SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis December 15, 2011

B-1 Final Staff Report with Appendice s for Revised Proposed Amendments t o Rule 4352 

## APPENDIX B

Rule Consistency Analysis For Revised Proposed Amendments to Rule 4352

December 15, 2011SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis December 15, 2011

B-2 Final Staff Report with Append ices for Revised Proposed Amendments t o Rule 4352 This page intentionally blank.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis December 15, 2011

B-3 Final Staff Report with Append ices for Revised Proposed Amendments t o Rule 4352 RULE CONSISTENCY ANALYSIS FOR
REVISED PROPOSED AMENDMENTS TO RULE 4352

I. REQUIREMENTS FOR RULE CONSISTENCY ANALYSIS

Pursuant to Section 40727.2 of the California Healt h and Safety Code, prior to adopting, amending, or repealing a rule or regulation, the Di strict is required to perform a written analysis that identifies and compares the air pollu tion control elements of the rule or regulation with corresponding elements of existing or proposed District and United States Environmental Protection Agency (EPA) rules, regulations, and guidelines that apply to the same source category. The elements an alyzed are emission standards, monitoring and testing, and recordkeeping and repor ting requirements.

II. RULE CONSISTENCY ANALYSIS

A. District Rules

Facilities subject to District Rule 4352 could be s ubject to other District rules including:

 Rule 2201 New and Modified Stationary Source Revie w  Rule 2020 Exemptions
 Rule 2520 Federally Mandated Operating Permits

 Rule 4101 Visible Emissions
 Rule 4301 Fuel Burning Equipment
 Rule 4305 Boilers, Steam Generators, and Process H eaters – Phase 2
 Rule 4306 Boilers, Steam Generators, and Process H eaters – Phase 3
 Rule 4307 Boilers, Steam Generators, and Process Heaters – 2.0 MMBtu/hr to

5.0 MMBtu/hr
 Rule 4308 Boilers, Steam Generators, and Process Heaters – 0.075 MMBtu/hr

to less than 2.0 MMBtu/hr
 Rule 4351 Boilers, Steam Generators, and Process H eaters – Phase 1
 Rule 4601 Architectural Coatings

 Rule 4801 Sulfur Compounds

 Rule 8011 General Requirements

 Rule 8021 Construction, Demolition. Excavation, Ex traction, and Other

Earthmoving Activities
 Rule 8031 Bulk Materials
 Rule 8041 Carryout and Trackout

 Rule 8051 Open Areas

 Rule 8061 Paved and Unpaved Roads
 Rule 8071 Unpaved Vehicle/Equipment Traffic AreasSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis December 15, 2011

B-4 Final Staff Report with Append ices for Revised Proposed Amendments t o Rule 4352 The above-listed rules are not in conflict with, no r are they inconsistent with the requirements of Proposed Rule 4352.

B. Federal EPA Rules and Regulations

1. 40 CFR 60 Subpart D (Standards of Performance fo r Fossil-Fuel Fired Steam
Generators for Which Construction Commenced After A ugust 17, 1971)

40 CFR 60 Subpart D applies to fossil fuel-fired, a nd fossil fuel and wood residue-fired steam generating units of more than 2 50 MMBtu/hr that commenced construction or modification after August 17, 1971. Subpart D establishes the emission standards for NOx, SOx, an d PM. Since Rule 4352 applies to units that are fired on solid fuel, the rule consistency analysis focused only on the NOx standards established in 40 CFR 60 Subpart D for similar type
of fuel.

NOx limits:

• Wood residue, or gaseous fossil fuel and wood resi due – 0.30 lb/MMBtu

• Solid fossil fuel or solid fossil fuel and wood re sidue (except lignite or a solid fossil fuel containing 25 percent, by weight, or more of coal refuse) –
0.70 lb/MMBtu

• Lignite or lignite and wood residue – 0.60 lb/MMBt u

• Lignite which is mined in North Dakota, South Dako ta, or Montana and which is burned in a cyclone-fired unit – 0.80 lb/M MBtu

In general, the applicability, emission limits, and monitoring requirements of Rule 4352 are more stringent than those specified for un its that are subject to 40 CFR 60 Subpart D.

2. 40 CFR 60 Subpart Db (Standards of Performance f or Industrial-CommercialInstitutional Steam Generating Units)

40 CFR 60 Subpart Db applies to steam generating un its with a heat input capacity of greater than 100 MMBtu/hr that commence construction, modification, or reconstruction after June 19, 1984. Steam gener ating units, as defined in 40 CFR 60 Subpart Db, do not include process heaters. Rule 4352 applies to solid fuel fired units so the rule consistency analysis f ocused only on the NOx standards established in 40 CFR 60 Subpart Db for s imilar type of fuel.

NOx limits:

• Mass-feed stoker – 0.50 lb/MMBtu.

• Spreader stoker and fluidized bed combustion – 0.6 0 lb/MMBtu.

• Pulverized coal – 0.70 lb/MMBtu

• Lignite – 0.60 lb/MMBtuSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis December 15, 2011

B-5 Final Staff Report with Append ices for Revised Proposed Amendments t o Rule 4352 • Lignite mined in ND, SD, MT, and combusted in a sl ag tap furnace – 0.80
lb/MMBtu

• Coal-derived synthetic fuels – 0.50 lb/MMBtu

In general, the applicability, emission limits, and monitoring requirements of Rule 4352 are more stringent than those specified for un its that are subject to 40 CFR 60 Subpart Db.

3. 40 CFR 60 Subpart Cb (Emissions Guidelines and C ompliance Times for Large Municipal Waste Combustors That are Constructed on or Before September 20, 1994)

40 CFR 60 Subpart Cb applies to each municipal wast e combustor unit with a combustion capacity greater than 250 tons per day o f municipal solid waste for which construction was commenced on or before Septe mber 20, 1994. Rule 4352 applies to solid fuel fired units so the rule consistency analysis focused only on the NOx standards established in 40 CFR 60 Subpa rt Cb for similar type of
fuel.

NOx limits:

• Mass burn waterwall – 205 ppm at 7% O2

• Mass burn rotary waterwall – 250 ppm at 7% O2

• Refuse-derived fuel combustor – 250 ppm at 7% O2

• Fluidized bed combustor – 240 ppm at 7% O2

• Mass burn refractory combustors - no limit

• Fluidized bed combustor – 180 ppm at 7% O2

In general, the applicability, emission limits, and monitoring requirements of Rule 4352 are more stringent than those specified for un its that are subject to 40 CFR 60 Subpart Cb.

4. 40 CFR 63 Subpart DDDDD (NESHAP for Industrial, Commercial, and Institutional Boilers and Process Heaters)

40 CFR 63 Subpart DDDDD establishes emission limits and work practice standards for boilers and process heaters to regula te hazardous air pollutants such as arsenic, cadmium, chromium, hydrogen chlori de, hydrogen fluoride, lead, manganese, mercury, and nickel. NESHAP appli es to any boiler process or heaters located at a major source. Existing units are units that commenced construction before January 13, 2003; new units are units built on or after January 13, 2003.

5. EPA –453/R-94-022 “Alternative Control Technique s (ACT) Document – NOx
Emissions from Industrial/Commercial/Institutional Boilers”, dated March 1994SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Rule Consistency Analysis December 15, 2011

B-6 Final Staff Report with Append ices for Revised Proposed Amendments t o Rule 4352 The ACT discusses the different control techniques for controlling NOx emissions from boilers with heat input capacities from 0.4 to 1,500 MMBtu/hr. The ACT also presented the achievable emission levels of se veral control techniques based on the type of boiler and the type of fuel us ed. The ACT contains cost
effectiveness estimates for different control techn iques. However, the ACT does not prescribe the specific emission limits that sho uld be used in developing a regulation to control NOx emissions from boilers.

6. EPA “Control Techniques Guideline (CTG) Document

There is no EPA CTG for boilers, steam generators, and process heaters.

7. EPA Policy on Start-up or Shutdown

Section 5.3 of Rule 4352 establishes certain operat ional standards that must be met during start-up or shutdown of boilers, steam g enerators, and process heaters. District staff believe that the proposed start-up or shutdown provisions are consistent with the EPA policy as discussed in an EPA memorandum, dated February 15, 1983, “Policy on Excess Emissions Duri ng Start-up, Shutdown, Maintenance and Malfunctions” which prohibits autom atic exemption during periods of start-up or shutdown of a unit.

8. EPA Policy on Recordkeeping

The recordkeeping requirement in Section 6.1 of Rul e 4352 is consistent with EPA’s policy to keep and maintain records for at le ast five years.

III. CONCLUSION

Based on the above analysis, District staff found t hat the revised proposed amendments to Rule 4352 would not conflict with federal rules, regulations, or policies covering similar stationary sources.