UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX AIR DIVISION

Technical Support Document

for
EPA ’ s Direct Final Rulemaking

for the California State Implementation Plan

San Joaquin Valley Unified Air Pollution Control District Rule 4308 Boilers, Steam Generators, and Process Heaters

– 0.075 MMBtu/hr to less than
2.0 MMBtu/hr

Prepared by: Nicole Law

November 2014 2



Agency: San Joaquin Valley Unified Air Pollution Control
District ( SJVU APCD )

SIP Approved Rule: Rule 4308

- Boilers, Steam Generators, and Process
Heaters

– 0.075 MMBtu/hr to less than 2.0 MMBtu/hr
Amended

– December 17, 2009
Submitted

– May 17, 2010 EPA Approved

– December 30, 2010 (76 FR 5276)

Superseded Submittals: none

Subject of this TSD: Rule 4308

- Boilers, Steam Generators, and Process
Heaters

– 0.075 MMBtu/hr to less than 2.0 MMBtu/hr
Amended

– November 14, 2013
Submitted

– May 13, 2014

RULE SUMMARY

-

Rule 4308 establishes emissions limits for criteria air pollutants, including NOx
and CO limits and certification requirements for boilers, steam generators, and process heaters

. It also describes related compliance reporting

, labelling , and test
methods . Rule 4308 does not ap ply to existing units , as it is a point of sale rule

. Changes from the approved SIP include:

1. Add ed carbon monoxide (CO) to section 1.0 Purp ose to clarify that the rule
also controls emissions from CO.

2. Removed the terms California Public Utility C ommission (PUC) Quality Natural Gas and Heat Output and added the terms EPA, Hot Water Pressure Washer, PUC Quality Natural Gas, and SCAQMD to section 3.0
Definitions.

3. Added h ot water pressure washers to the section 4.0 Exemptions.

4. Revised the compliance dates in section 5.0 Requirements to make the Table 1 requirements effective until December 31, 2014 and the Table 2 requirements effective starting January 1, 2015.

5

. Removed the Tier 1, 2, and 3 categories of units. The rule limits are
unch anged and now divided by size of unit and type of fuel in Table 1.

6. Added a Table 2 which introduces a lower limit for instantaneous water
heaters between the heating capacity of 0.075 and 0.4 MMBtu/hr. 3



7. Revised section 6.1 to remove language that units certified by SCAQMD need to comply with the emission limits and compliance schedule in rule
4308.

8. Revised section 6.2.3 to include that for natural gas fired units, a specific SCAQMD test method shall be used.

9. Removed section 7.0 Compliance S chedule from the rule.

EVALUATION CRITERIA

- The following criteria were used to evaluate the
submitted rule.

1. Enforceability

- The Bluebook ( Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations , EPA, May 25, 1988) and the Little Bluebook ( Guidance Document for Correcting Common VOC & Other Rule Deficiencies, EPA Region 9, August 21, 2001) were used to help evaluate compliance with the CAA § 110(a)(2)(A) requirement for enforceability.

2. Stringency

- EPA ’ s Alternat ive Con trol Techniques Document (ACT ) titled,

“ NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers ” ( EPA

453/R

- 94

- 022

- 1994/03, March 1994 ), CARB ’ s RACT/BARCT guidance
titled

, “ Industrial, Institutional, and Commercial Boilers, Steam Generators,
and Process Heaters ” (July 18, 1991), and other state and local rules for this category were used to help evaluate the stringency of the rule’s control requirements

.

3. SIP Relaxation

- CAA § 110(l) prohibits EPA from approving any SIP revision that would interfere with any applicable requirement concerning attainment and reasonable further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA § 193 prohibits the modifi cation of any SIP

approved control requirement in effect before November 15, 1990, in a
nonattainment area.

EPA EVALUATION

- A summary of our evaluation of the three criteria follows.

1. The rule requirements and applicability are clear, and the certifi cation

, compliance reporting and other provisions sufficient ly ensure that affected sources and regulators can evaluate and determine compliance with Rule
4308 consistently.

2. The SJVUAPCD regulates an extreme nonattainment area for the 8

- hour
1997 and 2008 Ozone National Ambient Air Quality Standards and a non

attainment area for the 24

- hr 1997 and 2006 PM2.5 NAAQS. As a result, Rule 4307 must fulfill RACT and RACM requirements. 4

 The submitted rule regulates boilers, steam generators, process heate rs, and water heaters that are smaller than the applicable units under CARB ’ s RACT/BARCT guidance for NOx

. T he controls in rule 4308 are comparable
to those in EPA’s ACT and other California District rules for this category for
CO and NOx

, including South Coast Air Quality Management District Rule
1146.2 and Sacramento Metropolitan Air Quality Management District R ule

414

. While Rule 4308 does not have specific controls for PM2.5, the rule
was evaluated for control of PM2.5 precursors such as NOx. Accord ingly

, we find that the control requirements in this rule represent RACT

- level
control for this source category for NOx and fulfill RACM requirements for PM2.5 precursors

.

3. W e propose to determine that our approval of the submittal would comply
with CAA §§ 110(l) and 193 because (1) the proposed SIP revision would
not interfere with the on

- going process for ensuring that requirements for RFP and attainment of the NAAQS are met, and (2) the submitted ru le has
introduced a lower limit for i nstantaneous water heaters with rated heat input capacity equal to 0.075 bu t less than or equal to 0.4 MMBtu/hr

. T herefore

, overall, the rule is more stringent than the existing SIP approved
rul e.

The rule has added an exemption for hot water pressure washers. These units fall under the definition of instantaneous water heaters, but it was not the intent of the District to include hot water pressure washers as they are generally portable units fueled with diesel fuel. Because of their portable nature, it would be difficult to install controls on these units. Rule 4308 is a point of sale rule and these units currently are not subject to an emission
limit. SCAQMD Rule 219 similarly exempts the se units.

RULE DEFICIENCIES

– We have identified no deficiencies with Rule 4308 sufficient for EPA to propose less than full approval.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION

- The following revisions are not currently the basis for rule d isapproval, but are
recommended for the next time the rule is amended.

1. Section 4.2 provides an exemption for units installed in recreational
vehicles. Consider removing this exemption.

2. Rule 4308 is a point of sale rule and applies to any person who supplies, sells, offers for sale, installs, or solicits the installation of boilers, steam generators, process heaters or water heaters. Consider expanding the applicability to include existing units with rated heat input capacity greater 5

 than 0.4 and les s than or equal to 2 MMBtu/hr as is done in SCAQMD Rule
1146.2

. 3. Section 4.3 gives a full exemption for hot water pressure washers

. Consider limiting this exemption to hot water pressure washers within a specific rated heat input capacity as is done in SCAQMD Rule 21 9 section (b)(4).

EPA ACTION

-

The submitted Rule 4308 strengthens the SI P, and the associated District s taff

rep ort projects it will reduce NOx emissions by 1.82 tons per year within the next 20 years . The rule satisfies the applicable CAA § 110 requirements. Therefore,
EPA staff recommends a full approval of Rule 4308 pursuant to CAA § 110(k)(3).

REFERENCES

-

1. SJVUAPCD Rule 4308

, Boilers, Steam Generators, and Process Heaters

– 0.075 MMBtu/hr to less than 2.0 MMBtu/hr

, as amended November 14,
2013 and submitted to EPA on May 13, 2014

. 2. SJVUAPCD Rule 4308

, Boilers, Steam Generators, and Process Heaters

– 0.075 MMBtu/hr to less than 2.0 MMBtu/hr

, , as approved into the SIP on December 30, 2010.
3. “ Alternative Control Techniques Document

- NOx Emissions from Industrial/Commercial/Institutional (ICI) Boilers” EPA

- 453/R

- 94

- 022

- 1994/03, March 1994

. http://www.epa.gov/groundlevelozone/SIPToolkit/ctg_act/199403_nox_epa 453_r

- 94

- 022_ici_boilers.pdf

4. “Determination of Reasonably Available Control Technology and Best Available Retrofit Control Technology for Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters,” CARB, July 18, 1991.

5

. “ Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations, ” ( a.k.a., Bluebook) EPA OAQPS, May 25, 1988 (web citation ).
6

. “ Guidance Document for Correcting Common VOC & Other Rule Deficiencies, ” (a.k.a., Little Bluebook), EPA Region 9, Augu st 21, 2001 (http://www.epa.gov/region09/air/sips/littlebluebook2001.pdf ).