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PROPOSAL:

Annual Report on Public Outreach Activities for Rule 1146.2 – Emissions of Oxides of Nitrogen from Large Water Heaters and Small Boilers

SYNOPSIS:

Rule 1146.2 establishes emission limits for NOx for new water heaters and small boilers rated between 75,000 and 2,000,000 Btu/hr heat input. This is the first annual report on Public Outreach activities aimed at educating and assisting stakeholders

COMMITTEE:

Stationary Source, December 18, 1998, Reviewed

RECOMMENDED ACTION:

Receive and file.

Barry R. Wallerstein, D.Env.
Executive Officer

Summary

Rule 1146.2 - Emissions of Oxides of Nitrogen from Large Water Heaters and Small Boilers was adopted on January 9, 1998. It requires emission reductions from large water heaters and small boilers ranging from 75,000 Btu per hour (Btu/hr) up to and including 2,000,000 Btu/hr. This type of equipment is ubiquitous throughout the Basin and is located at facilities covering a wide range of industries.

With the adoption of Rule 1146.2, the Board directed staff to continue public outreach efforts to all stakeholders impacted by this rule and to continue to evaluate issues in co-operation with the public and industry. The rule requires all new water heaters and boilers to meet low NOx emission limits. Some existing water heaters and boilers must also be either retrofitted or replaced to meet low-NOx limits. Most of the issues associated with this rule and the need for public outreach have centered on the impacts of the retrofit requirements on equipment operators.

To better direct our outreach, staff efforts have focused on the applicability of the retrofit requirement. The retrofit requirement was further examined for the following water heater and boiler categories:

I. Units £400,000 Btu/hr Heat Input
Out of a total population of 66,000 units subject to this rule, about two out of three units fall into this size category. Just as is the case for residential hot water heaters (Rule 1121), there are no retrofit requirements placed on the end users of this type of equipment. Manufacturers must ensure that they furnish only compliant units.

II. Units >400,000 Btu/hr but £1,000,000 Btu/hr
Of the remaining units, approximately 10,000 are in this size range. Most of the existing units in this size range will be exempt from any retrofit requirements based on a 9,000 Therm per year gas usage allowance.

III. Units > 1,000,000 Btu/hr up to and including 2,000,000 Btu/hr
There are approximately 12,000 units in this category located at approximately 5,200 facilities. Among these units, stand-by or seasonal usage equipment will generally be exempt based on the 9,000 Therm per year gas usage limit.

Based on the above data, an estimated 15 percent of units subject to this rule will be required to eventually retrofit or replace their equipment. Staff has begun conducting public outreach to that part of industry that will be subject to retrofits.

Status of Efforts

1. Rule 1146.2 Implementation Steering Committee
Pursuant to Rule 1146.2(i) an Implementation Steering Committee was formed to further study aspects of rule implementation. The committee has provided a forum for industry, trade associations and manufacturers to provide comments and address issues. It is comprised of:

• 9 equipment manufacturers
• 8 trade associations
• 4 Gas Company representatives
• 2 equipment distributors
• 3 AQMD staff

The committee has met four times this year. Activities have included:

• Third-party study contractor selection.
• Approval of study focus and itinerary.
• Approval of a field test protocol for boiler efficiency studies.
• Selection and approval of field test sites.
• Selection of additional standards to ensure third-party retrofit operations comply.

2. Third-Party Contractor Study
In coordination with Sempra Energy (formerly The Gas Company), the AQMD is sponsoring an independent contractor study of various issues regarding Rule 1146.2. RFP #9798-25 was released on February 20, 1998, and Energy and Environmental Research (EER) was selected by a joint AQMD, Sempra Energy and Gas Appliance Manufacturers Association panel in March 1998. The proposal was accepted at the May 1998 Governing Board meeting and EER began the study in June 1998. The AQMD is funding up to $85,000 for this project.

3. Rule 1146.2 Equipment Certification Program
An equipment certification program has been established in accordance with Rule 1146.2(d) to allow equipment manufacturers the opportunity to demonstrate that their specific equipment models comply with the rule requirements. This program will also greatly assist consumers by listing compliant boilers and water heaters that have been pre-certified by the AQMD. Manufacturers are encouraged to certify their compliant products through the AQMD thereby promoting the use of less-polluting products. To date approximately seven manufacturers are in the pre-certification process. A total of 45 manufacturers have been notified of the program nationally, and most have expressed a strong interest in getting their products pre-certified. Staff is working to certify compliant products as quickly as possible.

All of these programs are ongoing and are contributing to the successful implementation of this rule.

Outreach Efforts

Significant progress has already been made towards reaching all potential, affected stakeholders, particularly small businesses. A summary of our recent and future planned outreach efforts follows:

1. End-User Venue Participation
AQMD staff participated at the following trade shows and conventions, where information regarding the AQMD and specifically the rule were distributed and discussed:

Scheduled future event participation:

1. Rule 1146.2 Public Outreach Brochure
Staff is developing a public outreach brochure that will conveniently summarize the major points of the rule in a user-friendly manner. The brochure will be designed to be informative while still being understandable to readers from across a variety of industries and operations. Contact information is provided in the brochure for further technical or specific questions. The brochure will be handed out at all future public events.

2. Coordinated Outreach to Municipalities
We are preparing to distribute informational materials to local municipalities.

Although significant progress has been made, staff will continue to identify, educate, and assist stakeholders to assure compliance with this important rule.

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