United States Environmental Protection Agency, Region 9

Air Division

Technical Support Document

for

EPA’s Notice of Proposed Rulemaking

for the

California State Implementation Plan

San ta Barbara County Air Pollution Control District’s

Rule 3 5 2

, Natural Gas

- Fire Fan

- Type Central Furnaces and Small Water Heaters

Prepared by: Idalia Pé rez

October 2012Santa Barbara County Air Pollution Control District (S BC APCD)

Submitted Rule

S BC APCD Rule 35 2

, Natural Gas

- Fire Fan

- Type Central Fu rnaces and Small Water Heaters

 Revised : October 20 , 20 11

 Submitted: February 23 , 20 12

 Determined complete : March 13

, 20 12

Previous Rule Submittals There are no outstanding submittals of Rule 35 2

.

SIP

- Approved Rule

 Adopted: September 16

, 199 9

 Approved by EPA : December 20 , 200 0 ( 6 5 FR 7 9752 )

Rule Summar y Rule 35 2 limits NO

x emissions from gas

- fired fan

- type central furnaces and small water heaters

.

Rule Amendments

Rule 35 2 was amended to ex pa nd the applicability of the rule to include all small water he aters
and strengthen the emission limits for NO

x .

Section E was amended to allow certification only from the South Coast Air Quality Management District (SCAQMD) in lieu of testing.

Other changes were made to improve consistency, clarity and enforceabili ty of r ule 352

.

Effects on Emissions The staff report indicate s that Rule 35 2 will lead to an approximate reduction of 0.0867 tons of NOx per day in 2020

.

Rule Evaluation Criteria We have evaluated Rule 352 in accordance with the following criteria:

1. R ule Stringency

– Generally, SIP rules must be enforceable (see section 110(a) of the Clean Air Act, hereafter CAA); must require Reasonably Available Control Technology (RACT) for major sources in nonattainment areas (see CAA §182(b)(2) and (f)). Santa Bar bara County is designated as

unclassifiable/ attainment for all National Ambient Air Quality Standards (NAAQS) thus, submitted Rule 3 52 does not have to fulfill RACT requirements and we are not evaluating the stringency of the NO

x emission limit in Rule 352

.

2. Enforceability

– CAA section 110(a)(2)(A) requires that regulations submitted to EPA for approval into a State Implementation Plan (SIP) be clear and legally

enforceable.3. SIP Revisions

- 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 section 193 prohibits the modification of any SIP

- approved control requiremen t in effect before November 15, 1990, in a

nonattainment area.

Guidance and policy documents that we used to evaluate Rule 352 include the following:

 Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and Deviations (the "Blue Book"), US EPA, OA QPS (May 25, 1988).

 Guidance Document for Correcting Common VOC and Other Rule Deficiencies , EPA Region IX (August 21, 2001, the “ Little Bluebook ” ).

Recordkeeping and other compliance provisions in the rule ensure that the requirements are adequately enfo rceable. The expanded applicability and the addition of more stringent NO

x emission limits make the amendments a strengthening of the SIP. Thus, approval of the

submitted rule does not relax the SIP and s atis fies CAA §110(l) and §193.

Suggested Rule I mprovements SCAQMD Rule 1111 , amended on November 6, 2009, has more stringent limits for furnaces. The SBCAPCD should consider including these limits the next time the rule is amended.

Recommendation

EPA staff recommend s direct final approval of S BC APCD submitted rule 35 2 for incorporation

into the California SIP

.

Other References

1. SIP

- approved version of Rule 35 2

2. Submitted Rule 352

3. Submittal package for Rule 352