### VENTURA COUNTY APCD
STAFF REPORT

Amendments to Rule 74. 15.1 Boilers, Steam Generators and Process Heaters

June 23, 20 1 5

EXECUTIVE SUMMARY

The Ventura County Air Pollution Control Board

amend ed Rule 74.15.1 to reduce Ox ides of Nitrogen (NOx) emissions from boilers, steam gener ators, 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 t his rule was last revised on September 11, 2012 , APCD staff committed to updating this rule after 201 4 in response

to ARB comments. T h ese revisions w ere included as a potentially feasible control measure in the Ventura County Triennial Assessment adopted by the APCD Board on January 8, 2013.

This r ule development will implement an All Feasibl e 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.

The se more str ingent 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 replace d units are the same as

re quired 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 ne w NOx standards as units are replaced , and the potential emission reductions are about 9 .3 tons NOx per year.

The se new lower NOx limits will not apply to existing equipment, which wou ld have require d expensive retrofits to meet these standards. The cost

effectiveness 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 NO x 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, wh ere 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 rul e after 2014. This proposal is the result of this staff

reevaluation. Staff still considers retrofits not cost

effective 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.

Th ese amendments included a clarification of th e 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.

Th ese 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 contain ed 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 biennia l 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 requir ements 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 modif

ied 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:

### S taff Report Page 2

 Dehydrator, dryer, crematory, incinerator, calciner, cooker, roaster, furnace or open heated

tank

 Parts washers, metal he at treating, or metal

furnaces

 Afterburner s , 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 cond itions such as Best Available Control Technology (BACT) standards that l imit 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 Re quirements , (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 info rmation including regulatory history, air pollution control technology and source description. The second section explains the key features of the proposed re quirements . The third section compares the proposed requirements with existing federal requireme nts 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 meth ods 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 ad opted 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 limi t 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 Jun e 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 st andard 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 th e 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 cost

effectiveness for this control measure ranged from $12 to $1,887 per pound of NOx reduced and an

average cost

- effectivenes s 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.

Ano ther reason that Rule 74.15.1 may differ from the SCAQMD R ule 1146.1 is that NOx emission sources in South Coast may instead be subject to Regulation XX, RECLAIM. RECLAIM is a market

- based NOx

### S taff Report Page 3

emission credit trading program that allows more efficiently c ontrolled sources to sell excess credits to other less easily controlled sources. Source s 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, t hese 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 Source s

Although these proposed am endments 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 o r transport

. Process heaters are used to heat material streams for industrial operations such as oil heaters at asphalt batch plants. T able 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 Generator s 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 Scho ol 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 Te nby 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

J uvenile 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 (NO 2 ). In almost all combustion sou rces, 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

te mperatures, typically above flame temperatures of

2000 o F. 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 b etween 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 availab le 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, M i ura, Superior Boiler, Parker Boiler, Altex Technologies, Bloom Engineering, S.T. Johnson Company, Power Flame, Alzeta Corporation, Maxon, and SAA CKE.

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 whic h 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 reduc ing

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 burner s 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 co mbustion. Atmospheric boilers, where the burners are not totally enclosed, may still need a blower to premix t he 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 Uni fied Air Pollution Control District showed a 95 percent compliance rate with 9 ppm limits using ultra

- low NOx burners. The average

NOx concentration measured w as 7 ppm.

AMENDMENTS TO RULE 74 .15.1

Rule Applicability (Section A)

The amendment s 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 Proce ss 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 ne w 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 NO 2 ) for atmospheric units and 9 ppmv for all other natural gas units. These limits are

based on the new and r eplaced 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 limi ts 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 e quipment subject to SCAQMD Rule 1146.1. In addition, a new NOx limit was adopted for new or replaced units at 2 0 ppm for LPG

or propane

- fired units. This standard is based on

available low NOx burner technology for propane

fired units

. Also, the p roposal 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 existin g 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 w as adopted in 2012,

and is not being revised

. Th is 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 reduce d 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 additi on, 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 R ule 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 a nd for each fuel. Th ese amendment s 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 com pliance and

rule enforceability

.

Test Methods (Section E.1 )

An alternative procedure was adopted to allow for the determination of emission complian ce 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 Monoxid e, 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 th e 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 Fu rnace 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 p ollution 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) , a nd 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 hea ters 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

te chnologies 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 determ inations 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 pe rtinent air pollution control regulations.

IMPACT OF THE PROPOS ED RULE

NOx Emissions Impacts

T he 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

f ederal 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 availab le , feasib le , and cost

effective

.

Cost

- Effectiveness

Staff estimates typ ical 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 y ear 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

- effec tiveness 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 redu ction 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 re duced. 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 socio economic 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 a mendm ents to th is 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 amen dments on employment and the economy of the region.

Revisions to th is rule are not expected to have a negative impact on either employment or the economy of Ventura County. Worst

- case c ost
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 t he rule or regulation.

Based on a staff analysis

, the probable cost

effectiveness of $ 2.30 per pound of NOx

### Staff Report Page 7

reduced ma y 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 electro nic combustion controls using oxygen feedback.

(4) The availability and cost

- effectiveness of alternatives to the rule or regulation being proposed or amended.

T he proposed revision to Rule 74.15.1 is the

most cost

- effective control option, which

involv es 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 f

ederal 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 t he 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 require s 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 c ompliance 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 forese eable 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 emiss ions

. 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 perce nt 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 th e adoption of amendments to Rule 74.15.1 will not have a significant effect on the

environment due to un usual circumstances.

### Staff Report Page 8

REFERENCES

1. Ajax Boiler, “Low NOx systems,” www.ajaxboiler.com/products/ajax

- series

boilers/low

- nox

- systems.

2

. Altex Technologies, “Ultralow NOx Burner for

Boilers / Process Heaters,” www.altextech.com

3. Alzeta Corporation, “Ul tra Low NOx Emission Burners,” www.alzeta.com/ultra

- low

- nox

burners.

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.metal finishing.com

6

. EPA, “NOx Emissions from Indust r ial, Commercial, and Institutional Boilers,” EPA

453/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.johnson burners.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

- NOx

Burners.

11. May, Walter, “Re duction of Thermal and Prompt NOx in Exhausts of Natural Gas Fueled Boilers,” SFA International Website Library. www.sfainternational.com/library. Oct

. 9, 2012.

1 2

. Parker Industrial Boiler, “Premix Metal Fiber

Burner Low NOx Systems: The Solution to

Pol lution Steam, Hot Water or Thermal Fluid,” www.parkerboiler.com. 1 3

. 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

.

1 4

. 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.

1 5

. South Coast AQMD Board Meeting, “Amend Rule 1146.1, Emissions of Oxides of Nitrogen

from Small Ind ustrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters,” Sept 5, 2008.

1 6

. South Coast AQMD, “Compliance Protocol for the Measurement of Nitrogen Oxides, Carbon Monoxide, and Oxygen from Sources Subject to SCAQMD Rule 1146 a nd 1146.1,” March 10,

2009.

1 7

. South Coast AQMD, “ Final Environmental Assessment for Proposed Amended Rule 1146.1,” August 2008.

1 8 South Coast AQMD, “Final Staff Report for Proposed Amendments to Rule 1146.1,” 8/ 2008

1 9

. 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 La rge 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.

2 2

. Ventura County APCD, “Triennial Assessment and Update,” January 2013.

DISCLAIMER

This report co ntains 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.