UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

Feather River Air Quality Management District’s
Rule 3.21, Industrial, Institutional, and Commercial Boilers, Steam Generators,

and Process Heaters

Prepared by: Kevin Gong

November 1

, 2014 2



Agency: Feather River Air Quality Management District (FRAQMD)

SIP Approved Rule: There is no previously SIP approved Rule 3.21

Superseded Submittals: There is no previously submitted Rule 3.21

Subject of this TSD: FRAQMD Rule 3.21, Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process

Heaters

 Adopted June 5, 2006

 Subm itted to California ARB April 18, 2013 and to US EPA February 10, 2014

RULE SUMMARY

Under Section 107(d) of the Clean Air Act (CAA), EPA designated portions of Yuba and Sutter counties nonattainment for the following three National Ambient Air Quality Standards (NAAQS): 1

- hour ozone, 1997 8

- hour ozone and 2008 8

- hour ozone . These areas ar e regulated by the Feather River Air Quality Management District (FRAQMD).

Rule 3.21 establishes oxides of nitrogen (NOx) emission limits from boilers, steam generators and process heaters.

This rule applies to boilers, steam generators, and process heaters with heat input capacities greater than or equal to 1 million BTU per hour (MMBTU/hr), used in all industrial, institutional, and commercial operations. and outlines allowable NOx

control measures

.

The rule includes exemptions for smaller units operating below a threshold of 90,000 therms of annual heat inputs , definitions, requirements for compliance and metering equipment, acceptable test methods, and recordkeeping.

The rule’s emissions limits differ based on location. Part of the FRAQMD lies

within the Sacramento Federal Nonattainment Area (SFNA) , and has more stringent limits. The rule limits for criteria pollutants are detailed below, in pounds per million BTUs or parts per m illion by volume. 3



Type of Fuel Used North FRAQMD SFNA Part of

FRAQMD

Only Gaseous Fuel Firing

Units 0.08 lbs/MMBTU, or

70 ppmv at 3% O 2 0.036 lbs/MMBTU, or 30 ppmv at 3% O 2

Gaseous & Non

- Gaseous

Fuel Co

- Firing Units Heat Input Weighted Average Fuel Limits

Non

- Gaseous Firing Units 0.15 lbs/MMBTU, or 115 ppmv at 3% O 2 0.052 lbs/MMBTU, or 40 ppmv at 3% O 2

EVALUATION CRITERIA The following criteria were used to evaluate the submitted rule.

1. Enforceability

- Section 110(a)(2)(A) of the Clean Act Act requires that the

rule be enforceable. The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988) and the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate compliance with this requirement

.

2. Stringency

- Section 172(c)(1) of t he CAA requires nonattainment areas to implement all reason ably available control measures (RACM), including

such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, of reasonably available control technology (RACT), as expeditiously as practicable.

Ozone nonattainment areas classified as moderate or above must requir e RACT for all major sources of NOx (CAA section 182(f); 40 CFR section 51.912(a)). As mentioned earlier, the FRAQMD regulates an ozone

nonattainment area that is classified as severe for the 1997 and 2008 8

- hour ozone standards . FRAQMD defines this severe nonattainment area as

“ SFNA Portion of FRAQMD” for the purposes of regulation.

EPA ’ s Alternative Control Technique ( ACT ) titled, “ Alternative Control Techniques Document

– NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers ” ( EPA

- 453/R

- 94

- 022

1994/03 ), CARB ’ s RACT/BARCT guidance titled, “ Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology for Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters ” (July 18, 1991), and other state and local rules for this category were used to help evaluate the RACT requirements of CAA § 182(b)(2) and § 182(f). 4



3. SIP Relaxation

- CAA Section 110(l) prohibits EPA from approving any SIP

revision that would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA § 193 prohibits the modification of any SIP

- approved control requirement in effect before November 15, 1990,

in a nonattainment area.

EPA EVALUATION

- A summary of our evaluation of the three criteria follows.

1. The rule requirements and applicability are clear, and the monitoring, recordkeeping, reporting and other provisions sufficiently ensure that affected sources and regulators can evaluate and determine compliance

with Rule 3.21 consistently.

Rule 3.21 requires compliance demonstration every 8,760 hours or every two calendar years (whichever is more frequent), instead of once ever y calendar year as set out in SMAQMD Rule 411 (Section 403) and PCAPCD Rule 231 (Section 500, via annual tuning reports and source tests). Comments from CARB indicated that this was preferable to the original language which required testing every three cal endar years. Our

r ecommendations in the following section on the frequency of testing do not

affect our assessment of the rule.

2. W e have determined that the requirements for the Federal nonattainment

SFNA Portion of the FRAQMD in this rule fulfil RACT requirements because they are as stringent as CARB ’ s RACT/BARCT guidance and other California District rules for this category , including Placer County Air

Pollution Control District (PCAPCD) Rule 231 and Sacramento Metropolitan Air Quality Management District (SMAQMD) Rule 411

, and more stringent

than EPA ’ s 1994 ACT

.

3

. There is no previous Rule 3.21 in the California SIP. W e propose to determine that our approval of the submittal would comply wit h CAA §§ 110(l) and 193 because (1) the proposed SIP revision would not interfere

with the on

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

- approved control requirements.

RECOMMENDATIONS FOR THE NEXT RULE REVISION

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

the next time the rule is amended. 5



1. Revise Section C.1 “Annual Heat Input” defined to correct a typographical

error.

2. Delete the reference to permit limits for CO in Section D.3.

3. Amend Section F. 2 to requi re testing every calendar year.

4

. Section E.1 should be written as an “and/or” provision to ensure all units are covered. Currently, a unit that is only subject to either Section B or Section D could interpret the rule to not require the installation of monitoring equipment.

5

. Amend section H.1 to require records are kept for 5 ye ars.

EPA ACTION

The submitted Rule 3.21 strengthens the SI P, and the associated California ARB

rule evaluation projects it will reduce NOx emissions by 5 .47 tons/year from 2008 inventory levels in the Northern Part of FRAQMD

. EPA staff recommends the approval of Rule 3.21 into the California State Implantation Plan.

REFERENCES

1. F eather R iver Air Quality Management District Rule 3.21 , adopted June 5,

2006

2. Staff Report for FR Rule 3.21, Comments Attachment, and other SIP

submittal documents

3. Sacramento Metropolitan Air Quality Management District Rule 411 (Adopted 8/23/07) and Placer County Air Pollution Control District 231

. (Adopted 10/9/97)

4. “Alternative Control Techniques Document

– NOx Emissions from

Industrial/Commercial/Institutional (ICI) Boilers” ( EPA

- 453/R

- 94

- 022

1994/03 )

. http://www.epa.gov/groundlevelozone/SIPToolkit/ctg_act/199403_nox_epa
453_r

- 94

- 022_ici_boilers.pdf

5. “Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology for Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters” ( California
Air Resources Board, July 18, 1991)

. http://www.arb.ca.gov/ractbarc/boilers.pdf