SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

ATTACHMENT B

C OMMENTS AND R ESPONSES

The following comments include those received from the U.S. EPA in their June 2011 Technical Support Documents, at the Task Force meeting held on July 11, 2013 and the Public Workshop meeting held on August 28, 2013 as well as written comments received on or before September 13, 20 13

.

1. Comment: T o improve clarity and enforceability it is recommended adding a definition

f

or “unscheduled repair”, “as

- found operating conditions”, and “breakdown conditions”.

Response: Such descriptions referring to equipment shutdown is addressed in other District rules. Therefore, there is no need to incorporate such definitions in rules 1146 and
1146.1

.

2. Comment: In measuring CO emissions both rules allow the use of a source test or the portable analyzer as part of the diagnostic emission check. However, the protocol for the diagnostic emission test requires the measurement of CO emissions along with NOx emissions. Consequently, the owner or operator does not have a choice in the way in
which CO emissions are measured.

Response: Staff agrees with the comment and has proposed to modify the rule language

to reflect current protoco l practice by clarify ing that the CO measurements will be done as part of both the source test and the diagnostic emission check. This change is considered to be administrative because there is no impact on the emissions, no change in the way in
which the rules have been implemented, and no impact on costs.

3. Comment: A dd definitions of "diagnostic emission check" and "source test" to both of
the rules

.

Response: Typically a definition is included in a rule if the term to be defined is not
described in t he rule. Both "diagnostic emission check" and "source test" are described in subdivision (d) of both Rule 1146 and 1146.1. On this basis, definitions for these terms
are not necessary.

4. Comment: Appendix IV

- B “Stationary Source Control Measures

– Area S ources” of the 1991 AQMP included control measure CM #90

- D

- 2. This control measure proposed the use flat plate solar collectors, low NOx burners or equivalent control technology to reduce NOx emissions from swimming pool water heaters. Swimming pool wate r heaters are regulated under Rule 1121 “Control of Nitrogen Oxides from Residential

- Type, Natural

-Gas

- Fired Water Heaters”. Based on this information the application of flat plate solar
collectors should be extended to Rules 1146 and 1146.1.

Response: CM #90

- D

- 2 addresses the reduction of NOx emission from residential swimming pool heaters under Rule 1121 but not for the much larger boilers and heaters regulated under Rules 1146 and 1146 .1

. However, Rules 1146 and 1146.1, as in other SCAQMD rules, do not specify the manner in which emission reductions are achieved. Thus, the owner or operator of Rule 1146 and 1146.1 equipment is not precluded from using flat plate solar collectors in demonstrating rule compliance.

5. Comment: For Rules 1146(c)(5) and 1146.1(c)(5) there appears to be a mislabeling of paragraphs which led to an unintentional requirement to test for CO emissions, even when
low

- fuel usage units do not require a source test or diagnostic emission check. The previous version of the rule, an d the staff report made it clear that it was the intention to only require periodic tune

- ups for this category of units.

Response : Staff agrees with the comment and has proposed changes to the rules to correct the rule language.

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