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On October 23, 2019, the Imperial County Air Pollution Control District (ICAPCD) released a public notice proposing a major overhaul of permitting and emission control requirements for boilers, water heaters, steam generators, and process heaters. The proposed changes will require a large amount of retroactive permitting activity for existing units that were previously exempt from permitting requirements. Additional changes are proposed to restrict emissions from new fuel combustion.

The proposed amendments to Rule 400.2 will limit NOX emissions for new and existing boilers, process heaters, steam generators. The limits will apply to units as rated 5 million Btu/hour and higher. All units subject to the new rule without a current permit to operate (PTO) will be required to apply for a permit by December 31, 2022. Additionally, new boilers, process heaters, and steam generators will be subject to NOX concentration limits based on their rated heat input and fuel type. All units installed prior to January 1, 2020 will also be limited to NOX emissions of 30 ppmv when operated on gaseous fuels and 40 ppmv when operated on liquid fuels.

The new proposed Rule 400.5 will place restrictions on natural gas-fired water heaters, small boilers and process heaters with a heat input rating of 75,000 Btu/hour to 5 million Btu/hour. Affected equipment would be illegal for sale in Imperial County unless the manufacturer submits a certification of compliance in advance to ICAPCD, on a per model number basis, at least 30 days in advance of offering any affected unit for sale. The certification status will need to be displayed on the unit. The new proposed Rule 400.6 will place similar restrictions on natural gas-fired water heaters with a heat input rating less than 75,000 Btu/hour.

The public notice for the proposed rules and amendments can be reviewed on the ICAPCD's website. For more information regarding the proposed rules and amendments, please contact our Irvine office at (949) 567-9880.