South Coast Air Quality Management District
South Coast Air Quality Management District
BOARD MEETING DATE: November 17, 2000 AGENDA NO. 31
Amend Rule 1146 – Emissions of Oxides of Nitrogen from Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters
SYNOPSIS:
Proposed Amended Rule 1146 will address issues raised by ARB regarding implementation of all feasible measures and make Rule 1146 as stringent as the requirements of other California air districts, as required by the 1994 SIP settlement agreement. Proposed amendments to Rule 1146 will lower the NOx emission limit from 40 ppm to 30 ppm, add an annual testing requirement, and may change monitoring, recordkeeping or reporting requirements.
COMMITTEE:
Stationary Source, September 22, 2000, Reviewed
RECOMMENDED ACTION:
Adopt the attached resolution:
Barry R. Wallerstein, D.Env.
Executive Officer
Background
Rule 1146 – Emissions of Oxides of Nitrogen from Industrial, Institutional and Commercial Boilers, Steam Generators, and Process Heaters (Rule 1146) was adopted in September 1988. The rule applies to non-RECLAIM facilities with units greater than or equal to 5 million British Thermal Units (MM Btu) per hour rated heat input capacity and with an annual fuel usage greater than 90,000 therms. The current rule has a NOx emission limit of either 30 or 40 ppm, depending on the unit size (rated heat input) and annual fuel usage.
The purpose of Proposed Amended Rule (PAR) 1146 is to make the AQMD’s rule as stringent as other California air districts’ rules that regulate similar types and sizes of equipment. To achieve this, PAR 1146 will reduce the NOx emission limit, add an emissions testing requirement, and add monitoring requirements.
Affected Facilities
There are approximately 850 boilers that are currently subject to the NOx emission limits of Rule 1146. These facilities represent a wide range of businesses in the commercial and industrial sectors. All of the 850 boilers will be subject to emissions testing requirements of PAR 1146. Of the 850 boilers, an estimated 700 will be subject to the lower NOx emission limits of PAR 1146.
Public Process
A public workshop was held on September 13, 2000 and comments were received and are incorporated in the staff report. Over 2,000 companies and individuals were notified about the workshop. The AQMD notified owners and operators of Rule 1146 boilers, boiler and burner manufacturers, providers of boiler related services and trade organizations.
Proposal
A comparative assessment was conducted to identify areas of Rule 1146 that are less stringent than other air districts’ rules. The assessment compared components of Rule 1146 relative to 14 other air districts’ rules that regulate boilers greater than 5 MM Btu per hour. The analysis assessed all aspects of Rule 1146 such as the NOx emission limit, tune-up provisions, monitoring and reporting requirements, and exemptions. Based on the analysis, there are three areas of Rule 1146 that are less stringent than other air districts’ rules: (1) NOx emission limit, (2) emissions testing, and (3) monitoring.
PAR 1146 lowers the NOx emission limit to 30 ppm for units burning gaseous fuels and to 30 ppm or a fuel-weighted average of between 30 and 40 ppm, for units burning a combination of gaseous and non-gaseous fuels. All units above the exemption level will also be required to perform annual emissions testing. Units greater than or equal to 10 MM Btu per hour must meet the new NOx limits and perform emissions testing by January 1, 2002. Units less than 10 MM Btu per hour must meet the new NOx limits and perform emissions testing by July 1, 2002. Phasing in the implementation of PAR 1146 is designed to provide a more even work flow for performing emissions tests and for AQMD staff. PAR 1146 requires owners and operators of units burning both gaseous and non-gaseous fuels that elect to meet the fuel weighted limit, as compared to the 30 ppm emission limit, to install totalizing fuel flow meters for each fuel.
Based on information from boiler manufacturers and distributors, the burners used to achieve a 40 ppm NOx emission limit are the same burners used to achieve a 30 ppm limit. Additional tuning of the boiler is needed to reduce NOx emissions and increase the efficiency of the boiler. Although the majority of boilers affected by PAR 1146 are expected to comply with the 30 ppm NOx emission limit through tuning of the boiler, there may be a small percentage of boilers that may require a larger fan and re-piping to meet the 30 ppm limit.
Other amendments have been made to improve clarity and enforceability of the rule. Compliance dates that have passed have been removed from the rule.
Legal Mandates and Emission Reductions
The AQMD staff is proposing to amend Rule 1146 to address issues raised by the California Air Resources Board (ARB) regarding implementation of all feasible measures. In addition, amendments are designed to make each component of Rule 1146 as stringent as other districts’ requirements pursuant to a Settlement Agreement in Coalition For Clean Air vs. SCAQMD for non-implementation of the 1994 State Implementation Plan (SIP). Proposed amendments will make Rule 1146 as stringent as each component of any other air district’s rule that regulates the similar type and size equipment. With baseline emissions of approximately 400 tons per year for affected units, implementation of PAR 1146 is expected to result in 90 tons per year of NOx emission reductions.
CEQA & Socioeconomic Analysis
The AQMD has reviewed the proposed project pursuant to state CEQA Guidelines §15002(k)(1). No substantial physical change to the existing setting is anticipated and no secondary controls are required. Thus, it can be seen with certainty that there is no possibility that the project may have a significant effect on the environment. Therefore, the project is not subject to CEQA pursuant to state CEQA Guidelines §15061(b)(3). A Notice of Exemption has been prepared for the proposed project in accordance to state CEQA Guidelines §15062 and will be filed with the county clerks immediately following the adoption of the proposed amendments to the rule.
AQMD staff has also prepared a socioeconomic assessment which is part of the staff report. Based on this assessment, the cost effectiveness of the proposed amendment is approximately $7,000 per ton of NOx reduced. This estimate includes a cost of $700 for annual source tests, $3,000 for a totalizing fuel flow meter, a fan upgrade cost of $5,000, and an additional piping cost of $2,000.
Key Issues
One issue for this rule amendment relates to the use of portable analyzers to perform the annual emissions tests. AQMD will need to demonstrate to ARB and EPA that hand-held monitors provide adequate demonstration of compliance. Companies have also asked whether their own staff would be able to perform the emissions tests instead of having to hire an independent contractor. Staff will develop a protocol for using portable analyzers within the next 9 months. The portable analyzer protocol will be developed with public review and in consultation with ARB and EPA.
Resource Impacts
Implementation of this rule amendment can be handled with existing resources.
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