San Joaquin Valley Unified Air Pollution Control Di strict April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-372 

### Rule 4902 – Residential Water Heaters

Emissions Inventory: Tons per day – summer season

Pollutant 2005 2008 2011 2012 2014 2017 2020 2023

NOx 1.37 1.27 1.30 1.31 1.33 1.36 1.39 1.42

VOC 0.10 0.11 0.11 0.11 0.111 0.11 0.12 0.12
(Source: District 2007 Ozone Plan)

District Rule 4902 Description:

Units in this source category are water heaters located in private residences with he at input of 75,000 British thermal units per hour (Btu /hr) or less. The following units are exempt: water heaters using fuels other than natur al gas, natural gas-fired heaters used exclusively to heat swimming pools or hot tubs , and water heaters used exclusively in recreational vehicles.

How does District Rule 4902 compare with federal ru les and regulations?

A. EPA – Control Technique Guidelines (CTG)

There is no CTG for this source category.

B. EPA – Alternative Control Technology (ACT)

There is no ACT for this source category.

C. Standards of Performance for New Stationary Sources (NSPS)

There is no NSPS for this source category.

D. National Emission Standards for Hazardous Air Po llutants (NESHAPs) and Maximum Achievable Control Technologies (MACTs)

There is no NESHAP or MACT for this source category

.

How does District Rule 4902 compare to rules in oth er air districts?

District staff compared NOx limits and optional con trol requirements in District Rule 4902 to comparable requirements in rules from the f ollowing California nonattainment

areas:San Joaquin Valley Unified Air Pollution Control Di strict April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-373 South Coast AQMD Rule 1121, as amended September 2 004 Bay Area AQMD Regulation 9 Rule 6, as amended Nove mber 2007 Sacramento Metropolitan AQMD Rule 414, as adopted August 1996 Ventura County APCD Rule 74.11. as amended Decembe r 1986

A. South Coast AQMD Rule 1121

South Coast AQMD Rule 1121 (Control of NOx from Res idential Type Natural GasFired Water Heaters) applies to manufacturers, distributors, retailers, and installers of natural gas-fired water heaters, with heat input ra tes less than 75,000 Btu per hour. Water heaters in recreational vehicles are exempt f rom control requirements. For water heaters not in mobile homes, has two NOx limits for residential water heaters that are considered equivalent – one based on heat input to the unit and the other based on heat output from the unit. The emission limits are no more than 10 nanograms of NOx per joule of heat output (23 pounds per billion Btu (lb/billion Btu) of heat output) or 15 parts per million by volume at 3% oxygen, dry (17.5 lb/billion Btu of heat input). Water

heaters in mobile homes have a different NOx limit - no more than 40 nanograms of NOx per joule of heat output (93 lb/billion Btu of heat output) or 55 parts per million by volume (ppmv) at 3% oxygen, dry (71 lb/billion Btu of heat input).

These limits were phased in over three years beginn ing in 2006; meaning that the limits have not been fully implemented until this year. From this perspective, the lower limits in South Coast AQMD Rule 1121 represent RACT for future rule-making and not for current analysis of District Rule 4902. District R ule 4902 is undergoing rule development as part of the District’s 8-hour ozone attainment strategy. District staff anticipates incorporating the South Coast AQMD limi ts for this source category. Adoption of the rule amendments is expected in the first quarter of 2009.

B. Bay Area AQMD Regulation 9 Rule 6

Bay Area Regulation 9 Rule 6 (Nitrogen Oxides Emissions from Boilers and Water Heaters) is an umbrella rule that covers boilers and water heaters up to t wo million Btu per hour. The rule applies to all units regardless of whether the units are residential, commercial, industrial, or institutional use. Unit s with heat input of not more than 75,000 Btu per hour are generally considered reside ntial units, so the portion of the rule that applies to units of this size will be used for the analysis. This rule was amended recently. The current requirements for residential -type units is certified units with emissions of not more than 40 nanograms NOx (calcul ated as NO2) per joule of heat input. Beginning in 2009 and phasing in over the n ext three years, the NOx limit will be 10 nanograms NOx per joule of heat input. The new units would need to be certified to this lower limit. The 10 nanograms per joule limit mirrors the South Coast rule for this source category, however to date, the rule has not been fully implemented. From this perspective, the lower limits in the Bay Area AQMD rule represent RACT for future rulemaking and not for current analysis of District Rule 4902. District Rule 4902 is undergoing rule development as part of the District ’s 8-hour ozone attainment strategy.San Joaquin Valley Unified Air Pollution Control Di strict April 16, 2009

Chapter 4: Rule Analysis

RACT Demonstration for Ozone SIP 4-374 District staff anticipates incorporating the lower limits for this source category. Adoption of the rule amendments is expected in the first qua rter of 2009.

C. Sacramento Metropolitan AQMD Rule 414

Sacramento Metropolitan AQMD Rule 414 (Natural Gas- Fired Water Heaters) applies to any person who manufactures, distributes, offers fo r sale, sells, or installs any natural gas-fired water heater with a rated heat input capa city less than 75,000 Btu/hr. Exempted units include water heaters in recreationa l vehicles, water heaters in swimming pools and hot tubs and water heaters that use fuel other than natural gas. The rule requires that certified units be used. Fo r water heaters used in mobile homes, the rule limits NOx emissions to 50 nanograms of NO x per joule of heat output (116 lb/billion Btu of heat output). All other subject units are limited to NOx emission of no more than 40 nanograms NOx per joule of heat output (93 lb/billion Btu of heat output).

Both NOx limits are calculated as NO2. The NOx limi ts in current District Rule 4902 are at least as stringent as the Sacramento Metropolita n AQMD Rule 414.

D. Ventura County APCD Rule 74.11

Ventura County APCD Rule 74.11 (Natural Gas-fired R esidential Water Heaters – Control of NOx) applies to any person selling, offe ring for sale, or installing natural gasfired residential water heaters in Ventura County. The units subject to the rule have a rated heat input of less than 75,000 Btu/hour. Wat er heaters used in recreational

vehicles and water heaters installed in mobile home s are exempt. The rule requires a certified unit that emits no more than 40 nanograms of NOx (calculated as NO2) per joule of heat output (93 pounds NOx per billion Btu of heat output). The NOx limits in current District Rule 4902 match the requirements o f the Ventura County APCD rule.

Conclusion

There are no federal rules for regulations covering air emissions for this source category. After careful evaluation of prohibitory rules in other California nonattainment areas, District staff concludes that current Distri ct Rule 4902 satisfies RACT for

residential water heaters.