Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

FINAL STAFF REPORT

Revised Proposed Amendments to Rule 4702 (Internal Combustion Engines)

August 18, 2011

Prepared by: Anna Myers, Senior Air Q uality Specialist, Plan Development Sandra Lowe-Leseth, Air Quality Engineer, Permits

Reviewed by: Brian Clements, Seni or Air Quality Engineer, Permits Ramon Norman, Air Quality Engineer, Permits Patrick Houlihan, Senior Air Quality Specialist, Compliance Kevin McCaffrey, Senior Air Q uality Specialist, Incentives Mike Oldershaw, Manager, Compliance Leonard Scandura, Manager, Permits Errol Villegas, Program Manager , Strategies and Incentives Samir Sheikh, Director, Strategies and Incentives

I. SUMMARY

The San Joaquin Valley Unified Air Pollution C ontrol District (District) is committed to protecting public health for all residents in the San Joaquin Valley (Valley) through

efforts to meet health-based state and f ederal ambient air quality standards with efficient, effective, and entrepreneurial air qu ality management strategies. One such strategy includes a commitm ent in both the District’s 2007 Ozone Plan (Ozone Plan)

and 2008 PM2.5 Plan (PM2.5 Plan) to amend Rule 470 2 (Internal Combustion Engines)

to reduce emissions of oxides of nitr ogen (NOx) from this source category.

The proposed amendments to Rule 4702 seek to obtain as much NOx emission

reductions from the source cat egory as expeditiously practica l, technologically feasible, and economically reasonable, as determined by the District’s Governing Board. In order to provide better service to stak eholders and affected i ndustry, the proposed amendments will also simplify and clarif y existing rule language and standards. Proposed amendments are applicable to non-agriculture operated internal combustion engines. Proposed amendments include provisio ns for limited use engines, point of sale requirements for engines rated at 25 to 50 brake horsepower ( bhp), more stringent NOx emission limits for various types of engines within this category, and SOx requirements would be added to rule language.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

2 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 A. Reasons for Rule Development and Implementation

The federal Environmental Pr otection Agency (EPA) has classified the San Joaquin Valley Air Basin as an extreme non-attain ment area for federal ambient air quality

standard for ozone and non-attainment for t he standard for particulate matter with aerodynamic diameter of 2.5 micrometers and less (PM2.5 ). The California Air Resources Board (ARB) has classified the bas in a severe non-attainment area for the

state’s ozone standard. As a re sult of these classifications , the District is required to evaluate sources of pollution and create a stra tegy (plan) for how the District will come

into attainment of the standards. The ozone and PM2.5 attainment strategies are comprised of regulatory and incentive-based measures to reduce emissions of NOx, volatile organic compounds (VOCs), sulfur oxides (SOx) as well as directly-emitted particulates.

The Ozone Plan and PM2.5 Plan each iden tified Rule 4702 (Internal Combustion Engines) as part of the District’s attainment strategy. There is no commitment for a specific quantity of NOx reductions in either District attainment plan.

B. Rule Development Process

Work on this rule-amending project began in 2007 with the adoption of the District’s Ozone Plan. District staff began the rule dev elopment process with extensive research as a part of a feasibility study performed to determine if there was potential from this source category for achieving additional emission reductions.

After the completion of the f easibility study, staff continued to research the District’s permits database, industry standards, tech nological advancements and actions taken by other regulatory agencies regarding the technological and econom ic feasibility of amending rule standards to make them more stringent. District staff presented their research findings to stakeholders, indus try, ARB, and EPA during a public Scoping Meeting on June 24, 2010. During the Sc oping Meeting staff outlined the potential range of the rule project and requested comm ents, feedback, and cost information from all interested parties. It was during the public Scoping Meeting t hat staff explained to stakeholders that research was being conduct ed as to the feasibi lity of controlling SOx and that staff was considering the replacem ent of engines with electric motors where possible. Staff also explained the decisions as to why certain engine categories would not be amended during this rule -amending process; specifying that these decisions were based on research, the evaluation of the permits database, and conversations with industry.

District Staff crafted draft rule requirem ents based on the best available information after evaluating the comments received re garding the proposed rule concepts. The District then hosted a Public Workshop on September 9, 2010 to present and discuss

the draft amendments to the rule. The draft amendments to Rule 4702, as presented inSAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

3 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 September 2010, included requi rements that nearly all n on-agricultural operated (nonAO) spark ignited engines m eet a NOx concentration of 11 parts per million by volume on a dry basis (ppmvd) (at 15% oxygen (O 2 )). Draft VOC and CO limits were also considered to be proposed to be lowered. Knowing that the proposed rule requirements would potentially be costly to some facilit ies, the District included an annual fee option (similar to Rule 4320), and addi tional compliance options.

A socioeconomic focus group was also hel d during the first public workshop.

Stakeholders were solicited for more cost information and potential impacts to their operations in light of the draft amendments.

After the September Public Wo rkshop, District staff met seve ral times with stakeholders. District staff worked closely with stakeholde rs to refine the rule requirements and address the cost impacts to affected facilitie s and feasibility concer ns of implementing various control technologies. Due to the re maining issues, in December 2010, District staff provided an update to the District’s Governing Board (Boar d) on the status of this project with plans to bring forth a proposed rule for Boar d consideration in 2011.

The District hosted a technical discussion session in January 2011 with the District’s Citizens’ Advisory Committee of Industry (CA GI) to solicit further input on issues and

concerns from affected stakeholders. The comments received from the public, affected sources, interested parties, EPA, and ARB du ring the public workshop, stakeholder meetings, and technical session were used to develop the second draft amendments to the rule. The new amendments included prov isions for engines used on a limited basis, meaning they are only used during part of the year. A phased compliance schedule was developed to extend compliance deadlines for facilities with multiple engines to

lessen the financial burden on these facilities. In order to maximize NOx reductions, VOC and CO limits were changed back to current levels. Upon further reflection, the cyclically loaded and waste gas combustion engines were returned to current NOx

emission limits. The second dr aft of the rule was releas ed to the public for comment and the District conducted the final publ ic workshop June 22, 2011.

Staff continued to work diligently with the remaining affected stakeholders and EPA to draft the proposed rule. Compared to the June version of the draft rule, the proposed rule provides a requirement specific to lean burn engines used for gas compression. Additionally, the phased in compliance sched ule has been further extended for those operators with more than twelve engines at a stationary source. Section IV.B of this Final Draft Staff Report provides a deta iled discussion for each proposed amendment.

Pursuant to state law, the Dis trict performed a socioeconomic impact analysis. As part of the District socioeconomic analysis process, District staff solicited volunteers from affected stakeholders and interested parties to participate as members of the Socioeconomic Focus Group. District staff convened a meeti ng of the Focus Group in conjunction with the first workshop in Septem ber 2010 to assist District staff in gathering information on regulatory compliance cost s and business impacts resulting fromSAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

4 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 compliance with the draft amendments. The results of the socioeconomic analysis were published in a report and presented along with t he draft rule amendm ents to the public and interested parties during the June 2011 wo rkshop; at which time staff solicited

additional feedback from stakeholders.

The Proposed Rule and Final Draft Staff Re port were published and made available to affected sources and interested parties prior to a public hearing to consider the adoption of the rule by the District Governing B oard. The proposed am endments are scheduled to be presented to the Governing Board for t he public hearing to consider adoption of

the amendments to the rule on August 18, 2011.

II. GLOBAL CLIMATE CHANGE AND GREENHOUSE GASES

The California Global Warming Solutions Ac t of 2006 (AB 32) created a comprehensive, multi-year program to reduc e greenhouse gas (GHG) emissions in California, with the overall goal of restoring emi ssions to 1990 levels by the year 2020. In the coming years, ARB and the Legislature will be devel oping policies and programs to implement

AB 32. The District believes that the evi dence and the rationale that climate change is occurring is compelling and convincing. In addition to the long-term consequences of climate change, the District is concerned wit h the potential ramifications of more moderate but imminent changes in weather patte rns. The Valley depends heavily on agriculture for its economy and has develop ed agricultural practices based on the last several decades of weather patterns. Unant icipated and large fluctuations in these patterns could have a devastating e ffect on the Valley’s economy.

While there are many win-win strategies that can reduc e both GHG and criteria/toxic pollutant emissions, when faced with situati ons that involve tradeoffs between the two,

District staff believes that the more immedi ate public health concerns that may arise from an increase in criteria or toxic pollu tant emissions should take precedence. The San Joaquin Valley Air Pollution Control Dis trict’s Governing Board adopted the Climate Change Action Plan (CCAP) in August 2008. For California Environmental Quality Act (CEQA) requirements, one of the goals of the CCAP is to establish District processes for assessing the significance of greenhouse gas impacts. The District has developed a policy and guidance for addressing greenhouse gases under CEQA.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

5 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 III. BACKGROUND

An internal combustion engine is any engine t hat operates by burning its fuel inside the engine. Engines generate power by the combus tion of an air/fuel mixture. The main types of engines are spark-ignited engines and compression-ignited (or diesel) engines. In the case of spark-ignited engines, a spar k plug ignites the air/fuel mixture. Sparkignited engines come in several designs such as: two-stroke and four-stroke, rich-burn and lean-burn, turbocharged and naturally aspi rated. Spark-ignited engines may use one or more fuels, such as natural gas , propane, butane, liquefied petroleum gas, oil field gas, digester gas, landfill gas, methanol, ethanol, and gasoline.

Compression-ignited engines rely on heating of the inducted air during the compression stroke to ignite the injected diesel fuel. In addition to bei ng classified into compressionignited and spark-ignited, IC engines can be further divided into two-stroke and fourstroke engines. Most diesel engines are fou r-stroke, while larger diesel engines often are two-stroke. Natural gas fired spark-i gnited engines are usually four-stroke, but some operators prefer two-stroke engines for their applications.

Most engines are used for activities such as powering pumps, compressors, or electrical generators. Engines are used by a variet y of private businesses and public agencies throughout the Valley. Examples of busines ses and industries that use engines that could be affected by this project include schools and universities, agriculture, oil and gas production and pipelines, petroleum refi ning, manufacturing facilities, food processing, electrical power generation, landf ill and waste water treatment facilities, and water districts. Many of the permitted compression-ignit ed engines in the District are emergency standby engines that provide ba ckup power when electric service is interrupted.

IV. CURRENT RULE 4702 AND PROPOSED AMENDMENTS

A. Current Rule 4702

Rule 4702 (Internal Combustion Engines Phase 2) was adopted in August 2003 and was last amended in January 2007. The purpose of Rule 4702 is to limit NOx, CO, and VOC emissions from stationary engines. The ru le applies to any stationary engines with a rated brake horsepower (bhp) greater than 50. The rule requirements are organized into two engine categories: those used in agr icultural operations (AO) and those used in non-agricultural operations (non-AO). The existing NOx concentration limits in Rule 4702 range from 25 parts per million by volu me (ppmv) to 150 ppmv corrected to 15%

O 2 , depending on engine category. The VOC and CO concentration limits range from 250 to 750 ppmv (depending on engine categor y) and 2,000 ppmv, each corrected to

15% O 2 , respectively.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

6 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 B. Proposed Amendments to Rule 4702

In an effort to simplify rule language and clar ify existing requirements, expired language was removed, and some rule requirements we re reorganized to other sections of the rule. The following paragraphs detail the proposed modifications to rule language. See Proposed Rule 4702 for exact language.

1. Rule Title, Section 1.0 Pur pose and Section 2.0 Applicability

The title of the rule would be modified to remo ve the phrase “Phase 2”. This phrase is a holdover from past years and the phrase no l onger reflects the rule’s scope. The Purpose section of the rule would add SOx to the list of po llutants that are limited by rule requirements. In the Applicability section, the mi nimum brake horsepower (bhp) rating of engines subject to the rule would be amended from 50 bhp to 25 bhp.

2. Section 3.0 Definitions

The Definitions section would be updated by removing expired language, and some existing definitions would be upd ated for clarity. The definit ion for low-use engine would be re-located from Section 4.0 (Exemptions) to Section 3.0 (Definitions), with no change to the meaning of the definition.

The following definitions would be added to t he rule to improve clarity and reflect changes to rule requirements: Air Pollution Control Officer (APCO), ARB, California reformulated diesel, EPA, higher heating val ue, limited-use engine, and operator. Also, throughout the rule, the word “owner” would be replaced with the word “operator” to provide clarity as to who rule requirements ar e applicable to. It is important to note that this change does not change who the rule is applic able to, but is simply a clarification of existing rule requirements.

The June 22, 2011 version of the draft rule and draft staff report contained a draft definition of “existing cyclic field gas fuel ed engines.” This draft definition has been

removed from the rule because there is no NOx control technology that will allow newer cyclically-loaded engines to be controlled below their current emission level, even with the latest emission control technology.

3. Section 4.0 Exemption

Section 4.1 – Exemption From Rule Requirements Section 4.1 lists the engines that are exempt from rule requirements. Portable engines

will be moved from Section 4.3 to Secti on 4.1.6 and 4.1.7. This change removes record-keeping requirements from these engines.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

7 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 Additionally, District staff considered the District’s portable engi ne program. Engines registered in the District’s pr ogram keep records as a require ment of District Rule 2280 (Portable Engine Registration). These records are very similar to the records currently required in Rule 4702. The only difference is that Rule 4702 requires records that state the hours of operations whereas Rule 2280 records that show how much fuel was burned. There is a one-to-one relationship between the amount of fuel burned and the number of hours operated, so dropping the Rule 4702 records requirement will not

reduce the amount of operating information currently av ailable for these engines.

As originally posted in the July 19, 2011 vers ion of the Final Draft Staff Report for the Proposed Amendments to Rule 4702, t he language for portable engines could be construed that the engine be registered for both the state and Distr ict portable engine programs. The provis ion has since been rewritten to cl arify that if the engine is registered for either program, the engine is exempt from t he rule requirements, although the District-registered portabl e engines would still keep records in accordance with Rule

2280.

Section 4.2 – Exemption for Emergency Standby Engine or Low Use Engine The language in Section 4.2 would be amended to cons olidate requirements for emergency standby and low-use engines. T he language would be streamlined for reader clarity. No changes to the current requirements are proposed for this section.

Section 4.3 Exemption with Recordkeeping Requirements
Section 4.3.2 would be moved to Section 4.1.6 and 4.1.7 to reflect the removal of the record-keeping requirements. This change removes record-keeping requirements from these engines. The California Air Resource s Board (ARB) recently removed recordkeeping requirements from the statewide po rtable engine registration program. District staff reviewed ARB’s discussion and agreed wit h ARB’s assessment that the records

are unnecessary.

Section 4.4 – Exemption for BACT and Offset Requirements Section 4.4 allows an exempt ion from the requirements of Best Available Control Technology (BACT) and Offset requirement s of Rule 2201 (New and Modified Stationary Source Review Rule) if an existing facility is installing the replacement engine for the sole purpose of complying with Ru le 4702. Discussions between the District, EPA, and ARB continued after the July posti ng of the Proposed Amendments to Rule 4702 as to how to clarify this exemption in such a manner that does not violate Federal
or State laws and mandates. These discussi ons resulted in the revision of proposed amendments. These revisions are not a change in rule requirements, but a clarification of the existing exemption. Re vised Section 4.4 specifies that for existing facilities, a replacement unit installed for the sole purpo se of complying with the requirements of

Rule 4702 shall be considered to be an emissi on control technique and shall therefore,SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

8 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 be exempt from BACT and offsets requirements of District Rule 2201 provided that all other requirements of Ru le 2201 are met.

New Section 4.5 – Exemption for Stationary Engines Rated 25-50 bhp

New Section 4.5 would be added to rule language to help clarify that the new requirements for stationary engines rat ed between 25 and 50 bhp include the point of sale requirement and the one time reporti ng requirement only. No other rule requirements are applicable to these engines at this time. The addition of stationary engines rated between 25 and 50 bhp have been presented to stakeholders as a point of sale requirement, with a one-time repor ting requirement. Comments received from stakeholders pointed out that rule language could be misunder stood or misinterpreted; specifically, that t he Sections 5.9 and 6.2.3 would be ap plicable to these engines. It was never the District’s intention to require small engines to be subject to these two
Sections of the rule. Therefor e, to help clarify rule require ments, and District intentions regarding the addition of stationary engines rated between 25-50 bhp to rule language,
Section 4.5 would be added to rule language.

4. Section 5.0 Requirements

New Section 5.1 – IC Engines Rat ed Between 25 and 50 Brake Horsepower
New Section 5.1 would establish the r equirements for spar k-ignited engines and compression-ignited engines rated at 25 to 50 bhp that are used exclusively in non-AO. These small engines are already regulated under the existing federal Standards of Performance. The provision is a point of sale provision and prohibits a person from selling, or offering for sale, engines rat ed at 25 to 50 bhp unless the engines meet the requirements and emission limits specified in the Code of Federal Regulation Title 40 Part 60 (40 CFR 60) Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines ) and 40 CFR 60 Subpart JJJJ (Standards of Performance for Stationary Spark Ignition In ternal Combustion Engines) for the year that the engine is purchased. The provisi on is intended to ensure that more polluting engines are not sold to another person or ent ity if cleaner small engines that meet the

current NSPS standards are available in the market. District staff has removed the terms “solicit the operation, s upplying, and install” from this provision. Because this provision is a point of sale provision it does not affect the leasing of these engines because the ownership of the en gine would remain with the lessor until such time as the lessor chooses to sell the engine; at that time, this provision would apply.

This provision regulates engines by attrition ra ther than requiring the operator to install additional emission control system on exis ting engines as is the case for engines greater than 50 bhp. Over time, t he non-AO engines between 25 and 50 bhp will be replaced with the cleanest-burning engines av ailable and the replacement happens at a time of the operator’s choos ing, since the operator elec ts when to replace a given engine. If there is no cleaner engine availabl e, meaning that the f ederal emission limits haven’t changed since the engine was manuf actured, the engine can change hands andSAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

9 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 continue to operate within the Valley bec ause the engine is the cleanest version available. Conversely, if there is a cleaner federal emi ssion standard than the standard at the time the engine was m anufactured, rather than cont inuing to have the older, dirtier engine continuing to operate, but at a different Valley location, the District is proposing that the older engine be retired or re trofitted to meet the latest standard. The proposed requirement, as written, is a win-win situation for both oper ators and Valley air quality because it provides continuous ai r quality improvement through normal engine turnover as well as operator flexibility by allowing the operator, not the District, to determine when to replace an engine.

Additionally, the proposed rule amendments r equire the current owner of non-AO small engines operated in commercial, industrial, and institutional facilities to submit a onetime report to the District which includes in formation on the number of engines, location of each engine, engine manufacturer, m odel designation and engine serial number, engine bhp, fuel type and consumption rate, ignition type and combustion type, purpose of the engine, and daily operatin g schedule. The purpose of t he report is to allow the District to improve the emission inventory for this category. It is important to note that the District intends to use the existing emission inventory gat hering methodology to

obtain this information from stakeholders. This will minimize any impacts to the

facilities.

Section 5.2 – Engines Rated Gr eater than 50 Brake Horsepower Section 5.2 specifies emission limits/st andards for non-AO and AO spark-ignited engines and compression-ignited engines greater than 50 bhp.

1.) Section 5.2.1 – Existing Emission Concentration Limits Section 5.2.1 would be reorgani zed for purposes of clarificat ion and simplification of rule language. The existing emission limits for spark-ignited engines used in AO would be

relocated to Section 5.2.3 of the rule. T he existing non-AO limits will remain in effect

until new emission limits become effective.

2.) New Section 5.2.2 – Non- AO Spark-Ignited Engine Emission Concentration

Limits Section 5.2.2 would specify t he emission concentration limit s for non-AO spark-ignited engines greater than 50 bhp, effe ctive pursuant to the compliance schedule specified in Section 7.5. In the Septem ber 9, 2010 version of the dra ft rule amendments that were presented at the first public workshop, District staff propos ed 11 ppmv NOx limit for all engines in this category. However, after considering the comments and

recommendations from stakeholders and the Citizens Advisory Group of Industry (CAGI), District staff is propos ing the NOx emission limits t hat take into account the differences between engines used in different applications. Table 1 summarizes the proposed emission limit changes. The limits ar e in concentration units of parts per million by volume on a dry basis (ppm vd), corrected to 15% oxygen.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

10 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702

Table 1 – Current and Proposed NOx Limi ts (in ppmvd corrected to 15% oxygen) Engine Type Current Limit Proposed Limit Rich-Burn Engines A. Waste Gas Fueled Engine 50 50 B. Cyclic Loaded, Field Gas Fueled 50 50 C. Limited Use Engine ---- * 25 D. Rich-Burn Engine, not listed above 25 or

96% reduction 11

Lean-Burn Engines E. Two-Stroke, Gaseous Fueled, < 100 hp Engine 75 or

90% reduction 75

F. Limited Use Engine --- * 65 G. Lean-Burn Engi ne used for gas compression --- * 65 or 93% reduction

H. Lean-Burn Engine, not listed above 65 or

90% reduction 11



### * Limited-use engines and “lean-burn engines used for gas compression” are not categories in the current rule. They are currently subject to the applicable “not listed above” emission limits.

Due to the heat content variability of wast e gas, NOx control can be problematic for engines fired on waste gas, therefore, Distric t staff is proposing no amendments to the
NOx emission concentration limit for waste gas fueled engines.

Cyclic-loaded, field gas fueled engines can achi eve some level of control, but not the very stringent control that can be imposed on engines that operate in a narrow range of loads. The exhaust gas temperature of cyclic loaded engines varies as a function of the engine load. Catalyst chemistry depends on a minimum temperature to be effective. When the cyclic load engine is operating in an engine load range that the exhaust gas is in the catalyst’s effective range, the emi ssions are well-controlled, but as the engine cycles out of this range, NOx control is le ss. Eventually, the ex haust gas temperature can be too low for any effective control. Fo r this reason, District staff is proposing no amendments to the NOx limit for cyc lic loaded field-gas fueled engines.

Two-stroke, gaseous fueled engines between 50 hp and 100 hp would remain at the

current NOx emission level. There is no technology that will allow a lower NOx level.

The proposed amendments create a new cat egory of engines that operate less than 4,000 hours per year. This category was cr eated based on the cost effectiveness of installing additional catalyst for these engines compared to engines that have higher utilization. These engi nes will be designated as “limited-us e” engines. This is not to imply that the proposed amendments leave the engines as uncontrolled. The NOx

concentration limit for limited-use rich-bur n engines would be 25 ppmv NOx, which is

the current emission limit for rich-burn engines. The NOx emissions foregone resulting from not lowering the existing NOx limit of 25 ppmv to 11 ppmv for the limited use engines is about 0.004 tons/day as shown in A ppendix C of the Final Draft Staff Report.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

11 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 Based on the District Permit Services dat abase, there are no lean-burn engines currently operating less than 4,0 00 hours per year in the District. However, District staff is proposing to include this limited-use category of engines in order to provide operators with the option of limiting their engine usage so as not to retrofit with an expensive SCR system, in exchange for a reduction in t heir current emissions level.

Lean-burn engines used in gas compression w ould be another new category created by the proposed rule. In general, these engines operate over a wide range of loads. As noted in the EPA’s technical support doc ument (see Appendix F), these engines fluctuate over a broad range of conditions making SCR use problematic. For this reason, District staff proposes that the category of lean-burn engine used for gas compression be created with a NOx control as a percent reduction ov er the uncontrolled

emission factor. Based on a review of t he Permit-to-Operate for these engines, the majority of the operators choos e the percent reduction option rather than the 65 ppmvd

emission limit.

Although District staff is leaving certain types of engines at their current numeric emission limits, for most engi nes the proposed rule removes the percent reduction as an alternative limit. As currently enforced, the operators with the percent reduction are assuming that the input to t he control device is an uncontrolled engine. The percent reduction option when converted from pounds NOx per MMBtu to ppmvd at 15% oxygen is equal to or great er than the proposed numeric lim it, therefore, removing the percent reduction option will not increase emissions from the targeted engine.

3.) VOC and CO Emission Limits The September 2010 draft rule contained a CO limit of 500 ppm v and 30 ppmv VOC

limit. Stakeholders recommended leavin g the existing 2, 000 ppmv CO and 250/750 VOC limits in place. The Engine Manufac turers Association (EMA) commented that they do not believe reductions are achievab le in practice for all stationary engine systems particularly for existing engines u nder varied operating and field conditions. EMA stated that for spark- ignited engines, there is a known relationship between emissions of NOx, VOC, and CO , in that as the engine is adjusted to reduce NOx, the

VOC and CO emissions will increase. Effort s to adjust the engine to reduce VOC and

CO emissions would result in an increase in NOx emissions. District staff contacted
South Coast AQMD staff to determine if the current 30 ppmv VO C in South Coast AQMD’s Rule 1110.2 (Emissions from Gaseous - and Liquid-Fueled Engines) is being

achieved. District staff has found that there are several variances that have been approved by South Coast AQMD Hearing Board allowing a temporary regulatory relief from the 30 ppmv VOC limit until such time that an alter nate limit, which is an allowable provision of South Coast AQMD Rule 1110.2, c ould approved by their Executive Officer.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

12 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 Based on stakeholders’ recommendations and results of the South Coast AQMD variances, District staff believes that it is appropriate to not change the existing VOC limits in Rule 4702. Likewise, the current CO limit of 2,000 ppmv would not be changed. Keeping the existing VOC and CO emission limits in the curr ent rule would allow engine manufacturers and emission control system manufacturers to have the much-needed flexibility to be able to achieve much lowe r NOx emissions under varying field operating conditions and applications.

4.) Section 5.2.2.1 – Spark-Ignited Non- AO Engine Compliance Requirements New Section 5.2.2.1 specifie s requirements that non-AO engi nes shall comply with. This new section includes a requirement to comply with emission limits for NOx, CO, and VOC, as well as SOx control requirements and Mo nitoring requirements.

5.) Section 5.2.2.2 – Annual Fee Option Section 5.2.2.2 allows operat ors of non-AO spark-ignite d engines the option to pay annual fees in lieu of complyi ng with new NOx limits. The District would take the fees generated by the annual fee option to fund other emission-reduc ing projects that would get equivalent reductions. Operators would remain subject to current NOx, CO, and

VOC emission concentration limits. To further clarify, if an operator elects to use the fee payment option, the current em ission limits would remain in place for these engines. This provision prevents existing engines t hat are included in a fee payment program from increasing their emissions above the current emission limits. Including this provision fulfills an EPA requirement call ed “anti-backsliding,” meaning changes to a rule cannot allow operators to increase thei r emissions above whatever is currently in place. Previous draft versions of the rule intended for this provision to be in place but did not clarify that in the rule language. Amendments have been made to the language to clarify this requirement. Operators t hat choose the fee option would also remain subject to the new SOx contro l and monitoring requirements of sections 5.7 and 5.10.

6.) Section 5.2.2.3 – Spark-Ignited Non-OA Engines AECP Option This new Section 5.2.2.3 provides a prov ision for operators to participate in the alternative emission control plan pursuant to Section 8.0 in lieu of complying with the emission limits on an engine-by-engine basis. This provision provides operators another opportunity for flexibility in complyin g with rule requirements while still enabling the District to achieve it’s goals of reducing emissions in the Valley.

7.) New Section 5.2.3 - AO Spark-Ignited Engine Emission Limits Section 5.2.3 requirements were origina lly combined with the non-AO spark ignited engines in Section 5.1.1 of the previously ad opted version of this rule. For improved clarity of rule requirements, the AO engi ne emission limits have been moved to the new
Section 5.2.3. There ar e no proposed amendments to th e emission limits for AO engines for this rule-amending project. As published in the Federal Register, EPASAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

13 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 determined that the require ments of AO engines, as added to Rule 4702, to be, “consistent with EPA regulations, and re levant policy and guidance regarding enforceability, BACM/BACT, RACM /RACT, and SIP relaxations.” 1 Additionally, the Technical Support Document (TSD ) published in August 2007 for the Proposed Rulemaking and District Final Rule for the California SIP for Rule 4702 states “Submitted Rule 4702 continues to impl ement BACM/BACT and other SIP approval criteria for stationary inter nal combustion engines. In additi on, these revisions satisfy SJVAPCD’s commitment to apply BACT-leve l controls to agricultural engines,

consistent with its Amended 200 3 PM-10 Plan. Because the criteria for BACM/BACT are stricter than for RACT, by meeting BAC T requirements submitted Rule 4702 also
fulfills RACT.” 2

As illustrated by the dates of the EPA actions to approve the Rule 4702 as RACT, spark-ignited AO engines have only recently been required to comply with rule 4702 and are in the first generation of rule require ments. It is import ant to note that AO engines are currently in the mi ddle of the most recent co mpliance strategy and these engines are still in the process of comi ng into compliance with new standards with compliance dates ranging from Ja nuary 2009 through January 2015.

Additionally, as illustrated in Appendix D of Rule 4570 (Confined Animal Facilities), amended in October 2010, the agriculture community cannot absorb the costs of additional controls, nor can they pass t hose costs onto the consumer because the agricultural industry competes in a global economy where prices are not determined by the individual farmers. By comparison, non-AO engine emission limits were first adopted in 2003; meaning that operators with non-AO engine s have had an opportunity to get a return on their investment. Dis trict staff will re-evaluate potential emission reductions from AO engines as part of future plan control measures and rule projects.

8.) New Section 5.2.4 – AO and Non-AO Ce rtified Compression-Ignited Engine

Emission Limits The certified and non-certified compression i gnited engines are currently combined in the rule. District staff has separated the ce rtified and non-certified compression ignited engines to improve rule clarity. No changes are proposed for these engines.

The June 22, 2011 version of draft rule am endments to Rule 4702 did not have draft

amendments to Section 2.b of Table 4 – Emission Limits/Standards and Compliance Schedule for Compression-Ignited Internal Combustion Engines. However, the proposed amendments published on the Distr ict web page on July 19, 2011 amended

1 Revisions to the California State Implementation Pl an, San Joaquin Valley Air Pollution Control District and Sacramento Metropolitan Air Quality management District, 73 Fed. Reg. 7, pp. 1818 – 1822. (2008, January 10).

2 Technical Support Document for EPA’s Notice of Pr oposed Rulemaking and Direct Final Rule for the California State Implementation Plan San Joaquin Valley Unified Air Pollution Control District Rule 4702, Internal Combustion Engines – Phase 2. (August 2007).SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

14 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 Section 2.b of Table 4 to remove this requi rement from proposed rule requirements. This language was removed with the intent ion of clarifying rule requirements by simplifying rule language with the deletion of this section of the table. Upon further reflection, District staff feel that while deleting this language does not change rule requirements it could possibly confuse stak eholders; therefore, District staff have amended the proposed language to once again incl ude this section in Table 4. It is important to note that the act of not deleting this requirement does not change the intention or requirement s of rule language.

New Section 5.6 – Annual F ee Option and Calculations New Section 5.6 provides t he operator of a non-AO spark- ignited engine the option to pay an annual fee in lieu of complying with new NOx emission limits. This section

details the calculation of emi ssions and fees for this option. Section 5.6.1.3 contains the calculation for determining total emissions of the unit for determining the annual fee. The Proposed Rule contains an updated versi on of the equation from the draft version that was presented to the public during the pub lic workshop process. The intention of the updated equation was to simplif y and clarify these calculat ions. Staff has further reviewed this version of the equation and det ermined that it contained a mathematical error. Staff has since revised the equation to correct the error, this corrected version is in the Revised Proposed Rule. This change in equation is for the sole purpose of clarifying the calculation and ensuring accura cy when calculating the total emissions of the unit when determining the annual fee.

The fees continue to be based on the tota l annual NOx emissions for the unit. The District intends to use the fees collected by this program to acquire equivalent emission

reductions from other sources. Details of the program itself will be sent to EPA when the program is initiated. Cu rrently, the District does not ta ke State Implementation Plan (SIP) credit for emissions reductions ac hieved through fee payment programs and related monetary incentive programs. T he District has been colla borating with U.S. EPA and ARB to formalize a mechanism to pr ovide SIP credit for emissions reductions from such programs. Since th is work is still in progress, the District is not taking SIP

credit from the Rule 4702 f ee payment program at this time, but will continue to
collaborate with EPA to allow for SIP credit from this component of Rule 4702 in the

future.

Not taking SIP credit for NOx emission reductions does not affect either the Ozone Plan attainment strategy nor does it affect t he District’s 2008 PM2.5 attainment strategy because the control measure for amending Ru le 4702 did not include any specific

amount of emission reductions. The emission reduction analysis in Appendix B of this staff report is based on each engine complying with the ru le through the installation of NOx emission control technology. The Dis trict staff expects that the emission

reductions associated with t he fee payment option will be higher than by requiring

installation of individual control technology.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

15 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 New Section 5.7 – Sulfur Oxi de (SOx) Control Requirements

The rule would limit SOx emissions thr ough fuel choice. For non-AO engines, these fuels are widely available. Although the proposed sections limit the sulfur in the engine’s fuel, for SIP purposes, the District is not taking any credit for SOx emission

reductions associated with the rule modifi cations because it is expected that all operators are already compliant with the requirement. Alt hough SOx is a precursor to PM2.5, the control measure in the PM2.5 Plan did not co mmit the District to any SOx reduction; therefore, the atta inment date is not adversely affected by not taking SIP credit for the potential SO x emission reductions.

New Section 5.10 – SOx Emissi ons Monitoring Requirements New Section 5.10 outlines the necessary monitoring for operators selecting nonstandard fuels or elect to comply through a SOx emission control technology. Operators utilizing st andard fuels would have no monitori ng or testing requirements.

5. Section 6.0 Admini strative Requirements

Section 6.1 – Emission Control Plan Section 6.1 would be rewritten to clarify ex isting rule requirements regarding engines that are required to have emission contro l plans. This proposed amendment does not change the requirement or meaning of this se ction of the rule. Also, language would be added to this section that allows operators with no changes to their emission control plan to submit a letter stating that there are no changes rat her than having to submit the entire plan. District staff agreed with a stakeholder who stated that preparing an emission control plan is time-consuming an d is redundant if t he existing emission control plan is already adequate. The proposed change would st reamline compliance for certain operators of existing engines.

Existing Section 6.3 – Compliance Testing

Section 6.3.1 would be rewritten to clarif y existing rule requirements pertaining to compliance testing. This proposed amendm ent does not change t he requirement or meaning of this section of the rule.

Section 6.4 – Test Methods

1.) Section 6.4.7 – SOx Test Methods Section 6.4.6 would be added in order to spec ify the test methods for determining SOx, total sulfur as hydrogen sulfi de, sulfur content of liquid fu el, and calculation method for SOx control efficiency.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

16 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 2.) Section 6.4.7 – Higher Heating Value Test Methods Section 6.4.7 would be added to specify the allowable test methods for determining a fuel’s higher heating value. These te st methods were added to complement the addition of SOx requirements.

Section 6.5 – Inspection and Monitoring (I&M) Plan Section 6.5 would be rewritten to clarify rule requirements pertaining to the submission of I&M plans. This pro posed amendment does not change the requirement or meaning of this section of the rule. Also, l anguage would be added to this section to allow operators with no changes to the fa cility’s I&M Plan to submit a le tter to that effect rather than submitting a new plan. This provis ion affords operators a streamlined process when there are no changes to the facility’s current I&M Plan.

6. Section 7.0 – Compliance Schedule

District staff has reviewed the compliance schedules and, for the sake of clarity and simplification of rule language, expired language has been removed and the section has

been renumbered as appropriate.

New Section 7.5 – Non-AO Spark Ignited Engine This section provides the compliance schedu le for the operator of a non-AO sparkignited engine subject to the rule to comp ly with. The September 2010 version of the draft rule had a single compliance date. In response to stakeholder comments, the draft compliance date has been amended and now a phased-in compliance schedule is proposed. Additional discu ssions with stakeholders yielded a further refinement - operators with more engines have a longer period of time to come into compliance, starting in 2014 and ending in 2017. The l onger compliance schedule recognizes that operators with more engines might have some l ogistical issues in bringing so many engines into compliance in a short amount of time, while recognizing the District’s commitment to expedite air quality benefits as committed to by the Governing Board with the dual path strategy.

Table 2 below shows the proposed compliance sc hedule. It is important to note that the division of compliance date requirements in Tabl e 2 is specific to the amount of engines per stationary source and not to the amount of engines owned by an operator. For example, an operator that owns 12 engines with five engines at one facility and the other seven engines at another facility woul d not have the 2017 compliance timeline as allowed for operators with at least 12 engines at a stationar y source; because all the engines are not at one stationary s ource, rather than one location.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

17 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 Table 2 – Proposed Compliance Schedul e for Non-AO Spark Ignited Engines

Engines to be in Compliance at a Stationary Source Emission

Control Plan Authority to

Construct and Inspection and Monitoring Plan Full Compliance

Single Engine at a stationary

source 1/1/12 1/1/13 1/1/14

Operator with at least two engines, but le ss than 12 engines at a stationary source
33% or more of the engi nes 7/1/12 1/1/13 1/1/14 66% or more of the engi nes 7/1/12 1/1/14 1/1/15 100% of the engines 7/1/12 1/1/15 1/1/16 Operator with at least 12 en gines at a stationary source 25% or more of the engines 7/1/12 1/1/13 1/1/14 50% or more of the engi nes 7/1/12 1/1/14 1/1/15 75% or more of the engi nes 7/1/12 1/1/15 1/1/16 100% of the engines 7/1/12 1/1/16 1/1/17

New Section 7.6 – Annual Fee Payment Option The owner of a Non-AO spark-ignited engine who elects to pay annual NOx emission fees to the District in lieu of complying with the new NOx emission limits would be required to submit an Emission Control Plan which includes the information specified in new Section 7.6.1 by July 1, 2012. The owner would be required to pay the total annual

fee to the District no later than June 30 of each year for the NOx emissions of the previous calendar year. Payment would continue annually until t he engine either is permanently removed from use in the Valley and the Permit-to-Opera te is surrendered, or the operator demonstrates compliance wi th the proposed rule’s Table 2 emission

limits.

C. Implications of the Federal Stati onary Reciprocating Internal Combustion Engine (RICE) Requirements

Although the District has some of the most st ringent rules in the nation, the federal EPA

also creates rules to limit emissions. One such rule that affects stationary internal combustion engines is 40 CFR 63 Subpart ZZZZ (National Emissions Standards for

Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines).

Also called a Maximum Achievable Control Techniques (MACT), the MACT divides the engines into several groups and has different pr ovisions for the different engine groups depending on whether the facility where the engine is located is a major or area Hazardous Air Pollutants (HAPs) source, spar k-ignited or compression-ignited, rich-burn or lean-burn, etc. For so me engines, the MACT requires periodic maintenance only. For other engines, there are specific emissi on limits, source testing, and monitoring requirements. There are eit her CO or formaldehyde emission limits for certain larger spark-ignited engines. It is these engines that are of interest for this rule project.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

18 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 There are some engines that are in complianc e with the MACT’s low emission limits for CO/formaldehyde without an add-on control system . An existing engine that does not

meet the emission limits would need to be m odified, which usually means installing an emission control system contai ning an oxidation catalyst. The installation of the oxidation catalyst would be in addition to any equipment necessary to meet the Revised Proposed Rule 4702’s pr oposed NOx limit.

In addition to the potential to have a two- catalyst emission control system, the MACT compliance schedule is a little ahead of schedule for Revised Proposed Rule 4702. All spark-ignited engines at area HAPs sources that are subject to the RICE engine MACT must be in full compliance wit h standards by May 2013. As noted earlier, some engines are already in compliance wit h the MACT’s CO/formaldehyde limits and no retrofit would be required to meet the MACT standard. The compliance schedule for Revised Proposed Rule 4702 is tiered, meaning tha t, for operators with multiple engines, compliance deadlines are phased in over three or four years beginning in 2014. In a worst case scenario, operators could make m odifications to meet the RICE engine MACT in 2013, and then need to make more modifications in 2014. District staff believes that by making operators aware of the changes in the District’s rule soon enough would allow the operators to combine MACT and District rule retrofits to

minimize downtime and costs.

Stakeholders contacted about how they we re going to meet the RICE engine MACT stated that they were early in their assessment process and hadn’t fully determined their course of action. In general, operators are concerned about the engineering design challenges as well as the operat ional complexity inherent in a two-catalyst emission control system.

V. EMISSION REDUCTION ANALYSIS

District staff queried the District Permit Se rvices Database for all engines, and then manually sorted the engines into one of th ree categories: emergency standby, richburn, and lean-burn. No analysis was done for emergency standby engines because the proposed rule amendments do not affect this type of engine. Of the remaining engines, District staff determined that out of 326 rich-burn engines, only 160 engines would be required to reduce t heir NOx emissions. For lean- burn engines, District staff found a total of 97 lean-burn engines, of wh ich 62 have permit limits higher than the proposed rule limits. Based on the assumptions used, District staff estimates that the proposed changes in the rule limits for non- AO spark-ignited engines would lead to approximately 1.4 tons per day of NOx emission r eductions.

Currently, the District does not take St ate Implementation Plan (SIP) credit for emissions reductions achieved through fee payment programs and related monetary incentive programs; even though such innovativ e programs will be critical in helping the Valley meet both current and future air quality standards. The District has beenSAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

19 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 collaborating with U.S. EPA and ARB to formaliz e a mechanism to provide SIP credit for

emissions reductions from such programs. Since this work is still in progress, the District is not taking SIP credit from the Rule 4702 fee payment program at this time, but

will continue to collaborate with EPA to allow for SIP credit from this component of Rule

4702 in the future

It is the District’s experience that, when an emission limit is reduced, a small percentage of operators will choose to replace their IC engines with electric motors rather than

retrofit with an emission cont rol system. Based on past experience with engine rule amendments, some of the 222 affected engines r eplaced by electric motors. It would be speculative, to determine which engines w ould electrified, t herefore the following emission reduction analysis does not include an estimate for NOx reductions associated

with electrification scenarios. All affect ed engines are analyzed as if they will add NOx controls rather than replace t he engine with an electric motor.

District staff will not claim emission reducti ons for State Implementation Plan (SIP) purposes as part of this rule project. Howeve r, District staff will use the 1.4 tons per day
of NOx reductions in order to estimate co st effectiveness. A summary of the analysis

results is shown in Table 3 and details of the calculations are in Appendix B of this staff
report.

Table 3 – Summary of Estimated NOx Re ductions Used for Cost Effectiveness

Calculations

Engine Type Total

Permitted

Engines Number

Affected Engines Total Rated

Power (bhp) Estimated

NOx

Reductions (tpy) Estimated

NOx

Reductions (tpd)

Rich-Burn 326 160 80,738 131.5 0.36 Lean-Burn 97 62 123,886 390.9 1.07 Total 423 222 204,624 522.4 1.43

VI. COST EFFECTIVENESS ANALYSIS

Proposed Rule 4702 woul d implement low NOx limits for non-AO spark-ignited engines. These engines burn natural gas, gas from waste products or fiel d gas. It is the District’s experience that, when an emission limit is reduced, a small perce ntage of operators will choose to replace their IC engines with elec tric motors rather than retrofit with an emission control system. Based on this pas t experience, there would be at least several engines replaced by electric motors. It would be speculative to determine which engines would electrified, therefore the following compliance costs and cost effectiveness analysis do not include any cost-of-electrification scenarios.

The estimated total annual cost to retrof it 222 engines is a range between $12.3 million and $27.1 million annually. This range in total annual cost illustrates the variability inSAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

20 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 facilities, engines, and changes that would need to be made in order to comply with proposed limits. It is import ant to note that District staf f understand that each facility is unique and as such, faces unique chal lenges when making changes to engines, operations, and even changes in building stru ctures, in order to comply with new requirements.

Absolute cost effectiveness is the estimat ed total annual cost divided by the estimated

emission reductions. Table 4 shows the cost s and the results of the cost effectiveness analysis for engines greater than 50 bhp. Dis trict staff estimates that operators will need to retrofit a total of 222 engines at an annual cost between $12.3 million and $27.1 million. For rich-burn engines, the estima ted cost effectiveness is $29,600 per ton NOx removed. For lean-burn engines, the absolute co st effectiveness for th is rule project is between $21,600 and $59,300. Taking the rule amendment s as a whole, the cost effectiveness is between $23,600 and $51,800 per ton NOx removed. If all operators choose the fee payment option, cost effe ctiveness for all engines is $17,500 per ton NOx removed. Table 4 summarizes the compliance costs and cost effectiveness for both the situation where all operators elect to retro fit engines to meet the NOx emission

limits and the situation where all of the operators elect fee pay ment in lieu of compliance.

Table 4 – Summary of Compliance Costs a nd Cost Effectiveness to Retrofit All Engines All Operators Retrofit Their Engines

Rich-Burn Lean-Burn Overall Number Affected Engines 160 62 222 Total Cost ($/yr) a lower cost higher cost --- $3,900,000 $8,400,000 - $23,200,000 $12,300,000 - $27,100,000

Cost Effectiveness b ($/ton NOx)
--- $29,600 $21,600 - $59,300 $23,600 - $51,800 All Operators Elect Alte rnative Compliance Fee

Rich-Burn Lean-Burn Overall

Number Affected Engines 160 62 222
Total Cost ($/yr) a $1,700,000 $7,500,000 $9,100,000

Cost Effectiveness b ($/ton NOx) $12,600 $19,100 $17,500

a Rounded to nearest $100,000; Total may be off due to rounding

b Rounded to nearest $100

The incremental cost effectiveness is the di fference in cost between successively more effective controls. For engines operati ng at least 6,750 hours annually, the NOx

emission concentration limits ar e the most stringent availabl e. For this reason, no incremental cost effectiveness analysis can be done because there is no more stringent option available for these engines.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

21 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 The incremental cost effectiveness fo r requiring engines operating less than 4,000 hours per year to retrofit to meet a lower NOx limit was ev aluated. Incremental cost effectiveness cannot be directly compared to t he absolute cost effectiveness, but allows comparison between successively more stringent compliance options. In this case, the incremental cost effectiveness analysis fo cuses on limited-use engines and evaluates the difference between keeping the current NOx emission limit and requiring a lower NOx limit for these engines. The incremental cost effectiveness for limited-use engines is about $183,800 per ton addi tional NOx removed.

Details of the compliance costs and the co st effectiveness analysis are contained in Appendix C of this staff report.

VII. SOCIOECONOMIC IMPACT ANALYSIS

Pursuant to California Health and Safe ty Code (CH&SC) 40728.5(a), “Whenever a district intends to propose the adoption, am endment, or repeal of a rule or regulation that will significantly affect air quality or em issions limitations, that agency shall, to the extent data are available, perform an assessm ent of the socioeconom ic impacts of the adoption, amendment, or repeal of the rule or regulation.” As part of the District’s socioeconomic analysis process, a meeting of operators and other interested parties was convened in September 2010 to discuss compliance costs and possible business responses to the proposed amendments. Using information gathered during Focus Group meeting and public comment period, a draft of the so cioeconomic impact analysis report was presented during the June 2011 workshop for the rule. The socioeconomic impact analysis was perform ed by Applied Development Economics, Inc. (ADE) and is included with the Final Draft Staff Report as Appendix D. The rule affects both private sector businesses and public agencies like water districts and cities or counties. For the privat e sector industries as a gr oup (25 businesses), the costs have been evaluated in relation to financial operat ing ratios and fall below the level of significance for socioeconomic impacts. As such, it is anticipated that the industries can absorb these costs or pass a portion of the costs on to their customers without significantly affecting the businesses’ viabilit y. Four of the affected businesses meet the

criteria as small businesses in the State of California. These businesses have been evaluated separately but the proposed fee leve ls are low enough to avoid as significant socioeconomic impact for these businesses as well.

For the public water and wastewater agencies, the fees range from 0.3 percent up to 1.1 percent of agency operating re venues. In the short term, it is likely these fees could be absorbed by the agencies, but would be included in future rate increases, some of which may need voter approval.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

22 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 The impact analysis report includes an eval uation of the economic impact on affected small businesses and compares it to the impact to affected businesses overall. Of the 25 entities across the various pr ivate sector industries, thr ee are small businesses. The

estimated fees for each of these businesses were evaluated separately and the ratio of costs to net profits does not exceed the th reshold of significanc e. The affected small businesses are not disproportionately affe cted by the proposed rule amendments.

VIII. ENVIRONMENTAL IMPACT ASSESSMENT

Pursuant to the California Envi ronmental Quality Act (CEQA), District staff has reviewed the project for potential environmental impac ts resulting from implementation of the revised proposed amendments to Rule 4702 (Internal Combustion Engines).

Implementation of this project is expected to result in NOx emissi on reductions of about 522.4 tons/year (1.43 tons/day) as evaluat ed in Appendix B. Thus, the District has determined that implementati on of the proposed amendments to Rule 4702 would result in a positive impact on air quality.

In addition, the District also assessed potential changes in greenhouse gas (GHG)

emissions which would occur as a resu lt of implementation of the proposed

amendments. It was assumed that rich burn engines affected by this rule amendment already are equipped with non-selective cataly tic reduction systems (NSCR). As such,

there will be no GHG increase attr ibuted to the rich-burn engine category at this time because there is no change to the control technology.

For purposes of assessing greenhouse gas impacts, District staff assumes that operators of the lean-burn engines affected by the proposed rule amendments do not currently have SCR units, but w ill install SCR units as the control technology of choice

in order to meet the rule’s st ringent NOx emi ssion limits.

 SCR control technology can reduce the fuel efficiency of an engine by as much as 5%, meaning that 5% more fuel must be burned in order to have the same power output.

 Utilizing 5% as a conservatively high assumption for an engine's power penalty due to the use of an SCR system, and conservative ly applying that power loss to the total rated horsepower of all engines affected by the rule changes (a total of 123,886 bhp), there is an equivalent 6,194 bhp increase required to maintain current power

levels.

 Using a conversion factor to convert the additional 6,194 hp to carbon dioxide equivalents (metric ton CO2-e), it is estimat ed that the installati on of 62 SCR units will increase GHG emissions by 15,200 metric ton-CO2e/year.

 Compared to the installation of a SCR control system, elec trification (i.e., replacing a fossil fuel burning engine with an electric motor) as a method of compliance has the potential to offset any increases in GHG emissions. The District identified theSAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

23 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 number of engines subject to Rule 4702 that would need to electrify in order to offset the potential increas e in GHG emissions. The assessment demonstrated electrification of two to three engine s would reduce the net increase in GHG emissions. See Appendix B for mo re details on the calculations.

 Based on prior rule projects, electrificat ion of two to three engines is a plausible compliance response to the rule requirement s, thereby offsetting the increased GHG

emissions from the SCR.

Taking the above analysis as a w hole, District staff concludes that implementation of the proposed revisions would have a less than cu mulative significant impact on global climate change.

District staff concludes that there is no subs tantial evidence in th e whole record before the District that the revised proposed am endments to Rule 47 02 would cause any

adverse effects on the environment. Pursuant to CEQA Guidelines §15063 (a), District staff has prepared an Initial Study and Negat ive Declaration for the project. Upon approval of the propos ed amendments by the District’s Go verning Board, District staff

will file a Notice of Dete rmination with each County Clerk within the boundaries of the District, CEQA Guidelines § 15075(d).

IX. RULE CONSISTENCY ANALYSIS

Pursuant to CH&SC Section 40727.2, staff has prepared a rule consistency analysis that compares the elements of Rule 4702 with the corresponding elements of other District rules and federal regulations and guidel ines that apply to the same type of equipment or source category. The analysis is discussed in Appendix E of this staff report. District staff has conc luded that Proposed Rule 4702 is not in conflict with nor

inconsistent with other District rules nor is Proposed Rule 4702 in conflict with nor inconsistent with federal policy, rules, or regulations governing the same source category.

X. OTHER ANALYSES

A. Reasonably Available Contro l Technology (RACT) Analysis

Sections 182(b)(2) and 182(f) of the feder al Clean Air Act require ozone nonattainment areas to implement RACT for sources that ar e subject to Control Techniques Guidelines (CTG) documents issued by EPA and for “major sources” of VOCs and NOx, which are ozone precursors. RACT can be defined as dev ices, systems, process modifications, or other apparatus or techniques that are r easonably available, taking into account the necessity of imposing such controls in order to attain and maintain a national ambient air quality standard (NAAQS); the social, env ironmental, and economic impact of suchSAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

24 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 controls; and alternative means of providing for attainment and maintenance of such a standard. These control techniques, which are defined in EPA guidelines for limiting emissions from existing sources in nona ttainment areas, are adopted and implemented for nonattainment areas by state analysis. The following paragraphs evaluate the requirements of Proposed Rule 4702 in light of the RACT definition outlined previously.

In August 2007, EPA published the Technical Support Document (TSD) 3 for the current version of Rule 4702 in conjunction with EPA’s full approval of the rule for inclusion into the State Implementation Pl an (SIP). As published in the Federal Register, EPA determined that the require ments of AO engines, as added to Rule 4702, to be, “consistent with EPA regulations, and re levant policy and guidance regarding enforceability, BACM/BACT, RACM /RACT, and SIP relaxations.” 4 Additionally, the TSD published in August 2007 for the Proposed Rulemaking and District Final Rule for the

California SIP for Rule 4702 states “Submitted Ru le 4702 continues to implement BACM/BACT and other SIP approval criteria for stationary internal combustion engines. In addition, these revisions satisfy SJVAPCD’s commitment to apply BACT-level controls to agricultural engines, cons istent with its Amended 2003 PM-10 Plan.
Because the criteria for BACM/BACT are st ricter than for RACT, by meeting BACT requirements submitted Rule 4702 also fulfill s RACT.” Since the full approval of the current version of Rule 4702 by EPA, emis sions control technology for stationary internal combustion engines has not changed significantly, and the proposed amendments to Rule 4702 to make existing em issions limitations more stringent clearly
exceed RACT.

1. Emergency Engines and Low-Use Engines

District staff is not proposing any changes to the exemption requi rements for emergency standby engines and low-use engines. The exis ting requirements are consistent with ARB RACT/BARCT Determination for Spark- Ignited Engines and ARB Airborne Toxics Control Measures (ATCM). In addition, the ATCM is already being implemented through the District’s process for issuing Pe rmits to Operate. The exemptions as outlined in the current rule represent RACT for these sources.

2. AO Spark-Ignited Engines

There are no proposed amendments to the existing emission limi ts for AO spark-ignited engines because AO engines have only recent ly been required to comply with rule 4702 and are in the first generation of rule require ments. It is import ant to note that AO

3 Technical Support Document for EPA’s Notice of Pr oposed Rulemaking and Direct Final Rule for the California State Implementation Plan – San Joaquin Valle y Unified Air Pollution Control District Rule 4702 (Internal Combustion Engine – Phase 2), August 2007.

4 Revisions to the California State Implementation Pl an, San Joaquin Valley Air Pollution Control District and Sacramento Metropolitan Air Quality management District, 73 Fed. Reg. 7, pp. 1818 – 1822. (2008, January 10).SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

25 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 engines are currently in the mi ddle of the most recent co mpliance strategy and these engines are still in the process of coming into compliance with new standards.

As stated earlier, in August 2007, EPA published the TSD 5 for the current version of Rule 4702 in conjunction with EPA’s full approval of the rule for inclusion into the SIP. As published in the Federal Register, EPA determined that the requirements of AO engines, as added to Rule 4702, to be, “c onsistent with EPA regulations, and relevant policy and guidance regarding enforceabi lity, BACM/BACT, RACM/RACT, and SIP

relaxations.” 6 Additionally, the TSD published in August 2007 for the Proposed Rulemaking and District Final Rule for the California SIP for Rule 4702 states “Submitted Rule 4702 continues to impl ement BACM/BACT and other SIP approval criteria for stationary inter nal combustion engines. In additi on, these revisions satisfy SJVAPCD’s commitment to apply BACT-leve l controls to agricultural engines,

consistent with its Amended 200 3 PM-10 Plan. Because the criteria for BACM/BACT are stricter than for RACT, by meeting BAC T requirements submitted Rule 4702 also
fulfills RACT.” 7

As previously stated, owners of AO engines have just recently installed emission control systems to meet the current emission limits effective January 2009. The control systems included a 3-way catalytic converter, air/fuel ratio controller, and oxygen sensor. The District is still evaluating t he effectiveness and implementation issues associated with this type of control system , which have faced challenges due to the nature of agricultural engine in stallations, including remote locations, fluctuations in gas pressures, and unattended operations, which make it more difficult to constantly monitor the emissions level during day-to-day operat ion of the engines. The District will be evaluating the long-term effectiveness of the cu rrently installed emission control system for possible future rule am endments on AO engines.

As determined by EPA in 2007, District staf f believes that the existing Rule 4702 emission limits for agricultural engines meets RACT.

3. Compression Ignited Engines (AO and non-AO)

The existing emission limits for compre ssion-ignited engines apply to both nonagricultural and agricultural engines. It should be noted that certified Tier 1 or Tier 2 diesel engines are required to comply with EPA certified Tier 4 by January 1, 2015 or 12

5 Technical Support Document for EPA’s Notice of Pr oposed Rulemaking and Direct Final Rule for the California State Implementation Plan – San Joaquin Valle y Unified Air Pollution Control District Rule 4702 (Internal Combustion Engine – Phase 2), August 2007.

6 Revisions to the California State Implementation Pl an, San Joaquin Valley Air Pollution Control District and Sacramento Metropolitan Air Quality management District, 73 Fed. Reg. 7, pp. 1818 – 1822. (2008, January 10).

7 Technical Support Document for EPA’s Notice of Pr oposed Rulemaking and Direct Final Rule for the California State Implementation Plan San Joaquin Valley Unified Air Pollution Control District Rule 4702, Internal Combustion Engines – Phase 2. (August 2007).SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

26 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 years after installation date, whichever is la ter. Non-certified diesel engines that are required to meet either Tier 3 or Tier 4 depending on the engine size and its operating hours have just began complying with the existi ng emission limits early this year, and some of the larger engines will need to comp ly by mid-2011. Engines greater than 500 hp that operate at least 1,000 hours annually were required to meet 80 ppmv NOx last January 1, 2008 or by January 1, 2010, if the owner has an agreement to replace the diesel engine with electric motor. As deter mined by EPA in 2007, District staff believes that the existing Rule 4702 emission limits for agricultural engines meets RACT.

4. Limited-Use Non-AO Spark Ignited Engines (Rich-Burn and Lean-Burn)

District staff evaluated stationary engines that operate less than 4,000 hours annually and compared the cost effectiveness for t he limited-use engines and full-time use engines. Since limited-use engines have fe wer emissions on an annual basis, the cost effectiveness for a limited-use engine is higher than for a full-time engine. For this reason, the proposed rule includes a separ ate category for limited-use engines that keeps the current emission limit, which, as discussed earlier, meets RACT.

5. Waste Gas Fueled Non-AO Sp ark Ignited Rich-Burn Engines

The current NOx limit in Rule 4702 for non-AO waste gas fueled rich-burn engines is 50 ppmv (at 15% O 2 ) or 90 percent reduction. Although SCAQMD Ru le 1110.2 specifies a NOx limit of 11 ppmv for landfill gas or digester gas fired engines effective July 1, 2012, Rule 1110.2 includes a provision to comp lete a technology assessment by July 2010 and that the limit will only be implemented if the result of SCAQMD’s technology assessment that is confirms that 11 ppmv is indeed achievable. In a recent telephone conversation with South Coast AQMD staff, District staff has found that the technology assessment would not be completed until next year. Therefore, Dis trict staff is not proposing any change to the current limit for non-AO wa ste gas fueled rich-burn engines until such time that South Coast AQ MD’s technology assessment confirms that it is technologically and economic ally feasible to achieve the rule limit. As determined by EPA in 2007, District staff believes that the existing Rule 4702 emission limits for waste gas-fueled non-AO spark-igni ted rich-burn engines meets RACT.

6. Cyclic Loaded Field Gas Fueled N on-AO Spark Ignited Rich-Bun Engines

As noted earlier in this report, cyclic-loaded, field gas fueled engines can achieve some level of control, but not the very stringent control that can be imposed on engines that operate in a narrow range of loads. T he exhaust gas temperature of cyclic loaded engines varies as a function of the engine load. Catalyst chemistry depends on a minimum temperature to be effective. When the cyclic load engine is operating in an engine load range that the exhaust gas is in the catalyst’s effectiv e range, the emissions are well-controlled, but as the engine cycles out of the “sweet spot,” NOx control is less.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

27 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 Eventually, the exhaust gas tem perature can be too low for any effective control. For this reason, District staff believes that the current emission limit fulfills RACT. . As determined by EPA in 2007, District staff believe s that the existing Rule 4702 emission limits for cyclic-loaded field gas-fueled non-AO spark-ignited rich -burn engines meets
RACT.

7. 2-Stroke Engines Less than 100 hp Non-AO Spark Ignited Lean-Burn Engines

There is no technology for these engines that will allow a lower NOx level. District staff

believes that the current emission limit fo r 2-stroke engines less than 100 hp fulfills

RACT.

8. Lean-Burn Engine Used For Gas Compression

Most large natural gas-fired lean-burn IC engines in the region are in natural gas distribution and storage service and these engines experience frequently changing load

conditions. In the technical support document for the EPA’s 2003 NOx SIP call, the

EPA stated that there is an insufficient basis currently to conclude that SCR is an appropriate technology for the large lean-burn engines used for gas compression. The proposed emission limit is achievable throug h low-NOx combustion technology, which includes changes to the engine’s timing, enh anced control of the air-fuel ratio and other changes that lower NOx emissions. For this reason, and given the prior approval of the existing emissions limitation as RACT for this category, District staff believes that the proposed emission limit for these engines fulf ills RACT for this source category.

9. Non-AO Spark Ignited Engines, No t Listed (Rich-Burn and Lean-Burn)

The proposed emission limit of 11 ppmvd fo r non-AO spark ignited engines is more stringent than RACT since the engines in question would be required to install

advanced add-on controls in order to meet the proposed limi t. The proposed emission limit goes beyond RACT for this source category.

10. Consideration for Prohibitory Rules in Other California Air Districts: South Coast AQMD Rule 1110.2 (Emissions from Gaseous - and Liquid-Fueled Engines)

In considering what benchmarks to use for RACT, it is important to evaluate other emission limits that have been imposed on the same source category. District staff reviewed South Coast AQMD Rule 1110.2, whic h covers the same source category as
District Rule 4702. South Coast AQMD Rule 1110.2 has stringent NOx, CO, and VOC emission limits for internal combustion engines.SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

28 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 While on the surface it would appear that the South Coast AQ MD rule is more stringent, the medium and large operators in the South Coast Air Basin are most likely part of the South Coast RECLAIM program and therefore, not meeting the emission limits outlined
in the South Coast AQMD rule. All facilities that emit more than a certain amount of pollution are required to be in the RECLAI M program. Certain companies receive emission allocations every year. Each alloca tion is good for 12 mont hs. The portion of the allocation not needed to offset the operator ’s own emissions can be sold to other companies. If the operator does not receive an emission allocation, they must buy emission credits from operator s with unused emission allocations. In this way, the RECLAIM program is similar to a cap-and-trade program. At th is time, the District is not planning a RECLAIM-type program for this source categor y. Instead, a fee payment program in lieu of complying wit h the very stringent NOx limits is proposed. District staff

believes that the current rule limits fulfill RA CT, as evidenced by the recent approval of the current version of Rule 4702 by EPA. The proposed limits are beyond RACT and

fulfill the state mandate for all feasible measures.

11. Conclusion

Since the previous rule was determined to meet RACT and this amendment further strengthens the rule requirements, this rule is expected to establish requirements well beyond RACT, and thus satisfies RACT.

B. Consideration for the C ondensable Fraction of PM2.5

Certain high-temperature processes emit gas eous pollutants that rapidly condense into particle form in the ambient air. After Januar y 1, 2011, areas that are nonattainment for
the National Ambient Air Q uality Standard (NAAQS) for PM 2.5 are to consider the condensable fraction of directly emitted PM2.5 for purposes of establishing the

emissions limits for:

 Reasonable Further Progress (RFP), in which an area shows continuous reductions of directly emitted PM2.5 and precursors, with sufficient emissions

reductions to demonstrate attain ment by the applicable deadline

 Reasonably Available Control Technol ogy (RACT) and Reasonably Available Control Measures (RACM), in which a nonattainment area shows that it is adopting technologies and measures reasonabl y available, considering technical and economic feasibility; su fficient to demonstrate expeditious attainment; and meet RFP. (Code of Federal Regulations Ti tle 40 Section 51.1002(c))SAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

29 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 The District established emi ssions limits for its attainment, RFP, and RACT/RACM

demonstrations in the PM2.5 Plan for the PM2.5 NAAQS as set by EPA in 1997. The District continues to evaluate condensable pa rticulates and other di rectly emitted PM2.5 to improve its PM2.5 emissions inventory for future atta inment plan efforts.

Specific emission reduction targets for Rule 4702 were neither included in, nor does this action impede, the emissions limits set in the PM2.5 Plan. The District is not currently aware of significant uncontrolled condensable PM2.5 emissions or related condensable PM2.5 emissions control technologies for th e sources affected by this amendment. Therefore, the District has sa tisfied any applicable requirement to consider condensable particulates from this source at this time.

XI. REFERENCES

1. California Air Resources Board: De termination of Reasonably Available Control Technology and Best Availabl e Retrofit Control Technology for Stationary SparkIgnited Internal Combustion Engines. November 2001.

2. South Coast Air Quality Management Dis trict: Rule 1110.2 (Emissions from Gaseous- and Liquid- Fueled Engi nes). February 1, 2008.

3. South Coast Air Quality Management Dis trict: Final Staff Report for Proposed Amended District Rule 1110.2 (Emissions from Gaseous- and Liquid- Fueled Engines). December 2007.

4. U.S. Environmental Protec tion Agency: Alternative Control Techniques Document –

NOx emissions from Stationar y Reciprocating Internal Combustion Engines. EPA453/R-93-032. July 1993.

5. U.S. Environmental Protec tion Agency: Code of Federal Regulation Title 40 Part 51 Subpart U (Economic Incentive Programs)

6. U.S. Environmental Prot ection Agency: Code of Federal Regulations Title 40 Section 51 Subpart Z (Provisions for Implem entation of PM2.5 National Ambient Air Quality Standards).

7. U.S. Environmental Pr otection Agency: Revisions to the California State Implementation Plan, San Joaquin Valle y Air Pollution Control District and Sacramento Metropolitan Air Q uality management District, 73 Fed. Reg. 7, pp. 1818 – 1822. January 10, 2008.

8. U.S. Environmental Protection Agency: Technical Support Document for EPA’s Notice of Proposed Rulemaking and Direct Final Rule for the California StateSAN JOAQUIN VALLEY UNITIFED AIR POLLUTION CONTROL DISTRICT

Final Staff Report: Rule 4702 (Internal Combustion Engines) August 18, 2011

30 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 Implementation Plan – San Joaq uin Valley Unified Air Poll ution Control District Rule 4702 (Internal Combustion Engine – Phase 2). August 2007.

9. U.S. Environmental Pr otection Agency: Stationar y Reciprocating Internal Combustion Engines Technical Support Do cument for NOx SI P Call. October 2003