United States Environmental Protection Agency, Regi on 9

Air Division

Technical Support Document

for

EPA’s Notice of Rulemaking

for the

California State Implementation Plan

Santa Barbara County Air Pollution Control District ’s

Rule 333, Control of Emissions from Reciprocating I nternal Combustion Engines

Prepared by: Idalia Pérez

April 2010Santa Barbara County Air Pollution Control District (SBCAPCD)

Submitted Rule SBCAPCD Rule 333, Control of Emissions from Recipro cating Internal Combustion Engines

 Adopted: June 19, 2008

 Submitted: October 20, 2008

 Completeness determination: November 18, 2008.

Previous Rule Submittals The District submitted a previous version of this r ule on June 19, 1992 and we proposed a limited approval, limited disapproval (60 FR 6049) but did not finalize the action. The District

then submitted another version of this rule on Marc h 10, 1998 and later withdrew the submittal on January 18, 2000.

SIP-Approved Rule There is no SIP-approved version of Rule 333.

Rule Summary SBCAPCD Rule 333 regulates emissions of nitrogen ox ides (NOx), reactive organic compounds (ROC) and carbon monoxide (CO) from internal combus tion (IC) engines with a rated brake horse power of 50 or greater.

Section B of Rule 333 indicates the engine categori es that are exempt from the Rule.

Section C of the Rule contains definitions of relev ant terms.

Section D contains requirements for engine identifi cation and monitoring.

Section E contains the Emission Limits in the Rule. Engine Type NOx ROC (ppmv) CO

(ppmv) (ppmv) or (% reduction) Rich-Burn Noncyclically-loaded spark ignited 50 90 250 4500

Lean-Burn spark ignited with a rated brake horsepower > 50 and <100 200 - 750 4500

Lean-Burn spark ignited with a rated brake horsepower > 100 125 80 750 4500

Rich-Burn Cyclically-loaded spark ignited 300 - 250 4500

Compression ignited and dual-fuel 700 40 750 4500

Section F delineates the requirements of the Inspec tion and Maintenance Plan.

Section G contains the Compliance Plan requirements . The owner or operator of a unit subject to the emission limits in the Rule must submit, and ob tain approval of, a Compliance Plan according to the schedule in Section K.Section I specifies the Source Testing requirements

.

Section J has the Recordkeeping provisions.

The Compliance Schedule is specified in Section K.

Changes in Emissions According to the Staff Report, the estimated emissi on reduction due to the June 19, 2008 version of Rule 333 is 0.0178 tons of NOx per day. The esti mated emissions of ROC will increase by 0.0001 tons/day. These changes in emissions are bas ed on engines in the 2005 emission inventory.

Rule Evaluation Generally, SIP rules must be enforceable (see secti on 110(a) of the Clean Air Act, hereafter CAA); must require Reasonably Available Control Tec hnology (RACT) for major sources in nonattainment areas (see CAA §182(b)(2) and (f)); m ust not interfere with applicable requirements, including requirements concerning att ainment (see CAA section 110(l)); and must not relax existing requirements in effect prior to enactment of the 1990 CAA amendments (see section 193). The SBCAPCD regulates an area that is classified as maintenance for the 1-hour

ozone standard and is in attainment for all criteri a pollutants, thus, submitted Rule 333 does not have to fulfill RACT requirements.

Guidance and policy documents that we used to defin e specific enforceability requirements include the following:

• Issues Relating to VOC Regulation, Cutpoints, Defic iencies, and Deviations (the "Blue Book"), US EPA, OAQPS (May 25, 1988).

• EPA Region IX’s Guidance Document for Correcting Common VOC and Oth er Rule Deficiencies (August 21, 2001, the “Little Bluebook”).

• State Implementation Plans; General Preamble for th e Implementation of Title I of the Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 1992); 57 FR 18070 (April 28, 1992).

• State Implementation Plans; Nitrogen Oxides Supplem ent to the General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 (the "NO X Supplement to the General Preamble"), US EPA, 57 FR 55620 (November 25, 1992).

SBCAPCD Rule 333 meets some of the necessary requir ements listed above. The Rule was not

reviewed to determine its fulfillment of RACT thus we are not making a statement of its merit in this regard. It is a strengthening of the current S IP and will lead to a net decrease in NOx emissions when the rule is implemented. The Rule is not adequately enforceable as it gives the APCO too much discretion of what is required, lacks clear guidance on source testing parameters and lacks adequate follow-up if a portable analyzer reading is above the emission limit. These inadequacies are further discussed below.Rule Deficiencies

1. EPA guidance states that director’s discretion may be appropriate if explicit and replicable procedures within the rule tightly define how the d iscretion will be exercised to assure

emission reductions. 1 Rule 333 includes various provisions allowing for APCO discretion that do not follow EPA guidance. Some examples incl ude:

• Section F.3: If such an engine cannot be operated for portable a nalyzer emissions testing due to mechanical failure or lack of fuel, the monitoring requirement may be waived provided written Control Officer approval is obtained prior to the end of the quarter (or month, if performing monthly mon itoring).

• Section D.4: The continuous monitoring system may be a continuou s emissions monitoring system or an alternative approved by the Control Officer. The Rule should be amended to follow EPA guidance o n director’s discretion. One option for approvable provisions is to include EPA approval al ongside APCO approval.

2. Section F.3 indicates that portable analyzer readin g in excess of the emission limits triggers another reading in 15 days and monthly readings for 3 months. These high portable analyzers readings should instead trigger a source test withi n 60 days of the excess emission reading.

3. Section I.1 indicates that source tests shall be pe rformed at the engine’s maximum load or under the engines’ typical duty cycle as demonstrat ed by historical operation data. This should be constrained to the engine’s maximum load or conditions specified in the Permit to Operate. The option for testing at the engine’s typ ical duty cycle should be further defined and justified.

Suggested Rule Improvement EPA recommends that the SBCAPCD make the following improvements in the next revision of

Rule 333:

1. The emission limits in the Rule should be further s trengthened; see for example San Joaquin Valley Unified APCD Rule 4702, section 5.1.

Recommendation EPA staff recommends limited approval/disapproval w ithout sanctions of SBCAPCD Submitted Rule 333 for incorporation into the California Appl icable SIP.

Attachments

1. Submitted Rule 333

2. Staff Report

1 “Guidance Document for Correcting Common VOC & Oth er Rule Deficiencies,” EPA Region 9, August 21, 200 1 (the Little Bluebook), pages 17-18.