United States Environmental Protection Agency, Regi on 9

Air Division

Technical Support Document

for

EPA’s Notice of Rulemaking

for the

California State Implementation Plan

Santa Barbara County Air Pollution Control District ’s

Rule 361, Small Boilers, Steam Generators and Proce ss Heaters

Prepared by: Idalia Perez

April 2010Santa Barbara County Air Pollution Control District (SBCAPCD)

Submitted Rule SBCAPCD Rule 361, Small Boilers, Steam Generators a nd Process Heaters:

 Adopted: January 17, 2008

 Submitted: July 18, 2008

 Completeness determination: August 22, 2008

Previous Rule Submittals There are no outstanding submittals of Rule 361.

SIP-Approved Rule There are no SIP-approved versions of Rule 361.

Rule Summary Rule 361 regulates emissions of oxides of nitrogen (NOx) and carbon monoxide (CO) from boilers, steam generators and process heaters with a rated heat input rate greater

than 2 million BTU/hr and less than 5 million BTU/h r. The rule has a full compliance date of January 1, 2020.

Section B of the Rule specifies categories that are exempt from the rule.

Section C of Rule 361 includes definitions of relev ant terms.

Section D sets the emission limits of the rule:

 NOx: 30 ppm at 3% oxygen

 CO: 400 ppm at 3% oxygen. These limits are not applicable to units with an an nual heat input equal to or less than 1.8 billion Btu/year.

Section E describes the procedures to be followed w hen a unit loses its low-use exemption.

Section F specifies the requirements for compliance determination.

The recordkeeping requirements of Rule 361 are spec ified in Section G.

Section H specifies that all records must be submit ted to the District by March 1 for the prior year except for source test reports which mus t be submitted within 45 days of completion.

Section indicates the necessary number of tune-ups per year.

The source testing requirements of rule 361 are in Section J.

The compliance schedule for Rule 361 is outlined in Section K.The tuning procedures are included as an attachment to the rule. Procedure A is the tuning procedure for forced draft-fired equipment. Procedure B is the tuning procedure for natural draft-fire equipment. Both procedures r equire NOx measurements if the unit being tuned is subject to the NOx limit in the Rule

.

Emissions Reductions

The District estimates a reduction of 0.0467 ton of NOx/day in the year 2020 when the Rule is fully implemented.

Rule Evaluation Generally, SIP rules must be enforceable (see secti on 110(a) of the Clean Air Act, hereafter CAA); must require Reasonably Available C ontrol Technology (RACT) for major sources in nonattainment areas (see CAA §182( b)(2) and (f)); must not interfere with applicable requirements, including requirement s concerning attainment (see CAA section 110(l)); and must not relax existing requir ements in effect prior to enactment of the 1990 CAA amendments (see section 193). The SBCA PCD regulates an area that is

classified as maintenance for the 1-hour ozone stan dard and is in attainment for all criteria pollutants, thus, submitted Rule 333 does not have to fulfill RACT requirements.

Guidance and policy documents that we used to defin e specific enforceability requirements include the following:

• Issues Relating to VOC Regulation, Cutpoints, Defic iencies, and Deviations (the "Blue Book"), US EPA, OAQPS (May 25, 1988).

• Guidance Document for Correcting Common VOC and Oth er Rule Deficiencies

, EPA Region IX (August 21, 2001, the “Little Blueboo k”).

• State Implementation Plans; General Preamble for th e Implementation of Title I of the Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 1992); 57 FR 18070 (April 28, 1992).

• State Implementation Plans; Nitrogen Oxides Supplem ent to the General Preamble for the Implementation of Title I of the C lean Air Act Amendments of

1990 (the "NO X Supplement to the General Preamble"), US EPA, 57 F R 55620 (November 25, 1992).

• State Implementation Plans (SIPs): Policy Regarding Excess Emissions During Malfunctions, Startup and Shutdown from Steven A. Herman, Assistant Administrator for Enforcement and Compliance Assura nce, and Robert Perciasepe, Assistant Administrator for Air and Rad iation, September 9, 1999.

SBCAPCD Rule 361 meets some of the necessary requir ements listed above. The Rule

was not reviewed to determine its fulfillment of RA CT thus we are not making a statement of its merit in this regard. It is a stre ngthening of the current SIP and will lead

to a net decrease in NOx emissions when the rule is implemented. The lack of a specific definition for the length of time of start-ups and shutdowns leads to an enforceability deficiency in the Rule. The lack of specificity of the required documentation of fuelsulfur content also makes the Rule not adequately e nforceable. These inadequacies are

further discussed below.

Rule Deficiencies

1. Section F.3 defines the length of the startup and s hutdown intervals as “not last[ing] longer than is necessary to reach stable temperatur es and conditions”. This leads to enforceability concerns due to the lack of specific ity of the duration of these periods. The duration of these periods should be further spe cified 1 . An example of an adequate startup and shutdown provisions is San Joaquin Vall ey APCD Rule 4307, section 5.4.

2. Section G.4 states that documentation of fuel sulfu r content must be kept as a record. The type of documentation required should be specif ied in the rule. An example of an adequate documentation for sulfur content is San Jo aquin Valley APCD Rule 4307 which specifies:

a. Testing of the sulfur content of liquid fuel; or

b. Obtaining a copy of the fuel sulfur content specifi cation data from the fuel

manufacturer or vendor.

Suggested Rule Improvement EPA recommends that the SBCAPCD make the following improvements in the next

revision of Rule 361:

1. The emission limits in the Rule should be further s trengthened; see for example San Joaquin Valley Unified APCD Rule 4307, section 5.1.

Recommendation EPA staff recommends limited approval/disapproval w ithout sanctions of SBCAPCD Submitted Rule 361 for incorporation into the Calif ornia Applicable SIP.

Attachments

1. Submitted Rule 361

2. Staff Report

1 “State Implementation Plans (SIPs): Policy Regardi ng Excess Emissions During Malfunctions, Startup and Shutdown” from Steven A. Herman, Assistant Admi nistrator for Enforcement and Compliance Assurance, and Robert Perciasepe, Assistant Adminis trator for Air and Radiation, September 9, 1999.