SS28: Residential Fan-Type Furnaces Brief Summary: This control measure would reduce oxides of nitrogen (NOX) emissions from fan type central furnaces by reducing allowable NOX emission limits on new furnace installations in Regulation 9, Rule 4. Also, Regulation 9-4 would be amended to apply to non-residential furnaces in the same size range. Purpose: Reduce emissions of NOX from fan-type central furnaces. Source Category: Combustion Regulatory Context and Background: The Air District’s Regulation 9, Rule 4 is a “point‐of‐sale” type regulation, requiring that any new residential furnace rated up to 175,000 BTU/hr be certified to meet 40 nanograms (ng) of NOX per joule of delivered heat, which is equivalent to an emission concentration of about 55 ppmv at 3 percent oxygen. Regulation 9, Rule 4 was adopted and last amended in 1983. In 2009, the South Coast Air Quality Management District (SCAQMD), which previously imposed the same 40 ng/joule NOX limit as Regulation 9-4 in their Rule 1111, adopted a future NOX limit of 14 ng/joule for most categories of central furnace rated up to 175,000 BTU/hr (conventional units, high-efficiency condensing units, mobile-home units), with the first category subject to the reduced limit in October 2014. As of the beginning of 2014, SCAQMD staff reported to their governing board that manufacturers had developed and tested prototype furnaces in each device category that comply with the 14 ng/joule NOX limit, but that commercial versions of these devices were not yet available, and that Rule 1111 might be amended in 2014 to address this timing issue. In September 2014, Rule 1111 was indeed amended to delay the compliance date for condensing (high efficiency) units until April 1, 2015, and to allow up to three years’ delay for residential furnace manufacturers to meet the 14 ng/joule emission limit with payment of a mitigation fee. The intent of this control measure is to reduce NOx and CO emissions. In a broader context, the Air District is working with local governments and others to phase out the use of fossil fuelbased technologies in buildings, as part of the Air District’s large-scale effort to reduce greenhouse gas emissions (see control measure BL2: Decarbonize Buildings). When it is not feasible to install a non-fossil fuel-based furnace, this control measure ensures that the furnace installed uses best available retrofit control technology (BARCT). This control measure establishes maximum allowable NOx and CO emission levels for a specified type and size range of furnace. Any future greenhouse gas reduction rules the Air District may develop as part of its climate protection strategy may restrict commerce in or use of certain types of fossil fuel combustion devices, including devices addressed in NOx and CO BARCT rules.
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Implementation Actions: The Air District will: Develop amendments to Rule 9-4 to include the 14 ng/joule NOX limit that appears in SCAQMD Rule 1111 and extend the rule to non-residential applications. Explore opportunities regarding the use of fossil fuel-based technologies in residential and non-residential space heating. (See BL2: Decarbonize Buildings) Emission Reductions: Because the amended rule will apply only to new devices and because central furnaces have an average life of about 20 years, the emission reductions from this measure will be phased in as existing furnaces are replaced. Emissions reductions will be 6 to 7.2 tons per day after the measure is fully implemented. This estimate is based on a 65 percent reduction (14 ng/joule versus 40 ng/joule) of the 2011 NOX inventory for domestic space heating using natural gas fuel (8.61 tons/day), plus some portion of commercial natural gas use (2.41 tons/day). The inventory also includes industrial natural gas use (2.94 tons/day), but this is assumed to not be used for space heating. Exposure Reductions: Not applicable to NOX emissions. Emission Reduction Trade-Offs: Depending on the technology selected, NOX reductions may increase GHG emissions, specifically CO2, by reducing efficiency of the combustion process. This trade-off is unlikely for this control measure, however, because efficient low‐NOX burners have been developed for similar types of appliances. New forced air heaters will probably be more efficient than the ones they replace, reducing GHG emissions. Costs: In the staff report for Rule 1111, South Coast AQMD estimated that compliance with a 14 ng/joule NOX limit would cost from $9,400 to $20,750 per ton of NOX reduced and would result in an additional consumer cost of $118 to $223 per furnace, all in 2014 dollars. Co-Benefits: Because NOX compounds in the atmosphere contribute to the formation of secondary particulate matter (PM), any NOX emission reduction will also result in a reduction of PM 2.5. Secondary PM is formed from the conversion of NOX to ammonium nitrate (NH4NO3). District staff has estimated the ratio between NH4NO3 formation to NOX emissions to range between 1:6 and 1:10. Assuming a NOX emission reduction of 6 to 7.2 tons/day, and a particulate formation factor of 1:8, secondary particulate matter will be reduced by 0.8 to 0.9 tons/day by the control measure. Issue/Impediments: No specific issues or impediments have been identified.
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Source(s): 1. South Coast Air Quality Management District, Rule 1111 2. Bay Area Air Quality Management District (BAAQMD), Regulation 9, Rule 4
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