 ). To provide a comprehensive overview of the existing and proposed FAQs, this document includes the existing FAQs that interrelate to proposed new FAQs.STAF F REPORT

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Santa Barbara County APCD Temporary Equipment

– Examples [Existing FAQ on the SBCAPCD Web Site ]

Q: Examples of temporary activities that qualify for the temporary equipment exemption (202.D.5) include, but are
not limited to:

A:

 ICE's from cranes, welders, jack hammers, etc. used during the demolition of a source or part of a source.

 Replaceme nt or use of equipment during a breakdown situation.

 Demonstration equipment being used to determine feasibility (not lab test equipment).

 Any short

- term, one

- time project that requires equipment that pollutes is eligible if it meets the 1 ton criteria

o f all affected pollutants. The Portable Equipment Registration Rule is intended to handle portable equipment that emits more and is used for longer periods of time.

 While written notification is required, the project may commence as soon as notification i s made without waiting for approval from the APCD. However, if a project commences with equipment that is later found not eligible for the exemption, the commencement will constitute a violation of the APCD's Rules and Regulations

Temporary Equipment

– Method for Determination Compliance with the 60

- day and 1 ton per 12
Months Provision [Reference Proposed Amended Rule 202.D.5]

Q: Can the APCD clari fy how the 60

- day provision works in practice? That is, how compliance with the rule’s 60 days and 1 ton per 12 months provisions are determined.

A: The 60 day time period is a continuous period starting the first day the equipment is used. Once starte d, the 60 day period is not stopped and re

- started. The equipment may be used any time within the 60 day period and may leave and return to the site. Compliance with 60 day requirement is based on the start date. Compliance with the 1

ton requirement is based on a compilation of the consecutive 12

- month emissions as provided in the company’s written exemption requests. Multiple temporary projects are allowable within the consecutive 12

- month period provided 1) the aggregate 1

- ton threshold is not exceede d

, 2) the equipment is not used for more than 1 project, and 3) each individual project is not used for more than 60 consecutive days.

Equipment “Stac king” [Reference Proposed Amended Rule 202.D.15]

Q1: How is it determined that equipment is “stacked” or “used in the same process”?

A1: The APCD uses the engineering basis and system demands to determine that equipment is “stacked” or “used
in the sam e process.” Such analysis will involve looking at the equipment’s or system’s maximum energy needs or
demands under a worst

- case scenario.

 Example 1: A design basis is such that ten 1 million British thermal units per hour (MMBtu/hr) boilers can be requ ired at any one time. For this case, we would consider that equivalent to a single 10 MMBtu/hr
boiler.

 Example 2: A source installs two 4 MMBtu/hr boilers that are fired exclusively on natural gas. One is for primary use and one is standby. The design heat demand is 4 MMBtu/hr. Thus, the boilers in this configuration are not considered to be used in the same process (stacking).

 Example 3: An electric generator has two 30 brake horsepower internal combustion engines that drive a single shaft concur rently. The power demands are such that both engines typically need to run simultaneously. The configuration i s considered to be used in the same process and a total rating of 60STAF F REPORT

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Santa Barbara County APCD

brake horsepower would be used for determining permitting applicability (bu t Rule 333 would not be applicable).

Q2: A source is not sure if its existing equipment configuration constitutes “equipment stacking” and may require permitting. How can the source get an SBCAPCD determination about the configuration and its exemption/

permitting status?

A2: The source should complete an APCD Form

- 38, “Request for Written Determination of Permit Exemption,” and submit it along with the fee.

Q3: Will stacked equipment be subject to the requirements of the prohibitory rules and oth er regulations?

A3: Stacked equipment is subject to NSR provisions (e.g., BACT) for all units as one. For control measures such as Rule 342 and Rule 333, each unit is individually assessed for rule applicability.

Construction [Existing FAQ on the SBCAPCD Web Site ]

Q: In Section F.3 (IC Engines), does the 25 ton limit include fugitive dust emissions associated with the construction operation?

A: Yes. The 25 ton threshold applies to all pollutants emitted during the construction process. Also, the 25 ton threshold applies to each pollutant, and is not aggregated.

Construction

– Projected Actual Emissions and Offsets

[Reference Proposed Amended Rule 202.D.16]

Q1: How are fugitive dust emissions calculated when mitigation techniques are used?

A1: The potential to emit is determined taking in to account the dust mitigation techniques. These assessments are
done on a case

- by

- case basis using the best available emission calculations tools.

Q2: At what point would the 25 tons per year offset requirement for construction equipment be necessary ?

A2: Offsets are required prior to exceeding the 25 tpy projected actual emissions threshold. That is why the term “projected” is used.

Q3: There is a concern that an interpretation might be made that includes all construction projects within a

sta tionary source for the 25 ton total. For example, industry does not believe that a water line project and/or construction of a building within a large stationary source, not requiring an ATC, are subject to this 25 ton cap. This is analogous with other c onstruction projects occurring in Santa Barbara County (e.g., Housing developments, large parking structures, or UCSB construction projects).

A3: The method for determining that a construction activity may be subject to offsets under the proposed new Rul e 202.D.16 provision will be the same method used for the current Rule 202.F.3 provision. Only construction projects involving ATC permits are subject to this requirement.

Q4: Can the offset provisions be applied on a project or facility basis?

A4: No . Current Rule 202.F.3 specifies the requirement is for construction equipment used to construct a stationary source that requires an ATC. The proposed new Rule 202.D.16 text is essentially the same as current Rule 202.F.3. Stationary sources may opt to tally the total stationary source construction emissions on a project or facility basis, but the offset requirement is triggered on a stationary source basis; not on a project or facility basis.STAF F REPORT

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Santa Barbara County APCD Q5: A person proposes to build a new stationary source tha t requires an Authority to Construct. The construction emissions have a projected actual NOx emission rate in excess of 25 tons per year and the post

- construction stationary source will have a net emissions increase of 40 tons of NOx per year. What are t he emission offset implications for such a project?

A5: Per Rule 202.D.16, offsets are required for the project because the actual projected emission rate is in excess of 25 tons per year. The ATC permit will document the source of emission reduction c redits to be used to offset this construction emission offset liability. For the operational phase, offsets are triggered per Rule 802.E. Emission reduction credits applied to the construction phase offset liability may also be used to offset the operati onal phase liability (this assumes that there are no restrictions on the use of the ERCs and that the construction phase was completed).

Construction Engines [Reference PAR 202.D.16 and Current Rule 202.F.2]

Q: Who is responsible to get the permit or a PERP for a construction engine, the contractor or the source?

A: Ultimately the stationary source will be held accountable for the permitting or reg istering in the PERP of construction engines. The APCD recommends that sources put something in their request for bids or contracts requiring that all construction engines be registered in the PERP or be permitted.

Derated Engines

- Permitting Requirements

[Reference Proposed Amended Rule 202.F.1.e

- g]

Q: Will my derated engine need to be permitted?

A: Yes, unless the engine rated brake horsep ower before the derating was such that the engine would not require a permit.

 Example 1: A diesel engine with an original manufacturer’s nameplate rating of 48 brake horsepower is derated to 40 brake horsepower. Under Rule 202.F.1.e, the engine with the original manufacturer’s nameplate rating of 48 brake horsepower was exempt. Thus, the derated engine is exempt.

 Example 2: A spark ignition engine with an original manufacturer’s nameplate rating of 75 brake horsepower is d erated to 40 brake horsepow er. Under proposed amended Rule 202.F.1.f, the engine had an original rating of 75 brake horsepower, which is above the 50 or greater brake horsepower permitting threshold. Thus, the derated engine requires a Permit to Operate (PTO). †

 E XAMPLE 3 : A spar k ignition engine with an original manufacturer’s nameplate rating of 45 brake horsepower is derated to 25 brake horsepower and it is located at a source that requires engines in the > 20 to < 50 brake horsepower to be permitted. Under proposed amended Ru le 202.F.1.f, the engine with an original rating of 45 brake horsepower is not exempt. Thus, the derated engine requires a PTO. †

 E XAMPLE 4 : A source has eleven spark ignition engines only. These engines are derated. Each of the engine original equipme nt manufacturer (OEM) nameplate ratings (before derating) is 40 brake horsepower. Thus, a tally of the OEM nameplate ratings for these engines equals 440 brake horsepower (11 engines times 40 brake horsepower/engine). Since the aggregate exceeds 400 brak e horsepower, all engines need a permit. The owner or operator cannot permit just 2 engines derated to 10 brake horsepower so the aggregate becomes 380 [(2 engines times 10 brake horsepower/engine) + (9 engines times 40 brake horsepower/engine)] and get a n exemption for the other 9 engines. Once the requirement to permit all engines in the > 20 to < 50 brake horsepower range has been triggered, they shall not become exempt by the application of the derated brake horsepower ratings. Ratings of engines per manently removed will be excluded from new aggregate totals assessed pursuant to Authority to Construct modifications. †

________________________

† Figure 1 ( available here ) shows an overview of the Rule 202.F.1.f permit exe mption provisions.STAF F REPORT

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Santa Barbara County APCD Derated Engines

- Certifications and Enforceable Deratings

[Reference Proposed Amended Rule 202.F.1.e

- g]

Q1: My derated eng ines have been previously listed on a SBCAPCD PTO. Will I need to have additional derating certifications or power rating tests performed on my engine under the revised rules?

A1: If the engine deratings are (1) not enforceable and (2) not APCD

- approved on a Permit to Operate, then submittal of the documentation may be necessary. It is suggested that sources with engines in this category work closely with the Engineering & Compliance Division staff to determine what information needs to be submitted and what information is already on file with the APCD.

Q2: If the engine manufacturer re

- issues an engine nameplate to reflect the engine’s new continuous brake horsepower rating with an orifice plate or some other kind of physical limiting method, can the rating on the re

- issued nameplate be considered to be the engine’s rated brake horsepower?

A2: No, the APCD will use the engine manufacturer’s originally issued nameplate as the engine’s brake horsepower rating, unless the APCD issues a PTO for the dera ted engine. For the purposes of Rule 333 applicability, the APCD will consider an engine that has an enforceable derating, that has been certified, and is subject to a PTO to have a modified rated brake horsepower based on the derated brake horsepower fig ure.

Q3: My company has several unpermitted derated engines. Will I need to submit certification documentation to substantiate the engine deratings?

A3: The answer is “Yes.” If a permit is required for the ICEs, then certification documentation will need to be
submitted.

The APCD needs to issue PTOs for derated engines that would otherwise require a permit to ensure that the engine deratings are enforceable and maintained. The derating certification data needs to be submitted with the PTO applicatio n. It is suggested that sources with engines in this category work closely with the Engineering & Compliance Division staff to determine acceptable material that needs to be submitted with the application.

Q4: My engine has an orifice plate inserted b etween the carburetor and the engine’s intake manifold. There is a tab on the orifice plate that clearly shows the size of the orifice. Is this sufficient to show my engine is properly derated?

A4: Assuming that the engine was derated and certified as derated by procedures approved by the APCD and it is subject to a permit, it is not enough that the orifice plate’s tab is stamped correctly. We have physically checked orifice plates and found that they can deteriorate overtime. Thus, it is necessary th at the orifice plate actually be in compliance with the specifications as well as being marked with its appropriate size.

Q5: I believe my company derated engines from 75 brake horsepower to < 50 brake horsepower. But, there are no permits for them to reflect their deratings because they have always been exempt under the 500 brake horsepower exemption provision. How do I obtain a concurrence from the APCD that these engines are derated?

A5: These engines will require permits under the proposed revis ed Rule 202. Information on the deratings should be submitted with the applications for Permit to Operate. Depending on the method of derating and past derating certification documentation, additional analysis may be required.STAF F REPORT

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Santa Barbara County APCD Solvent Wipe Cleaning Exemption Recordkeeping [Reference Current Rule 202.U.3]

Q: As an operator of a large complex with several stationary sources and several facilities, a m I permitted to track solvent use on a facility basis?

A: Yes, as long as each facility solvent use is totaled for the stationary source for determining compliance with the Rule 202.U thresholds. Rule 202.U has an overall 10 tons per year threshold. R ule 202.U.2 has a solvent tank area aggregate threshold of 10 square feet for tanks with less than 1 square foot of area. And, Rule 202.U.3 has a wipe cleaning threshold of 55 gallons per year.

Designation of facilities and facility numbers are a const ruct of the APCD permitting process. Facilities are a subset of stationary sources. Thus, if an operator of a large complex desired to track solvent usage on a facility basis, the APCD would not have a concern, provided the operator properly aggregates a ll of the facility solvent usage and tank area data within the stationary source and is able to provide the stationary source data in support of exemption
claims.

Engine Electronic Management Fuel Metering

Q: Will the APCD accept onboard electronic engine fuel metering systems?

A: Yes, on an engine model

- by

- model basis and if the engine is set up to display the totalized fuel reading without
the ne ed to have an engine technician on site to retrieve the data. Monthly fuel readings are still required to be logged. For each engine fuel metering system, the APCD will require an initial validation test using an external
calibrated fuel meter as well as a fuel use monitoring plan for the permit.

Various Location Equipment Exemption

Q: What is the basis for the various equipment exemption under R ule 202.D.17?

A: This new exemption was added to allow for the use of permitted “various locations” equipment at existing stationary sources where the equipment is not owned by the stationary source using the equipment. The intent of this exemption is t o allow for the use of equipment for repair or maintenance related activities without the need for the stationary source owner or operator to comply with the New Source Review regulations. The equipment owner or operator will have a District Permit to Ope rate that specifically states that the equipment can be used at various locations and has conditions related to District notification and other restrictions of use. The type of activities envisioned for this exemption primarily includes tank degassing equ ipment and tank bottoms dewatering equipment.STAF F REPORT

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Santa Barbara County APCD ▲Back to Derated Engines

– Permitting Requirements