UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document

for
EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

San Joaquin Valley Unified Air Pollution Control District Rule 4307 Boilers, Steam Generators, and Process Heaters

– 2.0 MMBtu/hr to 5.0 0 MMBtu/hr

Prepared by: Nicole Law

November 2014 2



Agency: San Joaquin Valley Unified Air Pollution Control
District ( SJVU APCD )

SIP Approved Rule: Rule 4 307

- Boilers, Steam Generators, and Process
Heaters

– 2.0 MMBtu/hr to 5 .0 MMBtu/hr
Amended

– October 16, 2008 Submitted

– M arch 17, 20 08 EPA Approved

– January 13 , 2010 (7 5 FR 1715 )

Superseded Submittals: none

Subject of this TSD: Rule 430 7

- Boilers, Steam Generators, and Process
Heaters

– 2.0 MMBtu/hr to 5.0 MMBtu/hr
Amended

– May 19, 2011 Submitted

– July 25, 2014

RULE SUMMARY

-

Rule 430 7 has emissions control requirements for criteria air pollutants, including NOx and PM and certification requirements for gaseous fuel or liquid fuel fired boilers, steam generators, and process heaters with a total rated heat input of at least 2 MMBtu/hr and up to 5 MMBtu/hr

. It also describes related compliance reporting

, labelling , and test methods

. Changes from the approved SIP include:

1. Add ed definitions for Environmental Protection Agency and Tree Nut
Pasteurizer in section 3.0 Definitions

.

2. Added section 5.1.2 which requires that tree nut pasteurizers be fired exclusively on PUC quality natural gas. Tree nut pasteurizers are also exempt from having to comply with the emission limits in Table 1 and 2.

3. Section 5.4 was named Start

- Up and Shutdow n Requirements. Language in paragraph 5.4.4 was revised to clarify that the APCO, ARB, and EPA may approve longer start

- up or shutdown durations than specified in
section 5.4.1 or 5.4.2.

4. Added section 6.1.5 which describes operations and maintenance r ecords requirements for tree nut pasteurizers.

EVALUATION CRITERIA

- The following criteria were used to evaluate the
submitted rule.

1. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988) and the Little 3

 Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate compliance with the CAA § 110(a)(2)(A) requirement for enforceability.

2. Strin gency

- EPA ’ s Alternat ive Control Techniques Document (ACT ) titled,

“ NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers ” ( EPA

453/R

- 94

- 022

- 1994/03, March 1994 ), CARB ’ s RACT/BARCT guidance
titled

, “ Industrial, Institutional, and Commercial Boilers, Steam Generators,
and Process Heaters ” (July 18, 1991), and other state and local rules for this category were used to help evaluate the stringency of the rule’s control requirements

.

3. SIP Relaxation

- CAA § 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 § 193 prohibits the modifi cation of any SIP

approved control requirement in effect before November 15, 1990, in a
nonattainment area.

EPA EVALUATION

- A summary of our evaluation of the three criteria follows.

1. The rule requirements and applicability are clear, and the certifi cation

, compliance reporting and other provisions sufficient ly ensure that affected sources and regulators can evaluate and determine compliance with Rule
430 7 consistently.

2. The SJVUAPCD regulates a n extreme nonattainment area for the 8

- hour
1997 and 2008 Ozone National Ambient Air Quality Standards and a non

attainment area for the 24

- hr 1997 and 2006 PM2.5 NAAQS. As a result, Rule 4307 must fulfill RACT and RACM requirements.

The submitted rule has limits comparable to the BARCT limits in CARB ’ s RACT/BARCT guidance and limits more stringent than the RACT limits in CARB’s RACT/BARCT guidance for NOx

. T he controls for NOx in rule
430 7 are comparable to those in EPA’s ACT and other California District rules for this category

, including South Coast Air Quality Management
District Rule 1146. 1 and Sacramento Metropolitan Air Quality Management
District R ule 41 1

. Rule 4307 controls PM with requirements that units burn gas fuel, low sulfur fuel, or add controls. At this time, other California
District rules for this category do not include similar requirements and there is no guidance on what constitutes RACM for this category. Accordingly , we find that the control requirements in this rule represent RACT and RACM

level control for this source category for NOx and PM

. 4



3. W e propose to determine that our approval of the submittal would comply with CAA §§ 110(l) and 193 because the proposed SIP revision would not
interfere with the on

- going process for ensuring that requirement s for RFP and attainment of the NAAQS are met

.

Prior to this rule revision, the single almond pasteurization unit currently affected by the rule in the District was operating under a variance , so no new emissions will occur because of this rule revision

. While this revision exempts tree nut pasteurizers from complying with the emission limits in
Tables 1 and 2 , it improves the SIP by requir ing that they be fired exclusively on PUC quality natural gas as an emission control measure , and by adding accompanying operation and maintenance recordkeeping requirements. SJVUAPCD has demonstrated in their staff report that further controls on tree nut pasteurizers would not be cost effective. In addition to the capital and operational costs of installing controls, there would be costs for testing for the re

- validation of the sterilization process as required under FDA regulations. The single almond pasteurization unit is estimated to emit 1.0 to 1.5 tons per year of NOx. It is less than 1. 5 % of the NOx e missions emitted from sources controlled by Rule 4307, which is 124 tpy , and less
than 0.0015 % of the total NOx emissions in SJVAPCD

. See the District’s staff report for further details

.

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 43 0 7 sufficient for EPA to propose less than full approval.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

– We
have identified no additional recommended for the next time the rule is amended.

EPA ACTION

-

The submitted Rule 430 7 strengthens the SI P, and the associated District s taff

rep ort projects no emission changes . The rule satisfies the applicable CAA § 110 requirements. Therefore, EPA staff recommends a full approval of Rule 430 7 pursuant to CAA § 110(k)(3).

REFERENCES

-

1. SJVUAPCD Rule 4307

, Boilers, Steam Generators, and Process Heaters

– 2.0 MMBtu/hr to 5.00 MMBtu/hr

, as amended May 19, 2011 and submitted
to EPA on July 25, 2014

. 2. SJVUAPCD Rule 4307

, Boilers, Steam Generators, and Process Heaters

– 2.0 MMBtu/hr to 5.00 MMBtu/hr

, as approved into the SIP on January 13,
2010

. 5



3. “ Alternative Control Techniques Document

- NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers” EPA

- 453/R

- 94

- 022

- 1994/03, March 1994

. http://www.epa.gov/groundlevelozone/SIPToolkit/ctg_act/199403_nox_epa 453_r

- 94

- 022_ici_boilers.pdf
4. “Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology for Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters,” CARB, July 18, 1991.
5

. “ Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, ” ( a.k.a., Bluebook) EPA OAQPS, May 25, 1988 (web citation ).
6

. “ Guidance Document for Correcting Common VOC & Other Rule Deficiencies, ” (a.k.a., Little Bluebook), EPA Region 9, Augu st 21, 2001 ( http://www.epa.gov/region09/air/sips/littlebluebook2001.pdf ).

7. “2012 PM2.5 Plan,” Appendix B and D, SJVUAPCD, December 20, 2012.