1 Final Staff Report with Appendices for

Amendments to Rule 4702 SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

FINAL STAFF REPORT

Amendments to Rule 4702 (Internal Combustion Engines)

November 14, 2013

Prepared by: Jesse Madsen, Air Quality Specialist

Anna Myers, Senior Air Quality Specialist

Reviewed by: Valarie Ballard, Air Quality Inspector II

Brian Clements, Senior Air Quality Engineer Jennifer Ledergerber, Senior Air Quality Inspector Jessica Fierro, Program Manager, Strategies and Inc entives Errol Villegas, Program Manager, Strategies and Inc entives Samir Sheikh, Director, Strategies and Incentives

After a thorough evaluation and an extensive public process the San Joaquin Valley Unified Air Pollution Control District (District) a mended Rule 4702 (Internal Combustion Engines) in 2011. This adoption satisfied commitme nts in the both District’s 2007

Ozone Plan

and 2008 PM2.5 Plan . Since adoption of these amendments, and upon
further review, it has been determined that some cl arification is necessary to more clearly align rule language with the intent of the 2011 rule amendments.

The four-year rule amendment process for the 2011 a mendments included a feasibility study; research of the District’s permits database, industry standards, technological advancements and actions taken by other regulatory agencies; and evaluation of public comments received throughout the public process inc luding four public workshops, several stakeholder technical discussion meetings a nd socioeconomic focus group meetings. These extensive efforts resulted in the adoption of numerous technologically feasible and cost effective new and more stringent rule requirements. Through this process, the District made the determination that r educing the NOx emission limits for waste gas fueled internal combustion engines is not feasible, and therefore proposed no amendments to the NOx emission limits for these eng ines.

The purpose of this current rule amending project i s to make administrative updates to rule language to clarify existing rule requirements by adding Federal Register citations to Section 3.37, deleting “stationary” from Section 5.2, deleting “the” from Section 5.10.2, adding “and” to Section 7.5.2.1, adding “so urce” to Section 7.6.2.2, and by adding a line item to Table 2 to clarify that NOx l imits for lean-burn waste gas fired engines used exclusively in non-Agricultural Operat ions (Non-AO) is 65 parts per millionSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4702 November 14, 2013

2 Final Staff Report with Appendices for

Amendments to Rule 4702 by volume (ppmv). This rule amending project would not change existing emissions limits or affect air quality.

AMENDMENTS TO RULE 4702

The administrative rule clarifications are as follo ws.

Applicability During the rule amendment project for the 2011 amen dments, the word “stationary” was added to Section 5.2, as this section is applicable to all engines rated at greater than 50 brake horsepower (bhp) that are operated as a part of a stationary source. However, the addition of the term stationary could be misint erpreted by stakeholders to mean that requirements in Section 5.2 are limited to stationa ry engines. Additionally, we believe this word was carried over from Section 5.1, which is intended to provide an inventory of small stationary engines, and so the word “stationa ry” is less likely to be misinterpreted there. The amendments removed the word “stationary ” from Section 5.2 to ensure the intent of the language is not misinterpreted. This clarification does not result in a change to currently enforced rule requirements or a pplicability.

NOx Limits for Lean-Burn Waste Gas Fired Engines Section 5.2.2 Table 2 would be amended to clarify t he NOx limit for waste-gas fueled lean burn engines used exclusively in Non-AO. The addition of this line item would clarify the existing 65 ppmv limit for these engine s, originally presented in Table 1 line

item 2.b of the 2007 version of the rule.

During the 2011 rule amendment project, the Distric t determined that further reducing the NOx emission limits for waste gas fueled intern al combustion engines goes beyond RACT due to significant technical difficulties and prohibitive costs associated with the inherent heat content variability of waste gas. It was therefore decided that no amendments would be proposed to reduce the NOx emis sion limits for these engines. This decision is explained in several instances thr oughout the Governing Board Memo, CEQA Initial Study, and Final Draft Staff Report wi th Appendices 1 , and the presentation 2

at the public hearing for adoption of proposed amen dments:

• Governing Board Memo, pages three, eight and nine

• The CEQA Initial Study and Final Negative Declarat ion for Proposed Amendments to Rule 4702, page eight

• Final Draft Staff Report, pages three and ten

• Appendix B (Emission Reduction Analysis), page B-6

1 August 18, 2011 Memo to SJVUAPCD Governing Board ( 2011). Retrieved September 25, 2013 from http://www.valleyair.org/Board_meetings/GB/agenda_m inutes/Agenda/2011/August/Agenda_Item_10_Aug_18_201 1. pdf

2 August 18, 2011 Presentation to SJVUAPCD Governing Board (2011). Retrieved September 25, 2013 from http://www.valleyair.org/Board_meetings/GB/agenda_m inutes/Agenda/2011/August/R4702PresentationGB.pdfSAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4702 November 14, 2013

3 Final Staff Report with Appendices for

Amendments to Rule 4702 • Appendix C (Cost Effectiveness Analysis), pages C- 4 and C-5

• Appendix D (Socioeconomic Analysis), page D-7

• Presentation to the Governing Board, slides four a nd seven

The line-item clarification for lean-burn waste gas fired engines used exclusively in NonAO was added to Table 2 of Rule 4702; see below.

Updated Table 2 for Rule 4702 Emission Limits for I nternal Combustion Engines

Table 2 Emission Limits for a Spark-Ignited Intern al Combustion Engine Rated at >50 bhp

Used Exclusively in Non-AO (All ppmv limits are cor rected to 15% oxygen on a dry basis). Emission Limits are effective according to the compliance schedule specified

in Section 7.5.

Engine Type NOx Limit (ppmv) CO Limit

(ppmv) VOC Limit

(ppmv)

1. Rich-Burn

a. Waste Gas Fueled 50 2000 250 b. Cyclic Loaded, Field Gas Fueled 50 2000 250

c. Limited Use 25 2000 250

d. Rich-Burn Engine, not listed above 11 2000 250

2. Lean-Burn Engines a. Two-Stroke, Gaseous Fueled, >50 bhp and < 100 bhp 75 2000 750

b. Limited Use 65 2000 750 c. Lean-Burn Engine used for gas compression 65 ppmv or

93% reduction 2000 750

d. Lean-Burn Engine, Waste Gas Fueled 65 ppmv or

90% reduction 2000 750

ed. Lean-Burn Engine, not listed above 11 2000 750

ANALYSES

This rule amending project is an administrative cla rification of existing rule requirements; amendments do not result in new or mo re stringent regulatory controls and do not affect air quality or emission limitatio ns. No emission reductions or costs are associated with this rule-amendment project. There fore, this rule amending project does not require a socioeconomic impact analysis (C H&SC § 40728.5(a)), a rule consistency analysis (CH&SC § 40727.2), or a CEQA a nalysis (CEQA guidelines § 15060).SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Final Staff Report: Rule 4702 November 14, 2013

4 Final Staff Report with Appendices for

Amendments to Rule 4702 RULE DEVELOPMENT PROCESS

The District made the Proposed Amendments to Rule 4 702 and the Final Draft Staff Report available for review and public comment 30 d ays prior to a public hearing of the Governing Board to consider adoption of the propose d rule amendments. No comments were received during the subsequent two-we ek comment period. The proposed amendments were presented to the Governing Board for adoption at a public hearing on November 14, 2013.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Comments and Responses November 14, 2 013

A - 1 Final Staff Report with Appendices for

Amendments to Rule 4702 

### APPENDIX A

Summary of Significant Comments and Responses

For Amendments to Rule 4702

November 14, 2013SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Comments and Responses November 14, 2 013

A - 2 Final Staff Report with Appendices for

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Appendix A: Comments and Responses November 14, 2 013

A - 3 Final Staff Report with Appendices for

Amendments to Rule 4702 SUMMARY OF SIGNIFICANT COMMENTS FOR PROPOSED AMENDMENTS TO RULE 4702 (INTERNAL COMBUSTI ON ENGINES)

EPA REGION IX COMMENTS

No comment letter was received from EPA.

ARB COMMENTS

No comment letter was received from ARB.

STAKEHOLDER COMMENTS

No stakeholder comments were received.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix A: Comments and Responses November 14, 2 013

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