Frequently Asked Questions
Rule 102 - Definitions
For more information or assistance, call the Engineering
Division at (805) 961-8800, or e-mail us at
engr@sbcapcd.org.
Q: Are demolition or abandonment projects considered as construction?
A: No.
Q: Are there any Class I Impact Areas in Santa Barbara County?
A: Yes. We have the San Rafael Wilderness (see Figure 1).
Q: What if there is a conflict between a 102 definition and a definition in
a Prohibitory Rule or regulation?
A: Definitions in a specific rule or regulation have precedent over Rule 102
definitions.
Q: Under the definition of emission unit, what is meant by activity?
A: An activity is an aggregation of components dependent upon each other to
perform a necessary function. Typically, activities are composed of production
or process lines within the source. Examples of an activity are: cogeneration
system; auto body spray booth (including associated prep/touch-up and solvent
usage); non-metallic mineral processing line (e.g., crusher, furnace, calciner,
classifier, packing); sulfur recovery train (e.g., amine unit, sulfur recovery
unit, tail gas unit).
Q: It is not clear to me how the exceptions to the definition of
modification work. Please clarify?
A: There are three cases (items 1, 2 and 3 of the definition) where a change
in the method of a source's operation is not considered a modification and thus
is not subject to Regulation VIII (New Source Review). In any case, however, the
exceptions do not apply if any underlying permit limits the source's operation.
For example, if a source has an enforceable permit condition limiting production
rate, then an increase in production rate above the permit condition's limit
would be considered a change in the method of operation. Further, in item (1),
the term "...if such increase does not exceed..." the word increase means the
resulting value that the production rate of hours of operation increases to and
is not to be interpreted as the increase by itself.
Q: Suppose an existing autobody shop is permitted to emit ROC. They now
wish to install a gas-fired booth heater which is subject to ATC and PTO
requirements. Does this constitute a "new source" per the definition in Rule
102?
A: Yes. Since NOx will be emitted for the first time at this source, it is
considered a new source.
Q: Since an emission unit may be defined as an activity, and an activity is
a production or process line, what does "process" or "process line" mean?
A: The APCD uses the following definitions of process and process line:
"Process" means any method, reaction, or operation wherein materials are handled
or whereby materials undergo physical change (i.e., the size, shape, appearance,
temperature, state or other physical property of the materials is altered) or
chemical change (i.e., a substance or substances with different chemical
composition or properties are formed or created). A process includes all of the
equipment and facilities necessary for the handling of materials or the
completion of the transformation of the materials to produce a physical or
chemical change. There may be several processes in series or in parallel
necessary to manufacture or produce a product.
"Process Line" means one or more pieces of equipment linked by the process flow
to produce a product or perform a service such that the product cannot be
produced or the service cannot be performed if any piece of equipment is removed
or not functioning.
Q: For an oil and gas production field, how are the production or process
lines defined?
A: The objective of an oil and gas production facility is to prepare the oil
and gas for pipeline (or tank truck) transport. The process line for an oil and
gas production field starts at the production well(s) and ends at the LACT unit.
As such, the process line includes: well-head(s), pumping unit(s), phase
separators, emulsion breaking equipment, water treatment equipment, gas
dehydration and compression equipment, and oil storage tanks and transfer units.
Q: Are "large sources" and "major sources" one and the same?
A: No. There is a significant difference in what these two terms mean and how
they are used. The term "large" source is new to our rules and was added in
response to the California Permit Streamlining Act in which the APCD was
required to set up criteria for processing small, medium and large sources of
pollution. Rule 102 now contains definitions for each of these three categories.
Essentially, a large source is any source with a potential to emit over 10 tons
per year of any pollutant (except for CO which is 25 tons per year). Rule 208
provides the APCD's permit streamlining timelines for small, medium and large
sources. "Major" sources, on the other hand, are defined consistent with federal
law. Being a moderate nonattainment area, our County uses 100 tons per year
(potential to emit) to classify a source as major or not. See Rule 102 for the
definition of major source.
For more information or
assistance, call the Engineering Division at (805) 961-8800, or e-mail us at
engr@sbcapcd.org.
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