United States Environmental Protection Agency, Regi on 9

Air Division

Technical Support Document

for

EPA’s Notice of Proposed Rulemaking

for the

California State Implementation Plan

South Coast Air Quality Management District’s

Rule 1111, Reduction of NOx Emissions from Natural Gas-Fired, Fan-Type Central Furnaces

Prepared by: Idalia Pérez

June 2010South Coast Air Quality Management District (SCAQMD )

Submitted Rule SCAQMD Rule 1111, Reduction of NOx Emissions from N atural Gas-Fired, Fan-Type Central

Furnaces:

 Amended: November 6, 2009

 Submitted: May 17, 2010

 Determined complete: June 8, 2010

Previous Rule Submittals There are no outstanding submittals of Rule 1111.

SIP-Approved Rule

 Adopted: July 8,1983

 Approved by EPA: May 3, 1984 (49 FR 18830)

Rule Summary Rule 1111 limits NOx emissions from natural gas-fir ed, fan-type central heating furnaces with a rated hear input capacity < 175,000 Btu/hour used i n residences and small commercial buildings. The Rule also applies to combination heating and co oling units with a cooling rate < 65,000

Btu/hour.

Rule Amendments Rule 1111 was amended to strengthen the NOx emissio n limits and expand the applicability to

include mobile home furnaces.

The Rule includes a rebate incentive for early comp liance and mandates the completion of a technology assessment report on the status of manuf acturer’s progress towards compliance with

the new emission limits.

Other changes were done to the Rule language to imp rove clarity and enforceability.

Effects on Emissions The staff report indicates that the amendments of R ule 1111 will lead to an estimated reduction of between 2.5 to 3.1 tons per day of NOx emissions in 2023. Because of the lifetime of residential furnaces, the complete emissions reduct ion benefits of 6.8 tons per day will not be

realized until 2043.

Rule Evaluation Generally, SIP rules must be enforceable (see §110( a) of the Clean Air Act, hereafter CAA); must require Reasonably Available Control Technology (RA CT) for major sources of NOx in nonattainment areas (see CAA §182(b)(2) and (f)); m ust not interfere with applicable requirements, including requirements concerning attainment (see C AA §110(l)); and must not relax existing requirements in effect prior to enactment of the 19 90 CAA amendments (see §193).Although the SCAQMD regulates a serious (8-hour) an d extreme (1-hour) ozone nonattainment

area (40 CFR 81), submitted Rule 1111 is not subjec t to RACT because it is applicable to sources that are too small to exceed the major sour ce threshold.

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

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

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

The Rule was not reviewed to determine its fulfillm ent of RACT; thus we are not making a statement of its merit in this regard.

Recordkeeping and other compliance provisions in th e rule ensure that the requirements are adequately enforceable. The elimination of the exe mption for mobile homes and the addition of more stringent NOx emission limits make the amendme nts a strengthening of the SIP. Thus, approval of the submitted rule does not relax the S IP and satisfies CAA §110(l) and §193.

Recommendation EPA staff recommends approval of SCAQMD submitted R ule 1111 for incorporation into the

California SIP.

Attachments

1. Submitted Rule 1111 (Clean Copy)

2. Submitted Rule 1111 (Strikeout Copy)

3. Staff Report

4. SIP-approved version of Rule 1111