South Coast Air Quality Management District
South Coast Air Quality Management District
BOARD MEETING DATE: September 21, 2001 AGENDA NO. 15
Report on Emissions Testing Protocol for Implementation of Rule 1146 – Emissions of Oxides of Nitrogen from Industrial, Institutional, and Commercial Boilers, Steam Generators, and Process Heaters
SYNOPSIS:
The "Protocol for the Measurement of Nitrogen Oxides, Carbon Monoxide and Oxygen From Sources Subject to South Coast Air Quality Management District Rule 1146" will allow the use of portable hand-held analyzers for annual emission testing requirements. The protocol has been developed to reduce compliance costs and to ensure standardization of test procedures.
RECOMMENDED ACTION:
Receive and file.
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. Rule 1146 establishes limits on nitrogen oxides (NOx) and carbon monoxide (CO) for 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. RECLAIM facilities are subject to the non-NOx requirements of Rule 1146, such as the carbon monoxide (CO) emission limit and monitoring requirements. Rule 1146 was amended on November 17, 2000 to make the AQMD’s rule as stringent as other California air districts’ rules that regulate similar equipment. To achieve this, the NOx emission limit was lowered from 40 to 30 ppm and an annual NOx and CO emissions testing requirement was added. No changes were made to the CO emission limit.
The Governing Board directed staff to work with stakeholders and agencies to develop a protocol for emissions testing using portable analyzers. The use of portable analyzers will reduce costs for annual testing, while still being an effective compliance method.
Public Process
A public consultation meeting was held on August 15, 2001 and comments were received and incorporated in the protocol. Over 2,000 companies and individuals were notified about the meeting. The AQMD notified owners and operators of Rule 1146 boilers, boiler and burner manufacturers, providers of boiler related services and trade organizations. At the consultation meeting, comments were made regarding non-compliance and enforcement for boilers in the size range affected by this rule. Staff responded that the annual testing requirement helps to maintain compliance. A question was also raised as to whether RECLAIM facilities would be subject to the annual testing requirement for CO. Staff responded that RECLAIM facilities must continue to meet the CO requirements in Rule 1146, which includes annual testing of CO emissions. In addition, the AQMD staff clarified that cost estimates presented in the November 2000 Rule 1146 Staff Report are not expected to change since they are based on the same protocol for hand-held monitors.
Protocol
The protocol consolidates current guidelines for existing Rule 1146 test procedures into one document and would use existing AQMD guidelines with a U.S. EPA test method for hand-held analyzers, CTM-030. The protocol also specifies that the source testing contractor must be independent from the facility or company where the emissions testing is being conducted.
The protocol for Rule 1146 includes guidelines on the following:
The protocol has been developed to ensure standardization of test procedures including specified test conditions, required test methods, specifications for test equipment, data collection and reporting, and quality assurance requirements. Staff recommends that the Board receive and file this report.
Resource Impacts
Implementation of this protocol can be handled with existing resources.
Protocol for the Measurement of Nitrogen Oxides, Carbon Monoxide and Oxygen from Sources Subject to South Coast Air Quality Management District Rule 1146
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