UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document

for

EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

Placer County Air Pollution Control District Rule 247

Natural Gas

- Fired Water Heaters, Small Boilers and Process Heaters

Prepared by: Nicole Law

August 2014 2



Agency: Placer County Air Pollution Control District ( PCAPCD )

SIP Approved Rule: none

Superseded Submittals: none

Subject of this TSD: Rule 247

– Natural Gas

- Fired Water Heaters, Small

Boilers and Process Heaters

Amended

– February 13, 2014

Submitted

– May 13, 2014

BACKGROUND

– Placer County APCD is nonattainment for the 8 hour Ozone

standard. As a part of the State Implementation Plan, PCAPCD committed to adopt a new rule to regulate oxides of nitrogen (NOx). Rule 247 was adopted to fulfill that commitment as it regulates water heaters and boilers with rated heat capacity greater than 75,000 BTU/hr and less than 5 million BTU/hr.

RULE SUMMARY

-

Rule 247 establishes NOx limits and certification requirements for natural gas

fired water heaters, boilers, and process heaters. It also describes related recordkeeping, labelling , and test methods . Rule 247 does not apply to existing

units , as it is a point of sale rule . Rule provisions include :

1. Limits on NOx emissions to 20 ppmv at 30% oxygen for natural gas

- fired water heaters, boilers, or process heaters.

2. The rule effective date is January 1, 2015 when no person is allowed to offer for sale, sell or install a natural gas

- fired water heater, boiler or process heater which does not comply with the emission limit.

3. Manufacture r s of water heaters, boilers or process heaters su bject to the rule are required to submit to the Air Pollution Control Officer 30 days prior

to sale a statement that the unit is in compliance with the emission units

. Another option is for manufacturers to submit to the District certifications approved b y either the South Coast Air Quality Management District (SCAQ M D) or the San Joaquin Valley Air Pollution Control District (SJVAPCD).

4. Labelling requirements for manufacturers describe what information should

be included on the units as well as the carton.

5

. Manufacturers are responsible for keeping certification reports, test reports, and certification statements for as long at the unit is offered for sale or five years, whichever is longer. 3



6. Various allowable test methods are listed for determining certification and compliance with the rule.

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

2. Stringency

- 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 recordk eeping, reporting and other provisions sufficient ly ensure that affected sources and regulators can evaluate and determine compliance with Rule 247 consistently.

2. The submitted rule is more stringent than CARB ’ s RACT/BARCT guidance

, and the controls are comparable to those in EPA’s ACT and other California District rules for this category

, including Sacramento Metropolitan Air Quality Management District Rule 411 and 414

. Accordingly , we find that the control requirements in this rule repres ent RACT

- level control for this source category

.

3. W e propose to determine that our approval of the submittal would comply

with CAA §§ 110(l) and 193 because (1) the proposed SIP revision would

not interfere with the on

- going process for ensuring that requirements for RFP and attainment of the NAAQS are met, and (2) no previous version of 4

 this rule is in the SIP, so approval of this versi on only improves the SIP and

does not modify any existing SIP control requirement

.

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 247 sufficient for EPA to propose less than full approval.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE RE VISION

- The following revisions are not currently the basis for rule disapproval, but are

recommended for the next time the rule is amended.

1. Section 103.2 provides an exemption for water heaters used to heat pools/spas with a rated heat input capacity less than or equal to 400,000 Btu/hr. Consider adopting limits for these units as in San Joaquin Valley APCD Rule 4308 Section 5.0 Table 1 (for instantaneous water heaters and pool heaters between 75,000 and 400,000 btu/hr the limit is 55 ppmv NOx at 3% O2) and Sacramento Metropolitan AQMD Rule 414 Section 301 (for pool/spa heaters between 75,000 and 400,000 Btu/hr the limit is 55 ppmv at 3% O2).

2. Section 402.2 allows submittal of certification as approved by the San Joaquin Valley A PCD . The rule language states “A certification of a model to San Joaquin Qir Management District Rule 4307... ” but should state “ A

certification of a model to San Joaq uin Valley Air Pollution Control District

Rule 4307... .”

3. Section 502.3 references a South Coast AQMD test method by number. Consider including the title of the test method in this section as is recommended on page 13 of EPA’s Guidance Document for Correct ing

Common VOC & Other Rule Deficiencies

.

EPA ACTION

-

The submitted Rule 247 strengthens the SI P, and the associated District s taff

rep ort projects it will reduce NOx emissions by 1.01 tons/ day in 20 2 5. The rule satisfies the applicable CAA § 110 requirements. Therefore, EPA staff

recommends a full approval of Rule 247 pursuant to CAA § 110(k)(3).

REFERENCES

-

1. PCAPCD Rule 247

, Natural Gas

- Fired Water Heaters, Small Boilers and

Process Heaters

, as amended February 13, 2014 and submitted to EPA on May 13, 2014

. 2. PCAPCD Rule 247, Natural Gas

- Fired Water Heaters, Small Boilers and

Process Heaters

, as a dopt ed October 10, 2013. 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. “Determ ination 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/re gion09/air/sips/littlebluebook2001.pdf ).