VENTURA COUNTY APCD

STAFF REPORT

Amendments to Rule 74.15.1

Boilers, Steam Generators and Process Heaters

June 23, 2015

EXECUTIVE SUMMARY

The Ventura County Air Pollution Control Board

amended Rule 74.15.1 to reduce Oxides of Nitrogen 

(NOx) emissions from boilers, steam generators, or 

process heaters with a rated heat input capacity equal 

or greater than 2 million BTUs per hour and less than 

5 million BTUs per hour. Although this rule was last 

revised on September 11, 2012, APCD staff 

committed to updating this rule after 2014 in response 

to ARB comments. These revisions were included as 

a potentially feasible control measure in the Ventura 

County Triennial Assessment adopted by the APCD 

Board on January 8, 2013. 

This rule development will implement an All Feasible 

Measure as required by the California Clean Air Act

(HSC Section 40914). Ventura County APCD’s 

2007 Air Quality Management Plan relies on 

adopting All Feasible Measures to help attain the 

state ambient ozone air quality standard.

These more stringent NOx emission limits of 12 ppm 

(natural gas – atmospheric combustion) and 9 ppm 

(natural gas – all others) will only apply to new or 

replaced boilers, steam generators and process heaters

with a rated heat input capacity greater than 2 million 

BTU/hr and less than 5 million BTU/hr. These NOx 

standards for new and replaced units are the same as 

required by San Joaquin Valley Air Pollution Control 

District Rule 4307, Boilers, Steam Generators and 

Process Heaters, 2.0 MMBTU/hr to 5 MMBTU/hr. 

There are approximately 44 emission units potentially 

subject to the new NOx standards as units are 

replaced, and the potential emission reductions are 

about 9.3 tons NOx per year. 

These new lower NOx limits will not apply to 

existing equipment, which would have required

expensive retrofits to meet these standards. The costeffectiveness for retrofits was evaluated during the 

2012 rule revision and ranged from $12 per pound of 

NOX reduced to $1,887 per pound of NOx reduced 

(average of $147 per pound of NOx reduced). In 

contrast, 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. 

During the 2012 rule revision, the California Air 

Resources Board (ARB) strongly suggested in written 

comments that these proposed NOx limits apply to 

existing boilers, steam generators and process heaters, 

similar to what was adopted in South Coast AQMD 

Rule 1146.1. The 2012 rule revision did not include 

these new NOx limits for this equipment, and 

VCAPCD staff committed to reevaluating this rule 

after 2014. This proposal is the result of this staff 

reevaluation. Staff still considers retrofits not costeffective based on the 2012 cost analysis, but recent 

advances and wider availability of ultra-low NOx 

burners for the new and replacement market support 

this proposal as a feasible measure.

These amendments included a clarification of the 

applicability of the rule to other gaseous fuels besides 

natural gas. As revised, the rule will apply to other 

gaseous fuels including landfill gas, biogas, liquefied 

petroleum gas (LPG), otherwise known as propane, 

and produced oilfield gas. The use of the gaseous 

fuels other than natural gas requires the establishment 

of new NOx standards for new or replacement units. 

These amendments included NOx limits of 25 ppm 

for landfill gas and 15 ppm for biogas-fired units. 

These standards are based on the existing retrofit 

limits from SCAQMD Rule 1146.1. In addition, a 

new NOx standard of 20 ppm was adopted for LPG 

or propane-fueled units. This standard is based on

what is currently achievable for new or replacement 

units using propane. Also, the proposal contained

new NOx limits for produced oilfield gas at 15 ppm 

(atmospheric) and 12 ppm (pressurized), based on 

comments received from industry. 

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. Based on industry comments at the February 

2015 workshop, staff is proposing similar testing 

requirements 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, and existing annual screening 

requirements for these units would continue.

Finally, staff modified the definition of process heater 

to exclude additional types of combustion equipment 

from the requirements of Rule 74.15.1. This is a 

clarification of existing staff policy, and the following 

equipment shall not be subject to the provisions of 

Rule 74.15.1:
Staff Report Page 2

 Dehydrator, dryer, crematory, incinerator, 

calciner, cooker, roaster, furnace or open heated

tank

 Parts washers, metal heat treating, or metal 

furnaces

 Afterburners, vapor incinerators, thermal or 

catalytic oxidizers used in emission control 

devices

 Glass melting furnaces

 Tenter frame, fabric or carpet dryers.

This proposed rule revision will not nullify existing 

permit conditions such as Best Available Control 

Technology (BACT) standards that limit the NOx 

emissions from these combustion sources. All units 

subject to this rule are currently permitted by APCD.

This report contains five additional sections: (1) 

Background, (2) Proposed Rule Requirements, (3) 

Comparison of Proposed Rule Requirements with 

Other Air Pollution Control Requirements, (4) Impact 

of the Proposed Rule, and (5) Environmental Impacts 

of Methods of Compliance. The first section 

provides background information including 

regulatory history, air pollution control technology 

and source description. The second section explains 

the key features of the proposed requirements. The 

third section compares the proposed requirements 

with existing federal requirements and Best Available 

Control Technology (BACT). The fourth section is 

an analysis of the proposed amendment's effect on 

ROC emissions, cost-effectiveness, and 

socioeconomic impacts. The last section examines 

the environmental impacts of compliance methods 

and the mitigations of those impacts.

BACKGROUND

Introduction

Rule 74.15.1 applies to boilers, steam generators, or 

process heaters with a rated heat input capacity from 

1 million BTU per hour up to 5 million BTU per 

hour. The main purpose of the rule is to limit NOx 

emissions, which are precursors to ozone formation. 

Ventura County is currently designated a 

nonattainment area for ambient ozone. Ventura 

County is required by the California Clean Air Act 

(California Health and Safety Code Section 40914) to 

adopt “all feasible measures” as an alternative 

requirement to reducing precursor emissions by a 

minimum of five percent per year. This proposal is 

an all feasible measure that will reduce NOx 

emissions.

Regulatory History

Rule 74.15.1 was adopted in May 1993 based on 

Control Measure N-105 from the 1991 Air Quality 

Management Plan. This initial rule adoption required 

the retrofit of existing boilers, steam generators, and 

process heaters from 1 to 5 million BTU per hour to 

meet a new NOx limit of 30 ppm and a carbon 

monoxide (CO) limit of 400 ppm, corrected to a 3 

percent oxygen level. The original rule adoption 

reduced NOx emissions by 68 tons per year, and the 

cost-effectiveness ranged from $2.47 to $8.57 per 

pound of NOx reduced. 

In June 1995, Rule 74.15.1 was amended to add a 

new tune-up procedure for natural draft fired 

equipment. In June 2000, the rule was amended to 

satisfy an EPA-identified deficiency in the test 

method that related to startups, shutdowns, and 

breakdown conditions.

In September 2012, the rule was amended to include 

a new NOx limit of 20 ppm and certification 

requirements for new boilers, steam generators, and 

process heaters rated between 1 and 2 million BTU 

per hour. This new NOx standard was based on the 

same standard set by South Coast AQMD Rule 

1146.2. In addition, the 2012 amendments reduced 

compliance costs by changing the source test 

requirement for this equipment from every two years 

to every four years if an annual screening test was 

performed.

During the 2012 rule revision, comments were 

received from the California Air Resources Board 

(ARB) strongly suggesting that staff propose new 

NOx limits for existing boilers, steam generators, and 

process heaters based on standards adopted in South 

Coast AQMD Rule 1146.1. In response, staff 

performed a cost analysis for retrofitting existing 

equipment to the South Coast standards, and the costeffectiveness for this control measure ranged from 

$12 to $1,887 per pound of NOx reduced and an 

average cost-effectiveness of $147 per pound. On 

this basis, it was determined that the ARB 

recommendation was not cost-effective, and it was 

not included in the 2012 rule revision. In response to 

the ARB comments, staff committed to a reevaluation 

of the rule after 2014. 

Another reason that Rule 74.15.1 may differ from the 

SCAQMD Rule 1146.1 is that NOx emission sources 

in South Coast may instead be subject to Regulation 

XX, RECLAIM. RECLAIM is a market-based NOx 
Staff Report Page 3

emission credit trading program that allows more 

efficiently controlled sources to sell excess credits to 

other less easily controlled sources. Sources

participating in RECLAIM are exempt from the 

command and control NOx rules such as Rule 1146.1. 

Recent reports of the value of Reclaim Trading 

Credits in the South Coast average a little over $2 per 

pound of NOx. Thus, these market-based costs may 

be much lower than what may be required to retrofit 

existing boilers, steam generators, and process 

heaters.

Small Boiler NOx Emission Sources

Although these proposed amendments to Rule 

74.15.1 do not require retrofits of existing boilers, 

steam generators, or process heaters, there will be 

impact on new or replaced equipment from a wide 

variety of sources. As shown in Table 1, the affected 

sources have boilers or steam generators that produce 

hot water or steam for office buildings, schools, 

hotels, and industrial operations.

Natural gas-fired heaters are used at oil and gas 

production facilities to break oil-water emulsions so 

that the oil can be accepted by pipeline or transport. 

Process heaters are used to heat material streams for 

industrial operations such as oil heaters at asphalt 

batch plants. Table 1 lists facilities currently having 

permitted boilers, steam generators, or process 

heaters in the range greater than 2 and less than 5 

million BTU/hr. The projected NOx emission 

reductions from the replacement of 44 boilers, steam 

generators, or process heaters are approximately 9.3 

tons per year.

Table 1

Facilities with Natural Gas-Fired Boilers, Steam Generators or Process Heaters (2 to 5 Million BTU/hr)

Amgen Inc. La Conchita Oil & Gas Plant Ronald Reagan Pres. Library

Astrofoam Molding Company Inc. Los Cerritos Intermediate School Saticoy Lemon Association/Plant #4

California Resources Production Maple Leaf Bakery-Pioneer Div Seneca Resources Corporation

CalMat Company / Vulcan Materials Skyworks Solutions, Inc.

Thousand Oaks Civic Arts Plaza Naval Base Ventura County St. John's Pleasant Valley Hospital

Farmers Insurance Group Newbury Park High School Tenby Production Facility

Granite Construction Company Oxnard Lemon Co. Ventura Co. National Bank Bldg

Hill Cyn Wastewater Treatment Plant Paramount Citrus Ventura Youth Correctional Facility

Hyatt Westlake Plaza Hotel Platform Gilda Verizon California

Juvenile Justice Complex Record Technology Inc. Vulcan Materials Co., Western Div.

NOx Emission Control Technology

NOx emissions are defined by CARB Method 100 

and include both nitric oxide (NO) and nitrogen 

dioxide (NO2). In almost all combustion sources, 

more than 90 percent of the NOx emissions in the 

exhaust stack are nitric oxide. NOx emissions are 

formed using three different mechanisms: thermal 

NOx, fuel NOx, and prompt NOx. Thermal NOx is 

formed the reaction of nitrogen and oxygen at high 

temperatures, typically above flame temperatures of 

2000oF. Fuel NOx is formed by the direct oxidation 

of organo-nitrogen compounds contained in the fuel, 

but this is not an issue for natural gas fuel. Prompt 

NOx is formed by the relatively fast reaction between 

nitrogen, oxygen, and hydrocarbon radicals, 

consisting of hundreds of reactions and dozens of 

chemical species. Prompt NOx becomes more 

important under fuel rich conditions.

According to the SCAQMD Rule 1146.1 Staff 

Report, the technology available to meet the new 

NOx limits is the use of ultra-low NOx burners. 

These burners designed to premix the fuel and air 

prior to combustion achieve low emissions while 

maintaining good flame stability and heat transfer 

characteristics. Ultra-low NOx burners are available 

from many vendors including but not limited to: Ajax 

Boiler, Burnham, Cleaver Brooks, Laars, Miura, 

Superior Boiler, Parker Boiler, Altex Technologies, 

Bloom Engineering, S.T. Johnson Company, Power 

Flame, Alzeta Corporation, Maxon, and SAACKE.

The object of these ultra-low NOx burners is to create 

more uniform combustion, better mix the fuel and 

oxygen, and reduce the combustion residence times. 

These characteristics will reduce NOx formation and 

reduce the peak flame temperature, at which thermal 

NOx is formed. Some burners are also designed to 

manage the flame area to reduce hot spots. The 

combustion uniformity reduces the formation of fuel 

rich zones where prompt NOx is formed. These 

burners may increase thermal efficiencies by reducing 

the amount of excess air needed for combustion. This 

has the added benefit of reducing fuel usage, which 

results in energy savings.

Another type of ultra-low NOx burner is the radiant 

premix burner that can be constructed from ceramic 

or metal fibers, which can spread the flame via 

radiant heat. These burners increase boiler efficiency 
Staff Report Page 4

by having a more uniform heat source, which leads to

more efficient heat transfer.

Most premix burners require the use of a blower to 

mix the fuel and air prior to combustion. 

Atmospheric boilers, where the burners are not totally 

enclosed, may still need a blower to premix the fuel 

and air. Ultra-low NOx burners may need automatic 

controls and an oxygen trim system to maintain 

emission levels, efficiency, operate at turndown 

levels, and initiate startups.

Ultra-low NOx burner systems can achieve less than 

9 ppm NOx for boilers, steam generators, or process 

heaters without the use of Flue Gas Recirculation 

(FGR) systems. Source tests performed by the San 

Joaquin Unified Air Pollution Control District 

showed a 95 percent compliance rate with 9 ppm 

limits using ultra-low NOx burners. The average 

NOx concentration measured was 7 ppm. 

AMENDMENTS TO RULE 74.15.1

Rule Applicability (Section A)

The amendments include clarification of the rule 

applicability so that the rule will apply to both liquid 

and gaseous fuels. Applicable gaseous fuels include 

natural gas, landfill gas, biogas, liquefied petroleum 

gas (propane), and produced oilfield gas. In addition, 

the rule will apply to both stationary and portable 

process heaters. These changes will align Rule 

74.15.1 more closely to South Coast AQMD 1146.1.

Emission Limits for New and Replacement 

Boilers, Steam Generators and Process Heaters 

(Section B.2.b)

The amended rule will reduce NOx emissions from 

new and replaced boilers, steam generators, and 

process heaters in the size range greater than 2 

million BTU/hr and less than 5 million BTU/hr. 

Effective January 1, 2016, the new NOx limits for 

this natural-gas fired units in this size range will be 12 

ppmv at 3 percent oxygen (0.015 lbs/MMBTU) heat 

input (calculated as NO2) for atmospheric units and 9 

ppmv for all other natural gas units. These limits are 

based on the new and replaced NOx limits from San 

Joaquin Valley Unified APCD Rule 4307. 

Atmospheric units are defined in the rule as having a 

non-sealed combustion chamber in which natural 

draft is used to exhaust combustion gases.

The amended rule will include new NOx limits for 

new or replaced units fired on gaseous fuels other 

than natural gas. The NOx limit for landfill gas-fired 

units is 25 ppm, and the NOx limit for biogas is 15 

ppm. Both of these standards are based on the NOx 

limits for existing equipment subject to SCAQMD 

Rule 1146.1. In addition, a new NOx limit was 

adopted for new or replaced units at 20 ppm for LPG 

or propane-fired units. This standard is based on

available low NOx burner technology for propanefired units. Also, the proposal contains new NOx 

emission limits for new or replaced units fired on 

produced oilfield gas. The NOx limits of 15 ppm 

(atmospheric) and 12 ppm (pressurized) for units 

using this fuel are based on comments received from 

the oil industry.

The existing 20 ppm NOx limit for new or 

replacement natural gas-fired boilers, steam 

generators, and process heaters for the size range 

equal to or greater than 1 million BTU/hr and less 

than equal to 2 million BTU/hr was adopted in 2012, 

and is not being revised. This NOx limit is consistent 

with SCAQMD Rule 1146.2. 

Change in Testing Frequency (Section B.4.b)

New or replacement units subject to the new NOx 

limits in Subsection B.2.b and greater than 2 million 

BTU/hr input heat capacity will be subject to reduced

frequency source testing requirements. These units 

will test for compliance upon initial installation and 

then once every 48 months instead of every 24 

months. The newer equipment is more reliable and 

the emissions are more stable over time. In addition, 

this equipment will still be subject to the annual 

screening requirements.

Clarify Annual Screening Deadline

(Section B.4.d) 

The existing rule does not have a clear deadline for 

performing the annual screening analysis, which only 

applies to units with a rated heat capacity less than or 

equal to 2 million BTU/hr. This proposal establishes 

this deadline as no later than the yearly anniversary 

date of the last source test. 

Exemption (Section C.2)

As described earlier, the amendments to Rule 74.15.1 

have been developed to reduce NOx emissions from 

new or replacement units, rather than retrofit existing 

units, because of cost considerations. However, one 
Staff Report Page 5

existing source (Thompco) has been identified that 

would have required retrofitting to meet the existing 

NOx limit of 30 ppm when the proposed changes to 

rule applicability become effective. Since the cost of 

this retrofit exceeds $9.50 per pound of NOx reduced,

staff adopted an exemption from the existing NOx 

limit in Section B.1 for any portable oil well 

dewaxing process heater when the annual heat input 

is less than 2.8 billion BTU. The amount of NOx 

reductions not captured by including this exemption 

for this source is 0.29 ton NOx per year.

Recordkeeping Requirements

Totalizing Fuel Meter (Section D.1)

Currently, units that are exempt from the NOx limits 

in Subsection B.1 because of low fuel consumption at 

an annual heat input of less than 1.8 billion BTU are 

required to install a totalizing fuel meter for each 

applicable unit and for each fuel. These amendments

will require that any newly exempt source not subject 

to Subsection B.1 install a totalizing fuel meter.

Recordkeeping Requirements

Screening Test Log (Section D.3)

A new recordkeeping requirement was adopted for 

the annual screening of NOx and CO required by 

Subsection B.4.c. Operators shall record the date of 

the screening, measured NOx and CO readings, 

applicable emission limits, and any action taken, in an 

annual test log. This test log shall be made available 

to APCD personnel upon request. The purpose of 

this recordkeeping is to increase rule compliance and 

rule enforceability.

Test Methods (Section E.1)

An alternative procedure was adopted to allow for the 

determination of emission compliance in terms of 

lbs/MMBTU. These emission terms are calculated by

dividing the emission rate in lbs/hr by the heat input 

rate (MMBTU/hr). Staff is proposing the South 

Coast AQMD’s “Compliance Protocol for the 

Measurement of Nitrogen Oxides, Carbon Monoxide, 

and Oxygen from Sources Subject to SCAQMD 

Rules 1146 and 1146.1, dated March 10, 2009” as an 

alternative procedure for this purpose.

Definitions (Section G)

The definition of “process heater” in Subsection G.12 

was amended for clarification so that the rule will not 

apply to additional process heating combustion 

sources that are not as amenable to advanced NOx 

emission control technology. The additional 

combustion sources proposed for exclusion from the 

process heater definition and rule applicability are 

listed in Table 2.

Table 2

Combustion Sources Excluded from Process Heater Definition

Kiln Oven Afterburners Thermal Oxidizers

Dehydrator Dryer Catalytic Oxidizers Glass Melting

Crematory Incinerator Tenter Frame Dryer Open Heated Tank

Roaster Furnace Carpet Dryer Fabric Dryer

COMPARISON OF PROPOSED RULE REQUIREMENTS

WITH OTHER AIR POLLUTION CONTROL REQUIREMENTS

Health and Safety Code Section 40727.2 requires 

Districts to compare the requirements of a proposed 

revised rule with other air pollution control 

requirements. These other air pollution control 

requirements include federal New Source 

Performance Standards (NSPS), federal National 

Emissions Standards for Hazardous Air Pollutants 

(NESHAPS), Best Available Control Technology 

(BACT), and any other District rule that applies to 

the same equipment.

At this time, EPA has not adopted a national rule or a 

CTG to reduce NOx emissions from small boilers or 

process heaters. EPA published an Alternative 

Control Techniques (ACT) for process heaters in 

1993, and an ACT for industrial, commercial, and 

institutional boilers in 1994. These ACT documents 

provide an analysis of control technologies and their 

cost-effectiveness. Although ACT documents do not 

represent presumptive RACT, the control 

technologies evaluations provide some useful 

background information even if the analysis is over 

20 years old. However, almost all the focus of these 

ACT documents is on much larger boilers and 

refinery based process heaters

A review of current BACT determinations from the 

South Coast AQMD and California Air Resources 
Staff Report Page 6

Board indicates that BACT for this source category is 

based on existing SCAQMD Rule 1146.1. In 

summary, there are no conflicts between the proposed 

amendments to Rule 74.15.1 and any other pertinent

air pollution control regulations. 

IMPACT OF THE PROPOSED RULE

NOx Emissions Impacts

The estimated NOx emission reductions of 9.3 tons 

per year from this source category are significant, and 

all emission reductions are needed to reach the 

federal and state ambient ozone air quality standards. 

Ultra-low NOx burners for replacement or new 

boilers and process heaters in the size range between 

2 and 5 MMBTU/hr are available, feasible, and costeffective.

Cost-Effectiveness

Staff estimates typical cost-effectiveness at about 

$2.30 per pound of NOx reduced for new or replaced 

units. This analysis is based on the added cost 

($10,000) of installing an ultra-low NOx burner in 

place of the normal burner for a new or replaced unit. 

Assuming a ten year life and four percent interest rate 

resulted in a capital recovery factor (CRF) of 0.123. 

This assumes that the energy savings from the lower 

excess air characteristics of ultra-low NOx system 

will compensate for any added costs needed to 

control the combustion process including electronic 

oxygen feedback or oxygen trim systems.

Incremental Cost-Effectiveness Analysis

Health and Safety Code Section 40920.6(a) requires 

districts to identify one or more potential control 

options, assess the cost-effectiveness of those options, 

and calculate the incremental cost-effectiveness. 

Health and Safety Code Section 40920.6 also requires 

an assessment of the incremental cost-effectiveness 

for proposed regulations relative to ozone, carbon 

monoxide (CO), sulfur oxides (SOx), nitrogen oxides 

(NOx), and their precursors.

Incremental cost-effectiveness is defined as the 

difference in control costs divided by the difference 

in emission reductions between two potential control 

options achieving the same emission reduction goal 

of a regulation.

An incremental cost-effectiveness analysis was 

performed by the South Coast AQMD in their 2008 

revision to Rule 1146.1. The alternative control 

option identified in their evaluation was the use of 

Selective Catalytic Reduction (SCR) control 

equipment, which uses a catalyst with ammonia 

injection to reduce the NOx emission from 9 ppm to 5 

ppm. The estimated incremental cost-effectiveness 

calculated by SCAQMD staff for this alternative 

ranged from $53 to $141 per pound of NOx reduced. 

The high cost of this alternative control option 

disqualifies it as a cost-effective control measure.

Socio-Economic Impacts

Assembly Bill 2061 (Polanco), which became 

effective January 1, 1992, requires that the District 

Board consider the socioeconomic impacts of any 

new rule. The Board must evaluate the following 

socioeconomic information on proposed revisions to 

Rule 74.15.1. 

(1) The type of industries or businesses, including 

small business, affected by the rule or 

regulation.

The amendments to this rule may directly affect 

the following facilities:

 Commercial buildings

 Fruit packing plants

 Government facilities

 Hospitals

 Hotels

 Naval facilities

 Oil and Gas Production

 School Districts

 Small scale factories

(2) The impact of the rule amendments on 

employment and the economy of the region.

Revisions to this rule are not expected to have a 

negative impact on either employment or the 

economy of Ventura County. Worst-case cost 

estimates for the end user are not significant 

enough to impact employment. Limiting the 

impact of the proposal to new or replaced units 

will delay the rule implementation and spread 

out the costs over many years.

(3) The range of probable costs, including costs to 

industry or business, including small business, 

of the rule or regulation.

Based on a staff analysis, the probable costeffectiveness of $2.30 per pound of NOx 
Staff Report Page 7

reduced may be expected when installing or 

replacing a new boiler, steam generator, or 

process heaters in the size range between 2 and 

5 MMBTU/hr. The added cost to a new or 

replaced unit utilizing the ultra-low NOx burner 

was estimated at $10,000. The energy savings 

from the lower excess air characteristics of the 

ultra-low NOx burners should compensate for 

any additional costs, including electronic 

combustion controls using oxygen feedback.

(4) The availability and cost-effectiveness of 

alternatives to the rule or regulation being 

proposed or amended.

The proposed revision to Rule 74.15.1 is the 

most cost-effective control option, which 

involves the use of ultra-low NOx burners. The 

new proposed NOx limits will not require the 

use of additional equipment such as Flue Gas 

Recirculation (FGR). Other control alternatives, 

such as the use of SCR control equipment, are 

not cost-effective for this source category.

(5) The emission reduction potential of the rule.

The anticipated emission reduction potential of 

the proposed rule is about 9.3 tons per year of 

NOx emissions. These emission reductions 

result from the use of ultra-low NOx burners.

(6) The necessity of adopting, amending, or 

repealing the rule or regulation in order to attain 

state and federal ambient air standards pursuant 

to Chapter 10 (commencing with Section 

40910).

Ventura County is classified as a nonattainment 

area for the federal Ambient Air Quality 

Standards for ozone. These proposed rule 

amendments will reduce NOx emissions that are 

precursors to the formation of ozone. 

According to the 2007 AQMP, these emission 

reductions will help the District in its effort to 

attain the standards. California Health and 

Safety Code Section 40914(b)(2) requires that 

the District adopt every feasible measure to 

reduce ozone precursors.

ENVIRONMENTAL IMPACTS OF METHODS OF COMPLIANCE

California Public Resources Code Section 21159 requires the District to perform an environmental analysis of the 

reasonably foreseeable methods of compliance. The analysis must include the following information on proposed 

amendments to Rule 74.15.1

(1) An analysis of the reasonably foreseeable environmental impacts of the methods of compliance.

(2) An analysis of the reasonably foreseeable mitigation measures.

(3) An analysis of the reasonably foreseeable alternative means of compliance with the rule or regulation.

Table 3 lists all reasonably foreseeable compliance methods, the environmental impacts of those methods, and 

measures that could be used to mitigate the environmental impacts.

Table 3

Environmental Impacts and Mitigations of Methods of Compliance

Compliance Methods (including all 

reasonably foreseeable alternative 

means of compliance)

Reasonably Foreseeable 

Environmental Impacts 

Reasonably Foreseeable 

Mitigation Measures

Installation of Ultra-Low NOx Burners Air Quality Impacts: Lower excess air 

requirements may increase carbon 

monoxide emissions.

Both advanced flame stabilization 

and rapid mixing design of the 

ultra-low NOx burners will 

mitigate any CO emission 

increases. 

Installation of Ultra-Low NOx Burners Energy Efficiency Impacts: Older 

ultra-low NOx burners resulted in a 

two percent fuel penalty.

Lower excess air requirements 

and better combustion controls 

will actually increase fuel 

efficiency.

Installation of Ultra-Low NOx Burners Air Quality Impacts: Construction 

emissions resulting from the 

replacement of boilers and process

heaters.

No add-on controls or flue gas 

recirculation systems are required 

so construction emissions are 

minimized.

This analysis demonstrates that the adoption of amendments to Rule 74.15.1 will not have a significant effect on the 

environment due to unusual circumstances.
Staff Report Page 8

REFERENCES

1. Ajax Boiler, “Low NOx systems,” 

www.ajaxboiler.com/products/ajax-seriesboilers/low-nox-systems.

2. Altex Technologies, “Ultralow NOx Burner for 

Boilers/Process Heaters,” www.altextech.com

3. Alzeta Corporation, “Ultra Low NOx Emission 

Burners,” www.alzeta.com/ultra-low-noxburners.

4. Ballard, Alan, “Estimate of NOx emission 

reductions from Proposed Revisions to Rule 

74.15.1,” October 28, 2014.

5. Baukal, Charles, “Everything You Need to 

Know about NOx,” www.metalfinishing.com

6. EPA, “NOx Emissions from Industrial, 

Commercial, and Institutional Boilers,” EPA453/R-94-022, 1994.

7. EPA, “NOx Emissions from Process Heaters,” 

EPA-453/R-93-034, 1993.

8. Johnson Burners, “SWRLmatic Ultra Low NOx 

Burner,” www.johnsonburners.com.

9. Karell, Mark and Amit Chattopadhyay, “NOx 

Emission Reduction Strategies,” Pollution 

Online, June 16, 2000.

10. Maxon Corporation, “Maxon M-PAKT Ultra 

Low NOx Burners,” 

www.maxoncorp.com/Pages/product-Low-NOxBurners.

11. May, Walter, “Reduction of Thermal and 

Prompt NOx in Exhausts of Natural Gas Fueled 

Boilers,” SFA International Website Library. 

www.sfainternational.com/library. Oct. 9, 2012.

12. Parker Industrial Boiler, “Premix Metal Fiber 

Burner Low NOx Systems: The Solution to 

Pollution Steam, Hot Water or Thermal Fluid,” 

www.parkerboiler.com.

13. Pisano, Stephen, “Emerging Ultra-Low-NOx 

Burner Technology for the Heat-Treat 

Industry,” 

www.industrialheating.com/articles/91209-

emerging-ultra-low-nox-burner-technology. 

August 5, 2013.

14. San Joaquin Valley Unified APCD Rule 4307, 

“Boilers, Steam Generators, and Process 

Heaters – 2.0 MMBth/hr to 5.0 MMBtu/hr. 

Amended May 19, 2011.

15. South Coast AQMD Board Meeting, “Amend 

Rule 1146.1, Emissions of Oxides of Nitrogen 

from Small Industrial, Institutional, and 

Commercial Boilers, Steam Generators, and 

Process Heaters,” Sept 5, 2008.

16. South Coast AQMD, “Compliance Protocol for 

the Measurement of Nitrogen Oxides, Carbon 

Monoxide, and Oxygen from Sources Subject to 

SCAQMD Rule 1146 and 1146.1,” March 10, 

2009.

17. South Coast AQMD, “Final Environmental 

Assessment for Proposed Amended Rule 

1146.1,” August 2008.

18 South Coast AQMD, “Final Staff Report for 

Proposed Amendments to Rule 1146.1,” 8/2008

19. South Coast AQMD, “Source Test Protocol for 

Determining Oxygen Corrected Pollutant 

Concentrations from Combustion Sources with 

High Stack Oxygen Content Based on Carbon 

Dioxide Emission” March 3, 2011.

20. Southern California Gas Company, 

“Understanding SCAQMD Air Quality Rules 

for Large Boilers over 2 Million BTU/HR,” 

www.socalgas.com, 2009.

21. Ventura County APCD, “Final Staff Report for 

Revisions to Rule 74.15.1,” May 10, 2012.

22. Ventura County APCD, “Triennial Assessment 

and Update,” January 2013.

DISCLAIMER

This report contains references to company and product names to illustrate product availability. Mention of these 

names is not to be considered an endorsement by the Ventura County Air Pollution Control District.