CALIFORNIA AIR RESOURCES BOARD



### APCD/AQMD RULE EVALUATION FORM – Page 1

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I. GENERAL INFORMATION

District: SJVUAPCD

Rule No(s): 4306, 4307, and 4320 Date adopted/Amended/Rescinded: Amended Rule 430 6 and Rule 4307, and Adopted Rule 4320 October 16, 2008.

Rule Title(s): Rule 4306 (Boilers, Steam Generator s, And Process Heaters - Phase 3), Rule 4307 (Boile rs, Steam

Generators, And Process Heaters - 2.0 MMBtu/hr to 5 .0 MMBtu/hr), and Rule 4320 (Advanced Emission Reduction Options For Boilers, Steam Generators, An d Process Heaters Greater Than 5.0 MMBtu/hr)

Date Submitted to ARB: November 27, 2008

If an Amended Rule, Date Last Amended (or Adopted): Rule 4306 Amended March 17, 2005, Rule 4307 Amend ed April

20, 2006.

Is the Rule Intended to be Sent to the U.S. EPA as a SIP Revision? Yes No ( If No, do not complete remainder of form)

District Contact: Manuel Salinas Phone Number: (559) 230-5800 E-mail Address: manuel.salinas@valleyair.org

Narrative Summary of New Rule or Rule Changes: New Rule Amended Rule

Amendments to Rule 4306 and Rule 4307, and new Rule 4320 satisfy control measure commitments included in

both the Disrict's 2007 Ozone Plan and the 2008 PM2 .5 Plan. Amendments to Rule 4306 corrected the ru le deficiencies identified by EPA in order to make Rul e 4306 fully approvable for inclusion in the State Implementation Plan (SIP). Amendments to Rule 4307 removed the existing exemption for units used at s chools, as well as the limted exemption for atmospheric uni ts used in oilfields or refineries and glycol reboi lers. Additionally, Rule 4307 existing low-use unit thres hold has been lowered from 5.0 billion Btu/year hea t input to 1.8 billion Btu/year heat input. New Rule 4320, which will eventually supercede existing Rule 4306, estab lishes more stringent NOx limits for boilers, steam generators, and process heaters with a rated heat input greate r than 5 MMBtu/hr. In addition, Rule 4320 includes provisio ns to control emissions of PM10, SOx, and CO. Det ails of the proposed changes to Rules 4306 and 4307, and the pr ovisions of new Rule 4320 are discussed in Section II of the final draft staff report.

Pollutant(s) Regulated by the Rule (Check): ROG (NOx) SO2 (CO) PM TAC (name):

II. EFFECT ON EMISSIONS

Complete this section ONLY for rules that, when imp lemented, will result in quantifiable changes in em issions. Attach reference(s) for emission

factor(s) and other information. Attach calculatio n sheet showing how the emission information provid ed below was determined

.

Net Effect on Emissions: Increase Decrease N/A

Emission Reduction Commitment in SIP for this Sourc e Category: NOx: 0.69 tons per day from Rule 4320 and 0.51 tons per day from Rule 4307. SOx: 0.5 tons pe r day from Rule 4320.

Inventory Year Used to Calculate Changes in Emissio ns: 2011 Area Affected: SJV Air Basin

Future Year Control Profile Estimate (Provide information on as many years as possible) : Percent reduction from 2011- 2011: 5.8% 2012: 31.1% 2013: 31.1% 2014: 54.4% 2015: 54.4%CALIFORNIA AIR RESOURCES BOARD



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Baseline Inventory in the SIP for the Control Measu re: 4.6 tons per day of NOx and 2.57 tons per day of SOx.

Emissions Reduction Commitment in the SIP for the C ontrol Measure: NOx: 0.69 tons per day from Rules 4306 and 4320 and 0.51 tons per day from Rule 4307. SOx: 0.5 ton s per day from Rule 4320.

Revised Baseline Inventory (if any): None

Revised Emission Reduction Estimate (if developed): For Rule 4320: NOx: 3.3 tons per day (47% reduct ion from calculated baseline emissions of 7.1 tons per day o f NOx); SOx: 3.6 tons per day (73% reduction from calculated baseline emissions of 4.9 tons per day of SOx) For Rule 4307: NOx: 1.2 tons per day (64% reductio n from calculated baseline emissions of 1.8 tons pe r day of NOx) SOx: No reduction since a large majority of units are already firing on PUC- quality natural gas whic h will be in compliance with the SOx control requirements.

Note that the district’s input to the Rule Evaluati on Form will not be used as input to the ARB’s emis sion forecasting and planning.

III. SOURCES/ATTAINMENT STATUS

District is: Attainment Nonattainment Split

Approximate Total Number of Small (<100 TPY) Source s Affected by this Amendment: N/A

Percent in Nonattainment Area: N/A %

Number of Large (> 100 TPY) Sources Controlled: N/A Percent in Nonattainment Area: N/A %

Name(s) and Location(s) (city and county) of Large (> 100 TPY) Sources Controlled by Rule (Attach additional sheets as

necessary) : N/A

IV. EMISSION REDUCTION TECHNOLOGY

Does the Rule Include Emission Limits that are Cont inuous? Yes No

If Yes, Those Limits are in Section(s) 5.0 of the Rule.

Other Methods in the Rule for Achieving Emission Re ductions are: N/A

V. OTHER REQUIREMENTS

The Rule Contains:

Emission Limits in Section(s): 5.0 Work Practice Standards in Section(s): 5.0 Recordkeeping Requirements in Section(s): 6.0 Reporting Requirements in Section(s): 6.05/1/2002 CALIFORNIA AIR RESOURCES BOARD



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VI. IMPACT ON AIR QUALITY PLAN

No Impact Impacts RFP Impacts attainment

Discussion:

1. Rule 4320 would impose new advanced NOx, SOX an d PM control options that go well beyond Reasonably Available Control Technology (RACT), on larger units (greater than 5 MMBtu/hr) based on their size, fuel type, a nd fuel usage. The rule also includes special Staged Enhanced Schedule s that first require interim Initial Emission Limit s be achieved with a

lower Final Emission Standards to be met at a later date. These schedules would produce required reduc tions at the earliest possible date with even greater reductions in the future. Because the affected units have ty pically had several levels of NOx controls, obtaining additional reduct ions can require expensive systems. Although the te chnology is available, for certain units, those technologies ar e not economically feasible. Therefore, the rule p rovides an option allowing payment of an emissions fee rather than in stallation of additional NOx controls. To comply w ith federal requirements, the fee would be based on the total a ctual emissions. The fees would be used by the Dis trict to fund projects which could achieve cost effective reducti ons. The affected sources will have the option, on an annual basis, to stop the fee option and install controls specified in the rule.

2. Particulate emissions from these sources is pri marily generated from the fuel sulfur content so th e rule amendments and new rule propose PM2.5 controls based on fuel s ulfur limits or SOX limits on exhaust gases. Most of these units are fired on PUC-quality natural gas which is considere d to be a reasonable level of SOX control. Units f iring on field gas, refinery gas, or digester gas would either meet sim ilar fuel sulfur levels or install an exhaust gas c ontrol. Extended compliance schedules have been provided for some la rger units that are currently in compliance with NO x limits but need appropriate time to design and install the addition al SOX controls.

3. Units subject to Rule 4306 would also be subjec t to Rule 4320. Rule 4306 amendments are administr ative changes to address EPA concerns and make Rule 4306 approvable for inclusion in the State Implementation Plan (SIP ). Specifically,

Section 5.3.4 of Rule 4306 would be modified to cla rify that the exemption from BACT and offset requir ements when adding start-up or shutdown conditions in the Permi t to Operate (PTO) is not automatic but depends on Rule 2201 language.

4. Amendments to Rule 4307 apply to smaller units (2 MMBtu/hr to 5 MMBtu/hr) and generate NOx emissio ns reductions by removing or altering existing exemptions from th e rule. The total exemption for units used at scho ols would be removed, as well as the limited exemption for atmos pheric units used in oilfields or refineries, and g lycol reboilers. The low use unit threshold would drop from a limit of 5 .0 billion Btu per year heat input to no more than 1.8 billion Btu per calendar year. After July 1, 2015 these units must meet all applicable requirements of the rule. New and replacement units would have to meet lower 9 or 12 ppmv NOx lim its. This provision allows operators to lengthen u seful life of units that recently upgraded to meet the current limits. SOX and PM2.5 requirements would be similar to Rul e 4320 but these units are typically fired on Public Utility Corrlmi ssion quality natural gas so the provisions serve a s backstop language with

little cost and nominal emission reductions.