UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

for

EPA’s Direct Final Rulemaking

for the

California State Implementation Plan

Ventura County Air Pollution Control District Rule 74.15.1

Boilers, Steam Generators, and Process Heaters

Prepared by: Nicole Law

February 2014
2

Agency: Ventura County Air Pollution Control District

(VCAPCD)

SIP Approved Rule: Rule 74.15.1 – Boilers, Steam Generators, and 

Process Heaters

Adopted/Amended – June 13, 2000

Submitted – December 11, 2000

EPA Approved – October 10, 2001 (66 FR 51576)

Superseded Submittals: none

Subject of this TSD: Rule 74.15.1 – Boilers, Steam Generators, and 

Process Heaters

Amended – September 11, 2012

Submitted – April 22, 2013

RULE SUMMARY - Rule 74.15.1 regulates emissions of oxides of nitrogen (NOx) 

and carbon monoxide (CO) from boilers, steam generators, and process heaters. 

Changes from the approved SIP rule include:

1. Added a section to B. Requirements for units with rated heat input capacity 

equal to or greater than 1,000,000 BTU/hr and less than or equal to 

2,000,000 BTU/hr. The limits associated with these units are 20 ppmv for 

emissions of oxides of nitrogen and 400 ppmv for emissions of carbon 

monoxide. This new section also requires that the devices be certified in 

accordance with South Coast Air Quality Management District Rule 1146.2.

2. Moved the requirement that units under section B.1 be tested for 

compliance every 24 months to a new section B.4.a.

3. Added sections for testing requirements. Section B.4.b describes testing 

requirements for units with a rated heat input capacity less than or equal to 

2 million BTU/hr and section B.4.c describes annual screening 

requirements.

4. Revised Section D.2 to require the tune-up reports be submitted within 45 

days instead of 12 months.

5. Added section D.3 requiring the annual screening reports from section 

B.4.c be submitted annually.

6. Added section E.4 describing screening analyses requirements.

7. Added section F.4 describing how a violation is determined using screening 

analysis and what reporting and corrections need to be made. 

8. Added definitions for “alternate fuel” and “new boiler, steam generator, or 

process heater” in section G.
3

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 

compliance with the CAA §110(a)(2)(A) requirement for enforceability. 

2. Stringency - EPA’s Alternative Control Technique Document (ACT) titled, 

“NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers” (EPA453/R-94-022, 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 stringency. Generally, SIP rules are 

evaluated for RACT requirements of CAA §182(b)(2) and §182(f). 

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 modification of any SIPapproved 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 monitoring, 

recordkeeping, reporting and other provisions sufficiently ensure that 

affected sources and regulators can evaluate and determine compliance 

with Rule 74.15.1 consistently. 

2. The submitted rule is as stringent as other California District rules for this 

category, including South Coast AQMD Rule 1146.1 and Sacramento 

Metropolitan AQMD Rule 411and it is more stringent than CARB’s 

RACT/BARCT guidance. As a result, we have determined that this rule 

fulfills stringency requirements. Rule 74.15.1 is not subject RACT since the 

rule is applicable to sources too small to exceed the major source threshold 

and there is no CTG for the source category.

3. We 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) the emission limits in 

the submitted rule are more stringent than the existing SIP-approved control 

requirements that they would replace.
4

RULE DEFICIENCIES – We have identified no deficiencies with Rule 74.15.1 

sufficient for EPA to propose less than full approval.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION – The 

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

recommended for the next time the rule is amended.

1. South Coast AQMD Rule 1146.1 has lower NOx emission limits for 

units fired on natural gas in section (c)(2) Table 1146.1-1; consider 

these lower limits the next time the rule is amended.

EPA ACTION - The submitted Rule 74.15.1 strengthens the SIP. The rule largely 

fulfills the relevant CAA §110 and part D requirements. EPA staff recommends a 

full approval of Rule 74.15.1 pursuant to CAA §110(k)(3) and §301(a). 

REFERENCES -

1. VCAPCD Rule 74.15.1, Boilers, Steam Generators, and Process Heaters, 

as amended June 26, 2012 and submitted to EPA on April 22, 2013.

2. VCAPCD Rule 74.15.1, Boilers, Steam Generators, and Process Heaters, 

as amended on June 13, 2000, and approved into the SIP on October 10, 

2001 (66 FR 51576). 

3. “NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers,” 

EPA-453/R-94-022, March 1994. 

http://www.epa.gov/glo/SIPToolkit/ctg_act/199403_nox_epa453_r-94-

022_ici_boilers.pdf

4. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

5. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001 

(http://www.epa.gov/region09/air/sips/littlebluebook2001.pdf).

6. “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 http://www.arb.ca.gov/ractbarc/boilers.pdf.