-o ventura county - Air Pollution 

Control Dis trict 

June 23, 2015 

Air Pollution Control Board 

800 South Victoria Avenue 

Ventura, CA 93009 

669 County Squoro Drive 

Ventura, Colilornto 93003 

tcl805/645· 1400 

lox 805/ 6<15·1444 

www.vcopcd.org 

Michael Villegas 

Air Pollution Control OHicer 

SUBJECT: PUBLIC HEARING TO CONSIDER APPROVAL OF PROPOSED 

AMENDMENTS TO RULE 74.15.1, BOILERS, STEAM GENERATORS, AND 

PROCESS I !EATERS, FROM l MILLION BTU/IIR UP TO 5 MILLION 

BTU/HR AND FINDING THAT ADOPTION OF PROPOSED RULE 

REVSIONS ARE CATEGORICALLY EXEMPT fROM THE CALIFORNIA 

ENVIRONMENTAL QUALITY ACT (CEQA) 

RECOMMENDED ACTIONS: 

I . Find that adoption of proposed amendments to Rule 74. 15.1 is categorically exempt from 

CEQA, and direct the Air Pollution Control Officer or his designee to file a CEQA 

Notice of Exemption (Attachment I) following approval of the proposed amendments. 

2. Approve and adopt the proposed legislative findings for proposed amendments to Rule 

74.15.1 (Attachment 2). 

3. Approve and adopt the proposed amendments to Rule 74.15. 1 (Attachment 3). 

4. Direct the Clerk of the Board to forward two certified minute orders, and an affidavit of 

publication of the public hearing notice, for all of the foregoing proposed actions to the 

Air Pollution Control District within 20 days. 

STATEMENT OF MATTER FOR BOARD CONSIDERATION: 

Dackground 

Ventura County is subject to the requirements of the California Clean Air Act (CCAA) specific 

to the county's status as a nonattainment area for the state ozone ambient air quality standards. In 

particular, the CCAA requires local air districts to develop air quality plans that will achieve at least 

a five percent average annual ozone precursor emission reduction or, if that result is not achievable, 

that include every feasible emission control measure under the air district's purview and an 

expeditious adoption schedule (llealth & Safety Code §40914). The proposed rule change will add 

another feasible measure that will be part of the District's attainment strategy to reduce 

districtwide air emissions pursuant to llealth and Safety Code section 40914. The proposed rule 
Air Pollution Control Board 

June 23, 20 15 

Page2 

amendments will reduce oxides of nitrogen (NOx) emissions from the combustion of fuel in 

boilers, steam generators, and process heaters. 

During the processing of a 20 12 revision to District Rule 74.1 5.1, the Air Resources Board 

(ARB) strongly recommended that the District adopt NOx emission limits based on the South 

Coast Air Quality Management District (SCAQMD) Rule 1146.1, which, if adopted by the 

District, would have required that industry and government facilities retrofit at least 27 existing 

boilers, steam generators, and process heaters with ultra-low NOx emission control equipment. 

Statf determined at that time that these retrofits would not have been cost-effective, since the 

costs ranged from $ 12 to $1,887 per pound of NOx reduced. Instead, staff proposed a new NOx 

limit of 20 ppm for new (but not existing) boilers, steam generators, and process heaters between 

1 and 2 million BTU/hr based on SCAQMD Rule 1146.2, and staff committed to reevaluating 

District Rule 74.15.1 after 201 4. This proposal is the result of that reevaluation. 

Proposed Rule Amendments 

NOx emission reductions will result from proposed new NOx emission limits for new or 

replacement (but not existing) boilers, steam generators, and process heaters in the size range 

from 2 million up to 5 million BTU/hr depending on the type of gaseous fuel and whether or not 

the combustion chamber is atmospheric or pressurized, as follows: 

CATEGORY 

Units fired on Natural Gas - Atmospheric 

Units fired on Natural Gas- Pressurized 

Units tired on Landt111 Gas 

Units fired on Biogas 

Units fired on Liquefied Petroleum Gas 

Units fired on Produced Oilfield Gas- Atmospheric 

Units tired on Produced Oilfield Gas- Pressurized 

NOx Limits (3%0z} 

12 ppm 

9ppm 

25 ppm 

15 ppm 

20ppm 

15 ppm 

12 ppm 

The proposed rule amendments make three important changes to Rule 74.15. 1 's applicability in 

order to align the rule with other District rules applicable to small boilers, steam generators, and 

process heaters. With the amendments, Rule 74.15.1 will: 

l. Apply to gaseous fuels in addition to natural gas including landtill gas, biogas, liquefied 

petroleum gas (LPG) or propane, and produced oilfield gas (as shown in the table above). 

2. Apply to both stationary and portable process heaters. 

3. Contain a clarified definition of"process heater" which excludes combustion sources not 

regulated by SCAQMD Rule 1146.1 including kilns, open heated tanks, dehydrators, 

dryers, crematories, incinerators, calciners, cookers, roasters, furnaces, and emission 

control combustion devices such as atlcrburners, vapor incinerators, and thermal or 

catalytic oxidizers. 
Air Pollution Control Board 

June 23, 2015 

Page 3 

Proposed Rule Exemption 

Staff is proposing an exemption for a single existing source with two portable process heaters 

that otherwise would have been subject to the NOx limit of30 ppm for existing units based on 

the proposed changes to Rule 74.1 5.1 's applicability. This exemption for existing portable oil 

well dewaxing process heaters having an annual heat input of less than 2.8 billion BTU per year 

is being proposed because the cost-effectiveness for retrofitting with low-NOx burners for these 

units exceeds $9.50 per pound ofNOx reduced, which is not considered a reasonable cost at this 

time. The amount ofNOx reductions not captured by the inclusion of this exemption for this 

source is 0.29 tons NOx per year. 

Proposed Reduction in Compliance Costs 

The 2012 rule revision included a new provision to reduce compliance costs by substituting 

biennial source testing with annual emission screening analysis for equipment rated from 1 

million BTU/hr to 2 million BTU/hr and source testing every four years. To further reduce 

compliance costs, staff is proposing a similar testing frequency for new or replaced units having 

a rated heat input capacity greater than 2 million BTU/hr and less than 5 million BTU/hr. This 

would reduce compliance costs for these new or replaced units by reducing the source testing 

frequency from biennial to every four years. Existing annual screening requirements for these 

units would continue to provide a less expensive compliance alternative. 

Expected Emission Reductions and Cost Analysis 

The proposed amendments to Rule 74.15.1 will reduce NOx emissions in Ventura County by 

approximately 9.3 tons per year as units are replaced. The cost-effectiveness for new or replaced 

equipment is estimated at $2.30 per pound of NOx reduced based on the installation of ultra-low 

NOx burners, where the use of a Flue Gas Recirculation system is not needed to comply with the 

new limits. The staff report (Attachment 4) contains a more comprehensive analysis of emission 

and socioeconomic impacts. 

Comments 

A public consultation meeting/rule workshop was held on February 12, 2015. The meeting was 

attended by Susan Perez of Alta Environmental (consultant for portable asphalt plants), 

Marianne Strange (consultant for Western States Petroleum Associates - WSPA), City of 

Ventura Water Department and Miura American Company (boiler vendor). No comments were 

received from ARB. Staff received comments from the U.S. Environmental Protection Agency 

(EPA) Region IX and WSP A The proposal was amended to include all suggestions from both 

entities. EPA comments were based on a comparison with the SIP-approved SCAQMD Rule 

1146.1, which includes NOx limits for both landfill gas and biogas. WSPA requested new NOx 

limits for new or replaced units fueled by produced oilfield gas as shown in the table on Page 2 

above. WSPA also requested reducing the frequency of source testing for new or replaced units 

in the size range from 2 to 5 million BTU/ hr. Staff is proposing to reduce the frequency of 

source testing these units from every two years to every four years since annual NOx emission 
Air Pollution Control Board 

June 23.201 5 

Page 4 

screenings will still be required. As stated earlier, this provision will reduce the costs of 

compliance for these newer units. 

On April28, 2015, the Advisory Committee recommended adoption ofthc proposed 

amendments to Rule 74.15.1 by a unanimous vote (Attachment 5 - Voting Record). 

PROPOSED FINDINGS: 

I lealth and Safety Code sections 40703, 40727, 40727.2, 40728.5 and 40920.6(a) direct that, 

prior to adopting amendments to an air quality mle or regulation such as Rule 74.15.1, your 

Board adopt findings of necessity, authority, clarity, consistency, non-duplication, reference, 

cost-effectiveness, incremental cost-eftectiveness, and socioeconomic impacts, based upon 

relevant information presented at the hearing. Health and Safety Code section 40727.2 requires a 

written analysis, comparison, and consideration of existing air pollution regulations that apply to 

the same type of source (Attachment 4). Therefore, if your Board approves the proposed 

amendments to Rule 74.15.1, then your Board must also adopt the proposed findings that address 

these statutory requirements. 

The proposed amendments to Rule 7 4.15 .1 have been determined by District staff to be within 

the scope of the categorical exemptions from CEQA under State CEQA Guideline sections 

15307 (actions by regulatory agencies for protection of natural resources) and 15308 (actions by 

regulatory agencies for protection of the environment). The Notice ofExemption regarding this 

exemption determination is included as Attachment 1 and will be filed with the Ventura County 

Clerk's Office upon your Board's approval ofthe amended rule. 

This proposal has been reviewed by County Counsel. If you have any questions, please contact 

Mike Villegas at 645-1440 or Stan Cowen at 645-1408. 

i~Air Pollution 

v,Control 

It-Officer 

Attachments: 

1. Proposed Notice of CEQA Exemption 

2. Proposed Legislative Findings 

3. Proposed Amendments to Rule 74.15.1 

4. Final Staff Report 

5. Advisory Committee Voting Record