Bay Area Air Quality Management District 

939 Ellis Street 

San Francisco, CA 94109 

Staff Report 

Regulation 6, Rule 2: 

Commercial Cooking Equipment

November 2007 

Prepared by: 

Virginia Lau 

Senior Air Quality Specialist 

Planning and Research Division 
Table of Contents 

I. EXECUTIVE SUMMARY ......................................................................................1

II. BACKGROUND ....................................................................................................3

A. Introduction ....................................................................................................3

B. Source Description.........................................................................................4

C. Emissions Inventory.......................................................................................5

D. Regulatory Framework...................................................................................8

III. AVAILABLE CONTROL TECHNOLOGY.............................................................9

IV. REGULATORY PROPOSAL ..............................................................................13

A. Proposed Standard for Chain-Driven Charbroilers ......................................13

B. Proposed Standard for New Under-Fired Charbroiler Installations..............14

C. Proposed Standard for Existing Under-Fired Charbroilers ..........................14

D. Administrative Requirements .......................................................................15

V. EMISSION REDUCTIONS ..................................................................................17

VI. ECONOMIC IMPACTS .......................................................................................18

A. Cost Analysis for Charbroilers .....................................................................18

C. Incremental Cost Effectiveness ...................................................................26

D. District Staff Impacts....................................................................................27

E. Socioeconomic Impacts...............................................................................28

VII. ENVIRONMENTAL IMPACTS............................................................................29

VIII. REGULATORY IMPACTS ..................................................................................29

IX. RULE DEVELOPMENT PROCESS....................................................................29

X. FUTURE RESEARCH.........................................................................................32

XI. CONCLUSION ....................................................................................................33

XII. REFERENCES....................................................................................................34

APPENDICES 

Appendix A Emission Calculations 

Appendix B South Coast Air Quality Management District’s 

Protocol’s “Determination of Particulate and Volatile 

Organic Compound Emissions from Restaurant 

Operations”, November 14, 1997 

Appendix C Responses to Comments 

Appendix D Socioeconomic Analysis 

Appendix E CEQA Analysis and Negative Declaration
1 

I. EXECUTIVE SUMMARY 

Every day in the Bay Area, commercial charbroiling operations collectively emit 

an estimated 6.9 tons of particulate matter (PM) and 1.1 tons of volatile organic 

compounds (VOC). The Bay Area and neighboring regions are not yet in 

attainment with the State one-hour and eight-hour ozone standards and 

particulate matter standards and so further reductions of VOC and PM are 

needed. 

Currently, no Bay Area Air Quality Management District (District) rule directly 

regulates emissions from restaurants. The District proposes adoption of 

Regulation 6, Rule 2 in accordance with its Senate Bill (SB) 656 Particulate 

Matter Implementation Schedule, and in connection with Further Study Measure 

(FS) 3 in the District’s 2005 Ozone Strategy, which proposes evaluation of a rule 

to control emissions from commercial charbroilers. 

The District focused its efforts on reducing emissions from two types of 

charbroilers: chain-driven charbroilers and under-fired charbroilers. Charbroilers 

are a central appliance for most restaurant kitchens and produce over 80% of 

commercial cooking emissions. 

The District investigated a variety of control options for addressing emissions 

from charbroilers. To determine a list of available control technologies, the 

District reviewed reports and studies conducted either by universities, other air 

districts, and city health departments. Regulation 6, Rule 2 will require any 

restaurant with a chain-driven charbroiler to install a catalytic oxidizer to limit 

emissions of both PM and VOC if the restaurant purchases at least 500 pounds 

of beef per week and cooks at least 400 lbs of beef per week on the charbroiler. 

Owners of restaurants that have one or more under-fired charbroilers with a total 

grill surface area of at least 10 square feet that purchase at least 1,000 pounds of 

beef per week and that cook at least 800 pounds of beef per week on the 

charbroiler will be required to install a control device certified to reduce PM 

emissions. The proposed rule will become effective one year after the rule is 

adopted for chain-driven charbroilers and two or five years for under-fired 

charbroilers, depending on whether the charbroilers were new or existing, 

respectively. The District anticipates these proposed standards will result in an 

85% reduction in PM emitted by all affected charbroilers and an 80% reduction in 

VOC emitted by chain-driven charbroilers. 

A socioeconomic analysis of the proposed regulation concludes that the new 

regulation would not have significant adverse economic effects. An initial study 

of the proposed regulation concludes that the rule would not cause significant 

adverse environmental impacts, and a CEQA negative declaration is proposed 

for adoption. 
2 

Because this regulation addresses a new source category, the District undertook 

a comprehensive public outreach program to involve in the development of the 

proposed rule all stakeholders, including individual restaurant owners, hood 

manufacturers, restaurant trade organizations and industry representatives, 

county health departments, and vendors and installers of commercial kitchen 

appliances. The District held four public workshops on November 14 and 15, 

2006, and based on public input, revised the draft proposal for presentation at a 

fifth workshop held on March 6, 2007. The draft proposal was presented before 

the Board of Directors at the May 16, 2007 public hearing. The Board directed 

District staff to conduct additional research. District staff surveyed over 400 Bay 

Area restaurants to determine charbroiler grill sizes and types and amounts of 

meats grilled. Based on analysis of the survey results, staff revised the proposed 

regulation. In addition, District staff refined its cost analysis based on further 

discussions with restaurant owners, control device manufacturers, and building 

maintenance personnel. The revised draft proposal was presented at a sixth 

public workshop on October 23, 2007, and comments received at that meeting 

and during the comment period have been incorporated into the final proposal 

and into this staff report, as appropriate. 

In addition to proposed Regulation 6, Rule 2, the District proposes amendments 

to Regulation 3, Schedule R: Equipment Registration Fees and Regulation 6: 

Particulate Matter and Visible Emissions. The amendments to Schedule R 

propose a reduction in fees for restaurants and the amendments to Regulation 6 

renumber and rename the rule. The amendments to Regulation 6: Particulate 

Matter and Visible Emissions do not have any substantive effect. 
3 

II. BACKGROUND 

A. Introduction 

Restaurants vent substantial amounts of particulate matter (PM) and volatile 

organic compounds (VOC) into the atmosphere. Every day in the Bay Area, 

commercial charbroiling operations collectively emit an estimated 6.9 tons of PM 

and 1.1 tons of VOC. 

Several California air districts have adopted rules limiting emissions from 

commercial cooking operations. The South Coast Air Quality Management 

District (SCAQMD) funded a detailed study that determined chain-driven 

charbroilers, under-fired charbroilers, and griddles generate most of the VOC and 

PM emissions from commercial cooking operations. At present, SCAQMD, the 

San Joaquin Valley Unified Air Pollution Control District, and the Ventura County 

Air Pollution Control District have each adopted a rule that limits emissions from 

restaurant charbroilers. Each of these rules requires chain-driven charbroilers to 

operate with a control device to limit the emissions of VOC and PM. 

Currently, no District rule directly regulates emissions from restaurants. The 

District proposes adoption of Regulation 6, Rule 2 to fulfill a commitment in its 

Senate Bill (SB) 656 Particulate Matter Implementation Schedule, and in 

connection with Further Study Measure (FS) 3 in the District’s 2005 Ozone 

Strategy, which proposes evaluation of a rule to control emissions from 

commercial charbroilers. 

The initial proposal was presented before the Board of Directors at the May 16, 

2007 public hearing. At the conclusion of the meeting, the Board directed District 

staff to conduct additional research. The most significant changes that have 

been incorporated into the proposed rule include: 

• A provision that defines which restaurants are subject to the proposed rule 

based on the amount of beef purchased; 

• An exemption for restaurants that do not cook on the charbroiler most 

(80%) of the beef purchased; and 

• The removal of the requirement to install listed ventilation hoods. 

The Board of Directors directed District staff to conduct additional research on 

certain questions that were raised during the public hearing. District staff 

conducted a survey of Bay Area restaurants to determine charbroiler grill sizes 

and types and amounts of meats cooked. Staff also further analyzed the costs to 

operate and maintain control technologies. This staff report incorporates the 

findings from these studies as well as revisions to the proposed rule. 
4 

B. Source Description 

Commercial cooking equipment generates grease, smoke, heat, water vapor, 

and combustion products. A typical kitchen ventilation system includes an 

exhaust hood, ductwork, and fan system that extracts heat and pollutants and 

captures grease using filters, extraction baffles, or water mist systems. The 

cooking plume rises from the cooking appliance through the filters aided by the 

suction of the exhaust fan, located in most cases on the roof of the restaurant. 

Large particulates are generally captured in the filters while additional 

particulates condense in the duct work or in the exhaust fan. 

Broilers are the central appliance for most restaurant kitchens and are used to 

cook steak, hamburgers, fish, chicken, and seafood, as well as to brown food 

and reheat plated food. All broilers are comprised of a grated grill and a heat 

source, where food resting on the grated grill cooks as the food receives heat 

either directly from the heat source, or indirectly by way of a radiant surface. 

Proposed Regulation 6, Rule 2 would regulate two types of charbroilers: chaindriven and under-fired. Figure 1 presents examples of a chain-driven charbroiler 

and an under-fired charbroiler. A chain-driven (conveyorized) charbroiler is a 

semi-enclosed broiler designed to move food mechanically on a grated grill 

through the device as the food cooks. Food cooks quickly, because chain-driven 

charbroilers have burners located both above and below the grill. Chain-driven 

charbroilers are most common in fast food restaurants. 

Figure 1. Examples of Chain-Driven Broiler (left) and Under-Fired Broiler 

(right) 

Sources: Nieco and Magikitch’n 

In an under-fired charbroiler, the heat source is positioned at or below the level of 

the grated grill. Designs of under-fired charbroilers vary widely. Some underfired broilers use charcoal or wood for fuel, but usually, the broilers are fueled by 

gas or electricity. In gas under-fired charbroilers, a radiant surface, such as a 
5 

bed of ceramic briquettes or a metal shield, placed above the burners diffuses 

heat from the burners. (See Figure 2.) The heating elements of electric 

charbroilers are often interwoven with, or sheathed inside, the grill. Under-fired 

charbroilers are common in fine dining and casual restaurants. 

Figure 2. Diagram of Under-Fired Charbroiler 

 

GRATE 

 

 

RADIANT 

 

BURNER 

 

REFLECTOR 

 

COOL 

ZONE 

 

 

Source: Vulcan-Hart Company 

C. Emissions Inventory 

Charbroilers produce air pollutants through combustion. The air pollutants are 

primarily generated from incomplete combustion of grease and meat additives, 

such as tenderizers and marinade. The air contaminants are released when 

grease and meat additives fall onto the heat source, radiant surface, or hot plate, 

or when grease flares in the drip tray or bubbles at the surface. 

The smoke and vapors generated from the process contain VOC and PM that 

consist of aldehydes, organic acids, alcohol, nitrogen and sulfur compounds, and 

polycyclic aromatic hydrocarbons (PAHs). VOC reacts with other compounds in 

the atmosphere to form ground-level ozone, commonly called smog. PM 

consists of airborne particles. PM can be emitted directly and also can be 

formed in the atmosphere through chemical reactions between other pollutants, 

including VOC. Cooking emissions include fine particles that are equal to or less 

than 10 microns in diameter, commonly referred to as PM10. PM10 generated by 

cooking appliances passes through the ventilation system and is exhausted into 

the atmosphere. Particulate matter greater than 10 microns in diameter is 

typically captured in the grease filter in the ventilation hood, and is not exhausted 

to the atmosphere. 
6 

Both VOC and PM10 present public health risks. Ozone produced from chemical 

reactions involving VOC may damage lung tissues and the respiratory tract. 

Once inhaled, PM10 may become lodged in the respiratory tract and lead to 

wheezing, nose and throat irritation, bronchitis, aggravated asthma, and lung 

damage. 

The SCAQMD and the California Air Resources Board (CARB) sponsored 

several studies in order to determine the percentage of restaurants that use 

charbroilers, the amount and type of meat cooked on charbroilers, and the 

amount of PM10 and VOC produced from meat cooked on charbroilers. The 

District relied on these research studies, and on information provided by the 

health department of each of the nine Bay Area counties, to estimate the amount 

of PM10 and VOC emitted from restaurant charbroilers in the Bay Area. A more 

detailed description of the methodology is presented in Appendix A. 

District staff estimated the number of restaurants in operation in the Bay Area 

with assistance from the health department of each county in the District. Each 

county health department provided the District with the number of restaurants 

permitted within the county. District staff refined the number of restaurants by 

eliminating the establishments that are not open to the public (e.g., private clubs, 

dormitories, and company cafeterias) because charbroiler usage would likely be 

much less than a commercial restaurant. Restaurants that have gone out of 

business, as well as those that are less likely to cook, such as, ice cream parlors 

and delicatessens were also eliminated. The District estimates that there are 

approximately 14,838 restaurants in the Bay Area. 

To estimate the number of charbroilers used in Bay Area restaurants, the District 

consulted the 1997 SCAQMD report, “Staff Recommendations Regarding 

Controlling Emissions from Restaurant Operations.” The SCAQMD report 

surveyed the type of equipment that was used in restaurant cooking operations in 

Southern California. The report found that approximately 33% of restaurants 

operate under-fired charbroilers and 3.7% operate chain-driven broilers. The 

District verified these percentages by conducting an independent survey of Bay 

Area restaurants. District staff interviewed a random sample of approximately 

400 restaurants that included fast food chains and franchises and found that the 

SCAQMD percentages are representative of the Bay Area. Based on these 

percentages, the District estimates that approximately 4,897 Bay Area 

restaurants operate under-fired charbroilers and 554 operate chain-driven 

charbroilers. 

The District used several studies to estimate the amount of meat cooked on 

restaurant charbroilers and the associated emissions. The District relied on data 

developed for CARB by the Public Research Institute pertaining to the average 

amount of meat cooked on each type of appliance. Table 1 presents the 

estimated average pounds of meat cooked per year on an individual charbroiler 

in the Bay Area. 
7 

Emission factors developed by the University of California Riverside (UCR) and 

the University of Minnesota were used to quantify average emissions from each 

type of meat cooked on under-fired charbroilers including hamburger, steaks, 

chicken with or without skin, pork, and seafood. For chain-driven charbroilers, 

emission factors for poultry, pork, and seafood were estimated from the factors 

developed for under-fired charbroilers. The estimated emissions of PM10 and 

VOC by chain-driven and under-fired broilers are presented in Table 2. 

Table 1. Estimated Average Yearly 

Pounds of Meat Cooked per Charbroiler in the Bay Area 

Type of Food Conveyorized 

Broiler (lbs/year) 

Under-Fired Broiler 

(lbs/year) 

Hamburger 41,486 14,049 

Beef Steaks 12,281 9,363 

Poultry with Skin 7,651 7,485 

Poultry without 

Skin 

13,842 9,311 

Pork 2,997 7,699 

Seafood 6,179 7,416 

TOTAL 84,436 55,323 

Source: PRI 

Table 2. Emissions from Charbroilers in the Bay Area 

Type of Food Chain-driven Broiler Under-Fired Broiler 

PM10 

(tons/day) 

VOC 

(tons/day) 

PM10 

(tons/day) 

VOC 

(tons/day) 

Hamburger 0.23 0.072 0.90 0.37 

Beef Steaks 0.069 0.021 0.60 0.25 

Poultry with Skin 0.0091 0.0061 0.10 0.092 

Poultry without Skin 0.016 0.011 0.12 0.11 

Pork 0.0036 0.0024 0.10 0.094 

Seafood 0.012 0.010 0.16 0.019 

Total Emissions 

(tons/day) 0.34 0.11 2.0 0.94 

Total Emissions 

(tons/year) 126 41 724 342 

As noted in Table 2, a significant portion of the PM10 and VOC emissions from 

charbroilers are produced from beef products such as hamburgers and beef 

steaks. Beef products account for approximately 62% of PM10 and VOC 

emissions from chain-driven charbroilers and approximately 75% of PM10 and 
8 

66% of VOC emissions from under-fired charbroilers. The Bay Area restaurant 

survey also verified that beef is the meat most commonly cooked on a 

charbroiler. The proposed rule would regulate those restaurants that purchase 

and grill a significant amount of beef because these restaurants are responsible 

for the largest share of emissions. Emission reductions were estimated 

assuming that restaurants subject to this proposed rule cook a variety of meats, 

but predominately beef. 

In addition to VOC and PM emissions, cooking operations also produce carbon 

dioxide (CO2), a gas contributing to climate change. In 2005, the District adopted 

a Climate Protection Program aimed at reducing greenhouse gas emissions. A 

University of Minnesota study found that gas charbroilers generated most of the 

CO2 emitted by cooking operations. Charbroilers generate CO2 through the 

combustion of natural gas and when grease drippings combust on hot radiant 

surfaces. The District estimates that the average CO2 emissions for cooking 

activities per restaurant are approximately 25,000 pounds of CO2 annually based 

on operation of the cooking appliances and energy usage for the associated 

ventilation system1

. 

D. Regulatory Framework 

The District is proposing Regulation 6, Rule 2, in accordance with the District’s 

SB 656 Particulate Matter Implementation Schedule and in connection with FS 3 

in the District’s 2005 Ozone Strategy, as a means to reduce restaurant emissions 

of PM and VOC in the Bay Area. VOCs are ozone precursors, and also 

contribute to indirect or secondary PM. The Bay Area is not yet in attainment of 

the State ozone and particulate matter standards, and so, further reductions of 

VOC and PM are needed. 

SB 656 requires that all air districts in California adopt an implementation 

schedule that prioritizes appropriate measures for reducing PM emissions. The 

District’s Particulate Matter Implementation Schedule, adopted in November 

2005 proposed to adopt Regulation 6, Rule 2 as a measure to reduce direct and 

indirect PM emissions in the Bay Area. 

Under FS 3, the District proposed to examine the feasibility of reducing ozone 

precursor emissions from restaurants. FS 3 is part of the District’s 2005 Ozone 

Strategy, directed towards attainment of the State one-hour ozone standard. 

Currently, no District rule directly regulates the emissions of air pollutants from 

restaurants. Restaurants, cafeterias, and other food establishments are not 

required to obtain a permit to operate under the District’s Regulation 2, Rule 1. 

Nevertheless, restaurants must comply with the District’s regulations of general 

 

1

 Energy usage only accounts for the energy required to operate the cooking appliances and 

associated ventilation system. It does not include the energy required to power the air 

conditioning and heating systems, refrigeration units, make-up air, lights, and other types of 

equipment. 
9 

applicability, such as Regulation 6: Particular Matter and Visible Emissions, and 

Regulation 7: Odorous Substances 2 . Regulation 6 sets limitations on the 

emissions of particulate matter. Regulation 7 restricts the discharge of odorous 

substances. 

Bay Area restaurants are issued permits to operate by county health 

departments and in some cases, city health departments. The health 

departments require restaurants to adhere to California building codes, fire 

protection codes, and retail food laws. These codes require restaurants to install 

an exhaust ventilation hood with a fire suppression system above commercial 

cooking equipment that generates grease, smoke, steam, and vapor. The health 

departments also monitor the handling of food and ensure that all of the grease 

traps and hood filters are routinely cleaned. 

At present, the SCAQMD, San Joaquin Valley Unified Air Pollution Control 

District, and Ventura County Air Pollution Control District have each adopted a 

rule that limits emissions from restaurant charbroilers. These rules each require 

that chain-driven charbroilers be operated with a control device to limit emissions 

of VOC and PM. 

In addition, the City of Aspen Environmental Health Department has an 

ordinance regulating restaurant charbroiler emissions under Municipal Code 

Section 13.08.100: Restaurant Grills. The ordinance requires all restaurants that 

operate any charbroiler to install a control device that is certified by the 

manufacturer to reduce PM10 emissions by 90%. 

III. AVAILABLE CONTROL TECHNOLOGY 

The District considered a variety of technologies to control emissions from 

charbroilers. District staff reviewed reports and studies conducted by the UCR, 

College of Engineering, Center for Environmental Research and Technology 

(CE-CERT), on available control technologies in support of the SCAQMD 

Regulation 1138 to control emissions from chain-driven charbroilers. In addition, 

District staff contacted the City of Aspen Environmental Health Department 

regarding their ordinance regulating restaurant charbroiler emissions under 

Municipal Code Section 13.08.100: Restaurant Grills. District staff also consulted 

hood manufacturers and industry representatives. 

Available control technologies that are effective at removing either or both PM 

and VOC from charbroilers include catalytic oxidizers and thermal incinerators. 

Each of these is a reliable, proven, and commonly-used control technology. The 

District also considered wet scrubbers, electrostatic precipitators (ESPs), fiberbed filters, and high-efficiency particulate arresting (HEPA) filters as effective 

control devices for removing PM only. Other control technologies such as 

 

2

 On adoption of proposed Regulation 6, Rule 2, current Regulation 6 will be re-numbered as 

Regulation 6, Rule 1. 
10 

ultraviolet (UV) lamps and high-efficiency filters are available. The effectiveness 

of UV lamps at removing PM and VOC has not been investigated in an 

independent research study. High-efficiency filters have a significantly lower PM 

removal efficiency in comparison to the proven control technologies discussed 

below. 

Catalytic Oxidizers (flameless) 

A catalytic oxidizer is a flameless incineration device that is fitted to the top of a 

chain-driven charbroiler. Cooking exhaust is initially processed in the catalytic 

oxidizer through the heat exchanger where air is introduced. The air mixture 

then enters a flameless combustion chamber where it is evenly distributed onto 

the catalyst bed to ensure complete mixing of PM and VOC with oxygen. The 

PM and VOC oxidize into carbon dioxide and water vapor once the mixture 

reaches the combustion temperature. The released combustion energy is 

absorbed by the catalyst bed and is transferred to the heat recovery system. The 

control device is activated by the heat of the charbroiler and does not require any 

additional fuel to operate. The catalyst, which is a metal alloy, covers a substrate, 

typically either a honeycombed ceramic or a bed of ceramic beads housed in a 

canister. (See Figure 3.) 

Figure 3. Catalytic Oxidizers Canisters 

 

 Source: W.R. Grace and Company 

The catalyst is cleaned by immersion in water for one hour per month. Testing 

has shown catalytic oxidizers are capable of an overall PM and VOC removal 

efficiency of approximately 85% (83% for PM and 86% for VOC). Catalytic 

oxidizers are highly effective and virtually maintenance-free control devices for 

chain-driven charbroilers. However, this technology is not used to control 

emissions from under-fired charbroilers because the temperature at which the 

catalyst operates would require significant energy usage. Control equipment for 

under-fired charbroilers is mounted in the exhaust system, not on the broiler. 
11 

Thermal Incineration 

Thermal incineration oxidizes PM and VOC from an air stream at high 

temperatures, converting them into carbon dioxide and water. Thermal 

incinerators are not commonly used in commercial cooking applications. There 

are two types of thermal incinerators, recuperative and regenerative. Thermal 

recuperative incinerators consist of a gas preheating section (heat exchanger), a 

combustion chamber typically equipped with gas burner(s), and a heat recovery 

section. The heat exchanger is used to preheat the exhaust stream prior to 

combustion and may be used to recover heat to generate steam. 

Regenerative incinerators use direct contact with a high-density medium such as 

a ceramic-packed bed or catalyst bed for heat recovery and to preheat the 

exhaust stream. Preheated PM and VOC enters the combustion chamber where 

they are converted to carbon dioxide and water. Cleaned gases are then 

diverted to reheat the packed beds. PM and VOC removal efficiency is 

dependent upon temperature, residence time, and mixing inside the incinerator. 

PM and VOC conversion efficiencies typically range from 97% to 99.9% for 

recuperative incineration and 95% to 99% for regenerative incinerators. 

Thermal incinerators may be used as a control device for both chain-driven and 

under-fired charbroilers. 

Fiber-Bed Filters 

Fiber-bed filters may be used as stand-alone control devices or in conjunction 

with another control device such as a wet scrubber. Fiber-bed filters use a 

combination of impaction, interception and Brownian diffusion to remove 

particulate matter from an air stream. Particulates become trapped in the fibers 

of the filter and eventually drain into a capture area below the filter as illustrated 

in Figure 4. The filter bed may be made of fiberglass, polyester, polypropylene, 

or ceramic, depending on the PM concentration, exhaust flow, and temperature 

of the air stream. 

Figure 4. Operation of Typical Fiber-Bed Filters 

 Source: Kimre, Inc. 
12 

Periodically the filters must be replaced or washed to remove grease and other 

materials before returning to service. Fiber-bed filters have an overall PM 

removal efficiency of 90%. Filter-bed technology has been successfully used on 

chain-driven charbroilers in Southern California; however, they are not used in 

restaurants that operate under-fired charbroilers and thus, the costs for installing 

and maintaining the control device are not included for under-fired charbroilers. 

Electrostatic Precipitators 

Electrostatic precipitators (ESPs) have a proven track record of removing PM 

from the gas streams of many industries. An ESP functions by screening out 

large PM with a pre-filter, and then imparting an electrostatic charge in the 

remaining exhaust particles with a high voltage direct current. The charged 

particles then attach to an oppositely charged plate, from which they are later 

removed. An after filter is occasionally used after the plates to restore a positive 

back-pressure and ensure good gas distribution. 

The PM removal efficiencies of ESPs range from 90% to 99%. The removal 

efficiencies depend largely on whether the ESPs are frequently and properly 

cleaned. ESPs are effective control devices for either chain-driven charbroilers 

or under-fired charbroilers. 

Wet Scrubbers 

Wet scrubbers use a finely atomized stream of water to remove PM from an air 

stream. An exhaust stream flows upward through a series of grated 

impingement plates. Water is introduced from the top of the wet scrubber and 

flows down to each successive plate, counter to the exhaust flow. The cooking 

exhaust rises through the grated grills and cools once it contacts the water. The 

particles adhere to the water droplets which are then collected as liquid waste. 

The liquid waste collected at the bottom of the scrubbers requires either 

treatment for reuse or disposal. Liquid particles entrained in the exhaust gas 

leaving the scrubber are removed using an after filter. PM removal efficiencies 

of 90% to 99% have been achieved depending on particle size, load, flows, and 

pressure drop. Wet scrubbers may be used as a control device for either the 

chain-driven or under-fired charbroiler. 

HEPA Filters 

HEPA filters are comprised of a series of three (3) filters designed to capture 

successively finer particles sizes. The first filter is called a pre-filter, which is a 

fully disposable pleated filter that must be replaced every four (4) weeks. The 

second filter is a medium filter that is a fully disposable bag filter that is replaced 

every eight (8) weeks. The final filter is a fully disposable 12 inch HEPA filter that 

is replaced every six (6) months. The PM removal efficiencies of HEPA filters 
13 

varies from 95% to 99%. HEPA filters have been exclusively used at restaurants 

that operate under-fired charbroilers. Because there are more inexpensive 

control options available, restaurants with chain-driven charbroilers have not 

installed this control device. 

IV. REGULATORY PROPOSAL 

Under proposed Regulation 6, Rule 2: Commercial Cooking Equipment, the 

District is seeking to achieve further reductions of VOC and PM by requiring 

controls for under-fired and chain-driven charbroiler emissions. This chapter 

describes the proposed standards in Regulation 6, Rule 2. 

A. Proposed Standard for Chain-Driven Charbroilers 

Based on studies conducted by the UCR CE-CERT (1997), chain-driven 

charbroilers account for 4% of restaurant PM emissions and 13% of VOC 

emissions. Proposed Regulation 6, Rule 2 requires that, within one year of 

adoption of the rule, those owners of restaurants that have chain-driven 

charbroilers and that purchase 500 pounds (lbs.) or more of beef per week would 

be required to install and operate a District-approved catalytic oxidizer or other 

certified control. Restaurants that demonstrate, through meat purchase invoices 

or other documentation, that they cook less than 400 lbs. of beef per week on 

their charbroilers would be exempt from this proposed rule. 

Currently, three California air districts regulate chain-driven charbroiler 

emissions: SCAQMD, San Joaquin Valley Unified Air Pollution Control District, 

and Ventura County Air Pollution Control District. Each of these air districts 

requires chain-driven charbroilers to be equipped and operated with a catalytic 

oxidizer or equivalent control. As a result, the catalytic oxidizer has an 

established track record and has been proven capable of reliably reducing chaindriven charbroiler emissions of PM10 by 83% and VOC by 86%. The South 

Coast AQMD has already approved catalytic oxidizers from a variety of 

manufacturers to meet the same emissions standard as included in proposed 

Regulation 6, Rule 2; the devices SCAQMD has already approved at the time of 

this writing will be approved for use in the Bay Area. A manufacturer of a new 

catalytic oxidizer will be required to test and certify the equipment according to 

the protocol SCAQMD established, attached to this staff report as Appendix B. 

The proposed rule allows a restaurant operator the flexibility to install an 

alternative control device, provided the device has been certified by the 

manufacturer to reduce emissions to no more than 0.74 lbs. of PM10 per 1,000 

lbs. of beef cooked. Alternative controls, such as electrostatic precipitators, are 

capable of achieving a higher PM10 removal efficiency, but at greater cost, than a 

catalytic oxidizer. In some cases, other controls have already been installed on 

District restaurants. The manufacturer is required to have an independent 

laboratory perform the certification test, in accordance with specific procedures 

prescribed in the rule, to determine the ability of the control to meet the emission 
14 

standards the rule requires. 

B. Proposed Standard for New Under-Fired Charbroiler Installations 

Under-fired charbroilers account for 82% of PM emissions generated by 

restaurants, according to the 1997 University of California, Riverside study. The 

focus of the proposed rule for newly-installed under-fired charbroilers is to reduce 

emissions from high-production restaurants that cook large quantities of beef on 

under-fired charbroilers and, consequently, are responsible for a large portion of 

the emissions. Effective January 1, 2010, the proposal calls for any owner or 

operator of any restaurant that contains one or more new under-fired charbroilers 

that have a total of at least 10 square feet of grill surface area and that purchases 

1,000 lbs. of beef or more per week, to exhaust the restaurant’s charbroiler 

emissions through a certified control device. The control device must be certified 

by the manufacturer to limit emissions to no more than 1.0 lbs. of PM10 per 1,000 

lbs. of beef cooked, as measured by the test method set out in section 603 of the 

proposed rule. Any restaurant that demonstrates that it grills less than 800 lbs. of 

beef per week on its charbroiler(s) would be exempt. 

The rule recognizes that effective control equipment that meets these emission 

standards requires planning to install. Newly constructed restaurants can 

integrate the installation of the controls into their ventilation system to effectively 

reduce emissions. Owners of an existing restaurant who choose to install new 

under-fired charbroiler(s) in the restaurant and thereby become subject to the 

rule will have to install an approved control device. Alternatively, the restaurant 

owner may elect to install cooking equipment other than an under-fired 

charbroiler, such as a clamshell griddle or over-fired charbroiler, that emits much 

less PM than an under-fired charbroiler, and consequently, is not subject to the 

regulation. Cooking appliances such as clamshell griddles and over-fired 

charbroilers have the added benefit of using less energy than under-fired 

charbroilers. 

C. Proposed Standard for Existing Under-Fired Charbroilers 

Approximately 82% of Bay Area PM emissions from commercial cooking are 

attributable to the approximately 5,000 under-fired charbroilers in use in the Bay 

Area. PM emissions from already-existing under-fired charbroilers can be 

reduced by 14% (up to 0.28 tpd) by regulating the highest emitting restaurants 

(approximately the top 4%) that operate under-fired charbroilers. 

Five years after rule adoption, January 1, 2013, the proposed rule will require all 

restaurants that have one or more under-fired charbroilers with an aggregate grill 

surface area of 10 square feet or more and that purchase 1,000 lbs of beef or 

more per week to install control technology certified to emit no more than 1.0 lbs. 

of PM10 per 1,000 lbs. of beef cooked, as measured by the test method set out in 

section 603 of the proposed rule. This will reduce PM10 emissions from these 

restaurants by 90%. Any restaurant that demonstrates that it grills less than 800 

lbs. of beef per week would be exempt. 
15 

Current control technologies are available that can be retrofitted into existing 

restaurants. However, some restaurants may require remodeling, additional 

plumbing, or additional structural support in order to install and operate currently 

available control devices. As a result, an extended implementation date for 

existing under-fired charbroilers is proposed to allow adequate time for restaurant 

owners to plan, obtain the necessary building permits, purchase, and install the 

control. 

D. Administrative Requirements 

Chain-Driven Charbroilers 

All operators of chain-driven charbroilers that are subject to this proposed rule 

will be required to register the charbroiler and control device with the District. 

The District will implement a web-based registration system to simplify the 

registration process. Controls that have been certified for use in the South Coast 

will be approved and listed on the District web site as well as new, Districtcertified catalytic oxidizers. Restaurant owners will be assessed an initial 

registration fee and recurring annual fee to recover the District’s costs of 

administering and enforcing the proposed rule. The proposed initial registration 

fee is $360 and the proposed annual fee is $100. The fees are to be adopted as 

part of the proposed amendments to Regulation 3: Fees. 

The proposed rule also has a recordkeeping provision that requires owners and 

operators to record the date of installation of, and any maintenance and repairs 

performed on, the control device. The repair logs will contain the date, time, and 

description of the work that was performed. The owner or operator must keep 

the records for at least five years. The purpose of this recordkeeping 

requirement is to ensure that the control is operated in accordance with the 

manufacturer’s specifications. 

Under-Fired Charbroilers 

An operator of a restaurant with one or more under-fired charbroiler(s) that is 

subject to this proposed rule will be required to register the under-fired 

charbroiler(s) and the control device. Restaurant owners will be assessed an 

initial registration fee, followed by a recurring annual fee to recover the District’s 

costs of administering and enforcing the proposed rule. The proposed 

registration fee is $360 and the proposed annual fee is $100, consistent with the 

fees for chain-driven charbroilers. The fees are to be adopted as part of the 

proposed amendments to Regulation 3: Fees. 

The proposed rule requires that owners and/or operators of restaurants subject 

to the rule must keep records for not less than five years. The records must 

include date of installation of any control device operated to comply with the rule 

and records of any maintenance or repairs performed on the control device. The 
16 

maintenance and repair records must contain the date, time, and description of 

the work that was performed. The purpose of this recordkeeping requirement is 

to ensure that the control is operated in accordance with the manufacturer’s 

specifications. 

Certification of Control Equipment 

The manufacturer of an emission control device must contract an independent 

laboratory to perform a test, in accordance with specific procedures prescribed in 

the rule, to certify the ability of the control to meet the relevant emission 

standards in the rule. The manufacturer is required to submit to the District an 

application containing a complete source test report along with information 

describing the control and to certify that the device meets the emissions 

requirements.

The proposed rule requires the certification tests for all devices controlling 

emissions from under-fired charbroilers and for controls other than catalytic 

oxidizers for chain-driven charbroilers to performed according to the protocol set 

out in proposed section 6-2-603 and -602, respectively. The test protocol are 

intended to measure PM10, excluding condensable vapors. 

The proposed sections 6-2-602 and -603 protocols employ EPA Method 5, which 

measures total particulate, and not PM10 as such; however, the protocol are 

designed so that the vast majority of PM in the effluent stream that reaches the 

EPA Method 5 sampling train will be PM10. 

According to the CE-CERT study, “Further Development of Emission Test 

Methods and Development of Emission Factors for Various Commercial Cooking 

Operations” (1997), particulate matter greater than 10 microns in size is generally 

not emitted into the atmosphere, because the standard baffle filters installed in 

restaurant kitchen ventilation systems capture particles greater than 10 microns 

in size, termed coarse particulate. The CE-CERT study showed that the 

particulate matter that passed through the baffle filter was all PM10. Likewise, the 

effluent stream that will reach the EPA Method 5 sampling train under the 

proposed sections 6-2-602 and -603 protocol will consist of particulates less than 

10 microns in diameter because the test protocol requires that the test effluent 

stream pass through a baffle filter. 

In addition, the testing protocol set out in sections 602 and 603 of the proposed 

rule are intended to exclude condensable vapors from measurement. Emissions 

from charbroiling include particulate matter and compounds that condense into 

particulate matter as they cool. These latter compounds are termed condensable 

vapors, and are included in the definition of total PM10. As condensable vapors 

leave the very hot surface of a charbroiler, they cool and condense into PM. 

Some condensable vapors condense prior to being exhausted into the 

atmosphere; much does not. A control device that does not oxidize emissions, 
17 

such as an electrostatic precipitator or a HEPA filter, will remove only the vapors 

that condense prior to reaching the control device. The test method set out in 

sections 602 and 603 of the proposed rule, which provide the standards for 

certification testing of control devices other than catalytic oxidizers for use with 

charbroilers, measures only particles captured by, and condensable vapors that 

condense onto, the particulate filters used in the front half of the EPA Method 5 

test. As a result, the test methods set out in sections 602 and 603 of the 

proposed rule are designed to measure the particulate matter, including 

condensable particulate, that the control device could be expected to collect. 

V. EMISSION REDUCTIONS 

Charbroilers produce PM and VOC through incomplete combustion of 

tenderizers, marinade, and fats in the meat cooked. The District estimates that 

chain-driven charbroilers in the Bay Area emit a total of 0.34 tons per day (tpd) of 

PM and 0.11 tpd of VOC. Under-fired charbroilers, which produce significantly 

more emissions and outnumber chain-driven charbroilers by roughly a ten to one 

ratio, collectively emit approximately 2.0 tpd of PM and 0.94 tpd of VOC in the 

Bay Area. Cooking beef produces approximately 62% of the particulate 

emissions from chain-driven charbroilers and 75% of the particulate emissions 

from under-fired charbroilers because it represents the bulk of the meat cooked 

on these appliances and has about three times the emission rate of chicken, 

pork, or seafood. A more detailed discussion of the emissions estimates is 

presented in Appendix A. 

Chain-Driven Charbroilers 

The proposed standards for chain-driven charbroilers will become effective on 

January 1, 2009. Based on Bay Area restaurant survey, it is estimated that 

approximately 80% of all chain-driven charbroilers will be subject to this proposed 

rule; the remaining 20% of restaurants with chain-driven charbroilers either do 

not purchase over 500 lbs of beef per week or cook less than 400 lbs of beef per 

week on the charbroiler. The restaurants subject to this proposed rule emit 93% 

of the PM and VOC emissions from chain-driven charbroilers. The installation of 

control equipment is anticipated to reduce emissions of PM from these chaindriven charbroilers by 83% (0.27 tpd) and of VOC by 86% (0.091 tpd). 

Laboratory testing (UCR, 2002) conducted on catalytic oxidizers has verified that 

the control devices are capable of achieving these emission reductions. 

New Under-Fired Charbroilers 

The proposed standards for new installations of large under-fired charbroilers will 

become effective on January 1, 2010. Based on data provided by the county 

health departments, about 25 restaurants per year (about 0.5% of all permitted 

restaurants with under-fired charbroilers) will become subject to the requirements 

of this rule due to remodeling or new construction. Each year, these new 
18 

installations will add an additional 0.010 tons of PM production per day that will 

be subject to the requirements of the rule. The proposed rule would reduce PM 

emissions from these new installations by 90% (0.009 tpd). 

Existing Under-Fired Charbroilers 

The District estimates that there are currently 489 restaurants in the District 

operating one or more under-fired charbroilers with a total grill surface area of at 

least 10 square feet. The District estimates that approximately 40% of these 

restaurants (about 200 restaurants) purchase at least 1,000 lbs of beef per week, 

and grill at least 800 lbs of beef per week. These restaurants emit 16% of the 

total PM emissions from under-fired charbroilers, or 0.32 tpd. Effective January 

1, 2013, the rule is anticipated to reduce total PM emissions from under-fired 

charbroilers by 14% (0.28 tpd) (90% from affected under-fired charbroilers). The 

remaining emissions, approximately 1.7 tpd of PM, are produced from the 4,700 

restaurants that currently operate under-fired charbroilers, but are not subject to 

this proposed rule. 

Table 3 presents emissions and emission reductions for charbroilers subject to 

the proposed rule. 

Table 3. Emission Reductions from Charbroilers Subject to Proposed Rule 

Type of 

Charbroiler 

Uncontrolled 

PM10 Emissions 

(tpd) 

PM10

Emission 

Reduction 

(tpd) 

Uncontrolled 

VOC Emissions 

(tpd) 

VOC Emission 

Reduction 

(tpd) 

Chain-Driven 

Charbroilers 0.32 0.27 0.10 0.091 

Existing 

Under-Fired 

Charbroilers 

0.32 0.28 0.15 --- 

TOTAL 0.64 0.55 0.25 0.091 

New UnderFired 

Charbroilers* 

0.010 0.009 0.005 --- 

* Note: New under-fired charbroilers estimated to increase at a rate of 10% per year. 

VI. ECONOMIC IMPACTS 

This section discusses the estimated costs associated with the proposed rule. 

A. Cost Analysis for Charbroilers 

The District investigated the technical feasibility, potential emission reductions, 

and costs of installing and operating the control strategies identified in Section III. 

The total annual costs for a control technology are calculated based on a ten 

year period and are comprised of the annualized capital costs and the annual 
19 

recurring operation and maintenance (O&M) costs. 

The District estimated capital costs using the capital recovery method, which 

accounts for depreciation and interest (i.e., inflation) costs over the useful life of 

the control. The District annualized the capital costs using the following equation: 

Total Annualized Cost = (Capital Recovery Factor)×(Capital Expenditure) + Annual O & M Costs 

Where: 

Capital Expenditure is the equipment and installation costs 

Capital Recovery Factor is 14.2% (7% per year over 10 years) 

Annual O&M Costs are expenditures for utilities and equipment 

maintenance 

The annual recurring O&M cost includes expenditures for cleaning the equipment 

and the duct work. 

District staff also estimated a control technology’s cost effectiveness by summing 

the total annual costs for the control technology installed at restaurants and 

dividing that sum by the total annual PM and VOC emissions reductions to be 

achieved. 

Chain-driven Charbroilers 

Costs associated with control devices for chain-driven charbroilers were derived 

from the SCAQMD Staff Report for Proposed Rule 1138 (1997) and San Joaquin 

Valley Unified Air Pollution Control District Draft Staff Report for Commercial 

Charbroiling (2001). The District verified and adjusted costs to 2007 dollars. 

Table 4 presents a summary of the total annual cost for installing and maintaining 

the equipment and Table 5 presents the cost-effectiveness. Because catalytic 

oxidizers have been designed to work with chain-driven charbroilers and are 

certified for use in other districts, and because of their low costs relative to other 

controls, is the District expects that restaurants with chain-driven charbroilers will 

install catalytic oxidizers. 

Catalytic Oxidizers 

Capital Costs: Manufacturers sell a catalytic oxidizer at a cost ranging from 

$1,500 to $4,700. For this analysis, the capital cost was assumed to be $9,000 

for a new chain-driven charbroiler equipped with a catalytic oxidizer that includes 

costs for installing the control, initial catalyst, and replacement catalyst after 5 

years ($4,000). The cost would essentially be the same if an existing broiler was 

retrofitted with a catalytic oxidizer. Installation of the equipment was assumed to 

be $1,000, although typical installation costs ranges from $500 to $1,000. 

Operating Costs: Annual O&M costs of cleaning the catalyst are expected to be 
20 

$750, which includes monthly cleaning of the catalyst and the cost of cleaning 

the exhaust stack once a year. Cost savings associated with less frequent 

cleaning of the grease traps were not included in this cost estimate. The 

anticipated lifetime of the catalytic oxidizer is seven to eleven years with proper 

maintenance. 

The total annualized cost of installing a catalytic oxidizer, including O&M, is 

$2,028 (see Table 5). Based on the estimates of 0.34 tpd of PM emissions and 

0.11 tpd of VOC emissions (Table 3) from chain-driven charbroilers, it is 

expected that 0.27 tpd of PM and 0.091 tpd of VOC (132 tons per year) emission 

reductions can be achieved by installing a catalytic oxidizer, assuming an 83% 

removal efficiency for PM and 86% removal efficiency for VOC. The costeffectiveness to reduce emissions from all chain-driven charbroilers in the Bay 

Area is $6,837 per ton of PM and VOC reduced. 

Wet Scrubbers 

Capital Costs: A wet scrubber unit has a capital cost of $27,025 that includes an 

estimated installation cost of $2,000. The unit contains all the components and 

accessories to operate at 2,000 cfm, including surfactant feeder, controller, 

remote start/stop control, re-circulation pump, valves, and exhaust blower. 

Operating Costs: Annual O & M costs are anticipated to not exceed $2,000. 

O&M includes the energy cost for operating the controller and exhaust blower as 

well as the monthly expense of purchasing non-foaming surfactants detergent. 

The total annualized cost of installing this control, including O&M, is $5,838. PM 

removal efficiencies of 90% or higher have been achieved at restaurants in which 

wet scrubbers were installed as the control device. Based on the estimates of 

0.34 tpd of PM emissions, it is expected that 0.29 tpd of PM emission reductions 

can be achieved. The cost-effectiveness to reduce emissions from a chaindriven charbroiler by installing a wet scrubber is $24,558 per ton of PM reduced. 

Electrostatic Precipitators 

Capital Costs: Manufacturers provided a range of costs for a double pass 

electrostatic precipitator (ESP) with ducting, exhaust fan, and one set of 

replacement plates: $20,000 for a ventilation rate of 2,000 cfm to $40,000 for a 

ventilation rate of 5,000 cfm. The District assumed a cost of $20,000 for an ESP 

that operates at a ventilation rate of 2,000 cfm, which is sufficient ventilation for 

single chain-driven charbroiler unit. The District also included additional costs for 

installing optional equipment designed to enhance the performance and 

operation of the electrostatic precipitator and reduce the overall maintenance 

costs: 

• First pass autowash module, including timer, to automatically wash the 

plates - $4,000 
21 

• Outdoor weather package to insulate and weatherproof the unit if it is 

installed on the roof of the restaurant - $4,000 

• Advanced hood filters in the hood system that capture 55% to 60% of the 

large particles and consequently reduces the cleaning frequency of the 

plates - $1,500. 

A hot water line, drain, and wiring to the timer would be installed to support the 

automatic wash system at a cost of $7,500. The total capital cost for installing 

the ESP with automatic wash is estimated at $37,000. This cost is relatively high 

based on the additional options that were included in the cost estimate. 

Restaurants may purchase a single pass electrostatic precipitator without any 

additional enhancements for about $20,000. 

Operating Costs: Annual O&M costs are anticipated not to exceed $1,480. The 

ESP unit itself uses minimal energy, equivalent to that used by a 60 watt light 

bulb. However, industry representatives have stated that O & M costs will vary 

depending on the options that are installed in the unit at the time of purchase. 

A self-cleaning ESP with automatic water wash requires some additional cleaning 

of the plates and inside housing to ensure optimal performance. The automatic 

washing unit requires approximately one (1) gallon of detergent for each plate 

per week at a cost ranging from $9 to $18 per gallon. If the automatic wash cycle 

is not installed, then one to two gallons of detergent is sufficient to soak and 

clean the plates per month. 

A restaurant owner can either contract with a cleaning service or perform the 

maintenance and cleaning of the ESP themselves. A cleaning service will 

remove the first pass of plates; insert clean plates; soak, clean, and store the 

used plates; and power-wash the housing of the ESP using manufacturer’s 

approved detergent, at a cost ranging from $303 to $920 per month. 

Restaurants that choose to clean the ESP themselves, may soak the plates 

overnight and install a second set of plates while the first set is being washed for 

a cost of $123 per month, which includes the cost of the detergent for the 

autowash unit. If the restaurant opts to install more efficient hood filters, then the 

cleaning frequency and, thus, the cost of cleaning, can be reduced by half. 

Restaurant owners may also purchase optional odor control units that will 

increase the cost of the unit by at least $1,000 and the operating cost by at least 

$10,000 per year. For this assessment, staff estimated costs for operating a 

double pass electrostatic precipitator without an odor control unit where the 

plates are cleaned in-house and advanced hood filters have been installed. 

The total annualized cost of installing this control, including O&M, is $6,734. An 

ESP has a 90% collection efficiency for PM. It is expected that 0.29 tpd of PM 

(total of 105 tons per year) emission reductions can be achieved. The cost-
22 

effectiveness to reduce emissions by installing an ESP for a chain-driven 

charbroiler is $28,329 per ton of PM reduced. 

Fiber-Bed Filters 

Capital Costs: Fiber bed filter systems have a capital cost of $25,000 with an 

estimated installation cost of $2,500. 

Operating Costs: Annual O&M costs of replacing the filter ($3.18 per cubic feet 

per minute flow) and utility costs for operating the equipment are $7,500. 

The total annualized cost of installing this control, including O&M, is $11,405. 

The filters are capable of removing 90% of PM emissions. Based on the 

estimates of 0.34 tpd of PM emissions, it is expected that 0.29 tpd of PM (total of 

105 tons per year) emission reductions can be achieved. The cost-effectiveness 

to reduce emissions by installing fiber-bed filters for a chain-driven charbroiler is 

$47,980 per ton of PM reduced. 

Thermal or Direct-fired Incineration 

Capital Costs: Manufacturers estimated a cost of $25,000 for the incineration 

unit plus an additional $6,350 for the installation. 

Operating Costs: The unit requires 26 therms of natural gas per hour to operate. 

Using a rate of $0.63 cents per therm and assuming 16 hours of operation for 

365 days per year, the annual O & M cost is $95,659. 

The total annualized cost of installing this control including O & M is $100,111. 

PM and VOC removal efficiencies range from 95% to 99.9% depending upon the 

temperature, residence time, and mixing inside the incinerator. Assuming a 

removal efficiency of 95%, a total PM and VOC emission reduction of 0.40 tpd 

(148 tons per year) is expected. The cost-effectiveness is approximately 

$303,761 per ton of PM and VOC reduced from a chain-driven charbroiler. 
23 

Table 4. Annual Cost for Controls on Chain-driven Charbroilers 

Control for 

Chain-driven 

Charbroiler 

Capital Cost 

for Equipment 

and 

Installation 

(Dollars) 

Annualized 

Capital Cost 

(Dollars per 

year) 

Annual 

Recurring O&M 

Costs 

(Dollars per 

year) 

Total Annual 

Cost 

(Dollars per 

year over 10 

years) 

Catalytic 

Oxidizer $9,000 $1,278 $750 $2,028 

Wet Scrubber $27,025 $3,838 $2,000 $5,838 

Electrostatic 

Precipitators $37,000 $5,254 $1,480 $6,734 

Fiber Bed Filters $27,500 $3,905 $7,500 $11,405 

Thermal 

Incinerator $31,350 $4,452 $95,659 $100,111 

Table 5. Cost Effectiveness of Potential Controls on Chain-driven 

Charbroilers 

Control for 

Chain-driven 

Charbroiler 

Total Annual 

Cost (Dollars 

per year over 

10 years) 

Total PM and 

VOC Emission 

Reduction 

(Tons per year) 

Number of 

Chain-Driven 

Charbroilers 

CostEffectiveness 

(Dollars per ton 

of VOC and PM 

removed) 

Catalytic 

Oxidizer $2,028 132 443 $6,837 

Wet Scrubber $5,838 105 443 $24,558 

Electrostatic 

Precipitators $6,734 105 443 $28,329 

Fiber Bed Filters $11,405 105 443 $47,980 

Thermal 

Incinerator $100,111 148 443 $303,761 

Under-fired Charbroilers 

As described in Section III, the District evaluated the technical feasibility, 

potential emission reductions, and costs of installing an ESP, thermal incinerator, 

wet scrubber, or HEPA filter to control particulate matter emissions from underfired charbroilers. Table 6 presents a summary of the total annual cost for 

installing and maintaining the equipment, and Table 7 presents the costeffectiveness. Catalytic oxidizers, designed to fit directly on top of a chain-driven 

charbroiler, have not been developed for under-fired charbroilers. The currently 

available control options for an under-fired charbroiler are more expensive 

although under-fired charbroilers produce more emissions. For this reason, the 

proposal to control under-fired charbroilers is focused on restaurants with large 

grills (equal to or greater than 10 square feet) that purchase 1000 lbs. of beef per 

week rather than 500 and grills 800 lbs. of beef per week. 
24 

HEPA Filters 

Capital Costs: HEPA filters have a capital cost of $35,000 for a 3,000 cfm unit 

and an estimated installation cost of $2,000. 

Operating Costs: The annual O&M costs are anticipated to not exceed $3,000. 

HEPA filter units use a filter module that consists of three filters placed in series. 

The first filter is called a pre-filter that is fully disposable pleated filter that cost $6 

per filter and must be replaced every four (4) weeks. The second filter is a 

medium filter that is a fully disposable bag filter that cost approximately $10 per 

filter and is replaced every eight (8) weeks. The final filter is a fully disposable 12 

inch HEPA filter that costs $200 per filter and is replaced every six (6) months. 

The total annualized cost of installing this control, including O&M, is $8,254. It 

is expected that 95% of PM may be captured using this control device. Based on 

estimate of 0.31 tpd of PM emissions from restaurants affected by the proposal, 

the PM emission reduction is anticipated to be 0.29 tpd (total of 107 tons per 

year). The cost-effectiveness to reduce emissions by installing HEPA filters to 

control an under-fired charbroiler is $17,306 per ton of PM reduced. 

Electrostatic Precipitators 

Capital Costs: Manufacturers provided a range of costs for a double pass 

electrostatic precipitator (ESP) with ducting and exhaust fan of $20,000 for a 

ventilation rate of 2,000 cfm to $40,152 for a ventilation rate of 5,000 cfm. For 

this assessment of the costs to control an under-fired charbroiler, a maximum 

ventilation rate of 4,000 cfm was used. This ventilation rate is typical required for 

a large under-fired charbroiler. The cost of an ESP that operates at this 

ventilation rate is $27,500. Installation costs are site-specific and will vary 

depending on given local building codes. The District calculated costs for a 

4,000 cfm ESP that includes an automatic wash system, outdoor weather 

package, more efficient hood filters, plumbing for a hot water line and drain, and 

electrical wiring for the autowash system. The total capital cost is estimated to be 

$44,500. However, the cost of the electrostatic precipitator may be as low as 

$20,000, if fewer options were installed, or may be higher if the ESP must 

accommodate a higher ventilation rate. 

Operating Costs: The annual O&M cost is anticipated not to exceed $2,480. 

The ESP is assumed to be serviced in-house including cleaning and the plates 

and power-washing the housing. Detergent costs are estimated at $2,000 per 

year. For more information regarding O&M costs for an ESP, see the discussion 

of electrostatic precipitator operating costs under the heading “Chain-Driven 

Charbroilers,” above. 

The total annualized cost of installing this control, including O&M, is $8,799. 
25 

ESPs will remove 90% of PM. Based on the estimates of 0.31 tpd of PM 

emissions from restaurants subject to this rule, it is expected that 0.28 tpd of PM 

(total of 102 tons per year) emission reductions can be achieved. The costeffectiveness to reduce emissions by installing an ESP on an under-fired 

charbroiler is $19,468 per ton of PM reduced. If a restaurant chooses to contract 

with a service company for monthly cleaning of the plates and housing, the costeffectiveness can be as high as $37,847 per ton of PM removed. ESPs that are 

installed without the autowash system and are cleaned nightly by restaurant 

personnel have a cost–effectiveness of $11,899 per ton of PM. 

Wet Scrubbers 

Capital Costs: A wet scrubber unit has a capital cost of $30,452 for a system 

that operates at 3,000 cfm, and an estimated installation cost of $6,266. The 

costs include all components and accessories necessary for the complete 

operation of the unit. 

Operating Costs: The annual O&M cost is anticipated to not exceed $6,582. 

This O & M cost estimate includes the energy cost for operating the controller 

and exhaust blower, as well as the monthly expense of purchasing non-foaming 

surfactants detergent. 

The total annualized cost of installing this control including O&M is $11,796. 

Although wet scrubbers have achieved PM removal efficiencies of 90% at 

restaurants in the South Coast Air Quality Management District, wet scrubbers 

are not commonly used in restaurants located in the Bay Area. Based on the 

estimates of 0.31 tpd of PM emissions from mixed meats, it is expected that 0.28 

tpd of PM (total of 102 tons per year) emission reductions can be achieved. The 

cost-effectiveness to reduce emissions by installing a wet scrubber on an underfired charbroiler is $26,098 per ton of PM reduced. 

 

Thermal or Direct-fired Incineration 

Capital Costs: Manufacturers estimated a cost of $25,000 for the incineration 

unit plus an additional $6,350 for the installation. 

Operating Costs: The unit requires 26 therms of natural gas per hour to operate. 

Using a rate of $0.63 cents per therm and assuming 16 hours of operation for 

365 days per year, the annual O&M cost is $95,659. 

The total annualized cost of installing this control, including O&M, is $100,111. 

PM and VOC removal efficiencies range from 95% to 99.9% depending upon the 

temperature, residence time, and mixing inside the incinerator. Assuming a 

removal efficiency of 95%, a total PM and VOC emission reduction of 0.43 tpd 

(158 tons per year) is expected from restaurants subject to this proposal. The 

cost-effectiveness is approximately $142,588 per ton of PM and VOC reduced. 
26 

Table 6. Annual Cost for Controls on Under-Fired Charbroilers 

Control for 

Chain-driven 

Charbroiler 

Capital Cost 

for Equipment 

and 

Installation 

(Dollars) 

Annualized 

Capital Cost 

(Dollars per 

year) 

Annual 

Recurring O&M 

Costs 

(Dollars per 

year) 

Total Annual 

Cost 

(Dollars per 

year over 10 

years) 

HEPA Filters $37,000 $5,254 $3,000 $8,254 

Electrostatic 

Precipitators $44,500 $6,319 $2,480 $8,799 

Wet Scrubber $36,718 $5,214 $6,582 $11,796 

Thermal 

Incinerator $31,350 $4,452 $95,659 $100,111 

Table 7. Cost Effectiveness of Proposed Controls on Under-Fired 

Charbroilers 

Control for 

Chain-driven 

Charbroiler 

Total Annual 

Cost (Dollars 

per year over 

10 years) 

Total PM 

Emission 

Reduction 

(Tons per year) 

Number of 

Under-Fired 

Charbroilers* 

CostEffectiveness 

(Dollars per ton 

of VOC and PM 

removed) 

HEPA Filters $8,254 107 225 $17,306 

Electrostatic 

Precipitator $8,799 102 225 $19,468 

Wet Scrubber $11,796 102 225 $26,098 

Thermal 

Incinerator $100,111 158 225 $142,588 

*Includes 25 additional under-fired charbroilers from new construction in the first year. 

C. Incremental Cost Effectiveness 

Section 40920.6 of the California Health and Safety Code requires an air district 

to perform an incremental cost analysis for any proposed Best Available Retrofit 

Control Technology rule or feasible measure. The air district must: (1) identify 

one or more control options achieving the emission reduction objectives for the 

proposed rule, (2) determine the cost effectiveness for each option, and (3) 

calculate the incremental cost effectiveness for each option. To determine 

incremental costs, the air district must “calculate the difference in the dollar costs 

divided by the difference in the emission reduction potentials between each 

progressively more stringent potential control option as compared to the next less 

expensive control option.” 

To determine incremental costs, the District compared the cost-effectiveness of 

each control device presented in Table 5 for chain-driven charbroilers and Table 

7 for under-fired charbroilers. Table 8 presents a summary of the incremental 

cost-effectiveness associated with the proposed regulation. 
27 

As shown in Table 8, the catalytic oxidizer is the most cost-effective control 

device for chain-driven charbroiler. The cost-effectiveness of the other control 

technologies ranges from $24,558 to $303,761 per ton of PM removed. In 

addition, the catalytic oxidizer operates without an external energy supply since it 

uses the heat generated from the cooking process to activate the catalyst. The 

catalyst also radiates heat back to the charbroiler, and as a result, less energy is 

required to operate the charbroiler. Although the proposed standard essentially 

allows the use of any of the control technologies listed in Table 8, the proposed 

standard is based on the use of a catalytic oxidizer. 

For under-fired charbroilers, ESPs and HEPA filters are the most cost-effective 

control devices for controlling PM emissions. The wet scrubber is also a viable 

control option to restaurant owners given its proven control efficiencies in other 

industries. The thermal incinerator has substantially higher costs to operate. 

Table 8. Incremental Cost Effectiveness of Proposed Controls on UnderFired Charbroiler 

Type of 

Charbroiler 

Control 

Cost-Effectiveness 

(Dollars per ton of 

VOC and PM 

removed) 

Incremental Cost 

Effectiveness 

(PM only) 

Catalytic Oxidizer $6,837 $0.0 

Wet Scrubber $24,558 $17,721 

Electrostatic 

Precipitator $28,329 $21,492 

Fiber Bed Filters $47,980 $41,143 

ChainDriven 

Charbroiler 

Thermal Incinerator $303,761 $296,924 

HEPA Filters $17,306 $0.0 

Electrostatic 

Precipitator $19,468 $2,162 

Wet Scrubber $26,098 $10,049 

Under-Fired 

Charbroiler 

Thermal Incinerator $142,588 $126,539 

D. District Staff Impacts 

Currently, the District does not regulate emissions from restaurants except on a 

nuisance or smoke basis. Implementing this rule will require District resources 

from several divisions including Compliance and Enforcement, Engineering, and 

Administration. The actual personnel involved will likely involve air quality 

inspectors; an air quality technician to coordinate development of the web-based 

registration system, review registrations, and answers questions from the public; 

engineers to review the manufacturer’s certification and testing procedures; a 

program analyst to design the web-based registration and maintain the 

registration database; and an accountant to process registration and fees. 
28 

In the first year after adoption, the proposal calls for all owners and operators of 

restaurants that have chain-driven charbroilers and that purchase at least 500 

pounds of beef and cook at least 400 pounds of beef on the charbroiler to install 

a catalytic oxidizer or alternative control device certified for use under the rule. 

There are approximately 443 chain-driven charbroilers currently operating in the 

Bay Area that would be subject to this proposed rule. The District anticipates 

that an inspection should require no more than 100 minutes for each restaurant 

including drive time and paperwork. Given the number of restaurants, inspection 

time would be about 739 hours in the first year which is equivalent to 0.36 fulltime employees (FTE), at a cost of $77,040 for an air quality inspector. 

This proposal would be the first District rule to require web-based registration. In 

order to develop this system, a program analyst and an air quality engineer will 

be required to develop the registration form, maintain the registration database, 

review registrations, and respond to public inquiries. This is estimated to cost 

approximately $45,800 (0.21 FTE). Because many catalytic oxidizers have 

already been approved by the South Coast air district for control of chain-driven 

charbroilers, no more than $5,260 (0.02 FTE for a Principal Engineer) would be 

required to review manufacturers’ certifications. 

Starting two years after the rule is adopted, owners and operators of restaurants 

that have newly-installed under-fired charbroilers with a total of at least ten 

square feet of grill surface area would have to install and operate a control device 

if the restaurant purchases at least 1,000 lbs. of beef and cooks at least 800 lbs. 

of beef on the charbroiler. In five years, all restaurants with under-fired 

charbroilers totaling at least ten square feet of grill surface area that are subject 

to the proposed rule would be required to install a control device. There are 

currently 489 restaurants in the Bay Area that have under-fired charbroilers 

totaling at least 10 square feet of grill surface area. The rule would apply to 

approximately 200 of these restaurants. Inspections are anticipated to cost 

$23,219 based on 217 hours per year (0.11 FTE, Air Quality Inspector). 

Maintenance of the web-based registration system will cost $11,235 (0.05 FTE, 

Air Quality Engineer). Review of the certifications provided by control device 

manufacturers expected to cost $15,770 (120 hours or 0.06 FTE, Principal Air 

Quality Engineer). 

In total, the District is anticipated to incur a cost of approximately 0.81 FTE per 

year in the first five years to implement this proposed rule based on the estimates 

above. To recover costs, a registration fee of $360 and annual recurring fee of 

$100 is proposed. The fee schedule for restaurants in Regulation 3, Schedule R 

is proposed to be revised to reflect the current proposed Regulation 6, Rule 2. 

E. Socioeconomic Impacts 

Section 40728.5 of the Health and Safety Code requires an air district to assess 

the socioeconomic impacts of the adoption, amendment, or repeal of a rule if the 

rule is one that “will significantly affect air quality or emissions limitations.” 
29 

Applied Economic Development, Berkeley, California, has prepared a 

socioeconomic analysis. The analysis concludes that the affected restaurants 

should be able to absorb the costs of compliance with the proposed rule without 

significant economic dislocation or loss of jobs. The socioeconomic analysis is 

attached as Appendix D. 

VII. ENVIRONMENTAL IMPACTS 

Pursuant to the California Environmental Quality Act, the District has had an 

initial study for the proposed amendments prepared by Environmental Audit, Inc. 

The initial study concludes that there are no potential significant adverse 

environmental impacts associated with the proposed amendments. A negative 

declaration is proposed for adoption by the District Board of Directors. The initial 

study and negative declaration will be circulated for public comment. 

VIII. REGULATORY IMPACTS 

Section 40727.2 of the Health and Safety Code requires an air district, in 

adopting, amending, or repealing an air district regulation, to identify existing 

federal and district air pollution control requirements for the equipment or source 

type affected by the proposed change in district rules. The district must then 

note any differences between these existing requirements and the requirements 

imposed by the proposed change. 

Adoption of this rule would not conflict with any existing federal or District 

requirement. Under the federal air pollution requirements, there is no rule that 

limits emissions from restaurants. The District also does not have any rules that 

are applicable to restaurants except those of general applicability such as 

Regulation 1, Section 301: Public Nuisance and Regulation 6: Particulate Matter. 

IX. RULE DEVELOPMENT PROCESS 

District staff has undertaken a comprehensive public outreach program to involve 

all stakeholders in developing this proposal, including individual restaurant 

owners, hood manufacturers, restaurant trade organizations and industry 

representatives, county health departments, and vendors and installers of 

commercial kitchen appliances. 

The District started the rule development process in January 2005. At that time, 

the District contacted the SCAQMD to receive copies of all research documents 

and staff reports that were produced in support of SCAQMD Regulation 1138. 

The District then contacted the health departments of all the counties in the 

District in March 2005 and December 2005, to request an inventory of currently 

permitted restaurants and to apprise the counties of the District’s intent to 

consider restaurant controls. The District held two meetings with county health 

officials, one on January 19, 2006, and another on July 28, 2006. The purpose 
30 

of the meetings was to discuss the current emission inventory, solicit suggestions 

for ways to control emissions, and development of a cooperative enforcement 

strategy between the District and the various counties. 

The District also initiated contacted with the Golden Gate Restaurant Association 

in February 2006 to invite their participation in the rule development process. The 

District met with representatives of the Golden Gate Restaurant Association on 

February 24, 2006, and had follow-on telephone discussions as the rule evolved. 

District staff contacted the PG&E Food Service Technology Center in San 

Ramon, California in May 2006 regarding emission factors for specific types of 

commercial cooking equipment. After conducting a site walk of their facility, 

District staff has been in continuous discussions with representatives from the 

Food Service Technology Center in developing this proposal. The Center 

represents the interests of the restaurant industry and kitchen ventilation hood 

manufacturers. The Center is also a clearing house for commercial kitchen 

equipment performance and has expertise in commercial kitchen ventilation and 

building energy efficiency. 

District staff also verified the emission inventory by conducting source tests on 

four restaurants in the Bay Area. District staff tested two restaurants that 

operated either a chain-driven charbroiler or under-fired charbroiler that 

exhausted their emissions through a control device. For comparison purposes, 

the District also collected particulate matter samples from two restaurants that 

operated either a chain-driven charbroiler or under-fired charbroiler without any 

control device. The emission estimates were used to determine emission 

standards in the proposed rule. 

In October 2006, in advance of public workshops held in November 2006, District 

staff published the draft regulation and provided a workshop report explaining the 

proposed regulation. The first draft of Regulation 6, Rule 2, and the workshop 

report were posted on the District web site and e-mailed to stakeholders on 

October 16, 2006. Simultaneous to the posting on the District web site, the 

District sent out approximately 17,000 postcards to individual restaurant owners, 

hood vendors, and installers informing them of the rule and the then-upcoming 

public workshop. The District also developed a rule summary fact sheet that was 

translated to Chinese and Spanish and made available on the District web site. 

Once the regulation was posted, the District received and responded to more 

than 20 telephone inquiries and e-mails regarding specific topics and issues 

about the draft rule and workshop report. 

The District held four (4) public workshops on November 14 and 15, 2006, in San 

Francisco, San Jose, Oakland, and Vallejo to solicit comments from public, 

members of county health departments, industry organizations, and other 

interested parties on the proposed rule. A total of approximately 20 people 
31 

attended these workshops, with most of the interested parties being hood 

manufacturers, a restaurant organization, and independent local restaurants. The 

District received written comments from hood manufacturers that were identical 

to comments provided by the restaurant organization. 

Overall, the public comments supported the standard for chain-driven 

charbroilers. Input from the first workshop raised concerns about the technical 

feasibility and costs of installing high efficiency filters, a modest control, in all 

restaurants that operate a Type I hood. There was disagreement within the 

industry regarding the effectiveness of high efficiency filters. The trade 

organization did not support the installation of controls on restaurants that utilize 

low emission cooking equipment. Another comment suggested that the rule 

would result in more energy consumption and additional greenhouse gas 

emissions. 

After the November public workshops, the District continued discussions with 

hood manufacturers and trade organizations regarding ways to revise the 

proposal. These interactions lead directly to developing a second draft of 

Regulation 6, Rule 2 to address emissions from only charbroilers. A supplement 

to the workshop report was generated to summarize the differences from the 

original proposal. The District presented the revised proposal before the 

American Society of Heating, Refrigeration, and Air-Conditioning Engineers 

(ASHRAE) Technical Committee 5.10 Kitchen Ventilation on January 27, 2007. 

The second workshop notice and revised rule were posted on the District website 

and e-mailed to all interested parties. The second workshop was held on March 

6, 2007. 

Input from the second workshop was focused primarily on removing certain 

requirements intended to promote energy efficiency and on the costeffectiveness of control technologies. One set of comments requested that the 

District lower the effective grill size from 10 square feet to six (6) square feet and 

include a provision to regulate emissions from griddles. Staff used input received 

from the second workshop to develop the final draft of the proposed regulation 

that is published as a companion to this Staff Report for comments on April 2, 

2007. 

On May 16, 2007 an initial public hearing was conducted by the Board of 

Directors on proposed Regulation 6, Rule 2. Comments and questions at the 

hearing addressed issues including: the number of restaurants with charbroilers 

larger than 10 square feet; emissions from meats other than beef; and potential 

impacts to small businesses. The District Board directed staff to do additional 

research and referred the rule to the Stationary Source Committee. 

Staff conducted a survey of Bay Area restaurants, focusing on the grill size and 

amounts and types of meats cooked on under-fired and chain-driven 

charbroilers. District inspectors interviewed a representative sample of over 400 
32 

randomly selected restaurants from all nine Bay Area counties. The survey 

verified that the grill size specified in the rule focuses control requirements on 

large, high-production restaurants that represent approximately 4% of the 

restaurants that operate an under-fired charbroiler. In addition, staff has further 

investigated emissions from various types of meats and costs to operate and 

maintain control technologies. District staff also met with representatives from 

the Golden Gate Restaurant Association on June 14, 2007 and July 25, 2007, 

and with a representative from the California Restaurant Association on August 

11, 2007. 

Based on the findings from the survey and meetings with restaurant associations, 

the proposed rule was revised to focus control requirements on those restaurants 

that purchase and grill large quantities of beef. District staff revised the proposed 

Regulation 6, Rule 2 and held a workshop on the revised proposal on October 

23, 2007. 

The District sent approximately 13,300 postcards to Bay Area restaurants to 

notify them of the revised proposal and the public workshop. Comments at the 

workshop and in subsequent letters primarily focused on questions concerning 

the certification testing procedures to demonstrate compliance with the emission 

standard. One commenter noted the lack of a testing procedure in the proposed 

rule for new catalytic oxidizers and a question was asked about how a restaurant 

would demonstrate an exemption under the proposed rule. The proposed rule 

has been restructured based on these comments such that catalytic oxidizers 

certified by the SCAQMD are acceptable for installation in the Bay Area. The 

certification testing procedures have been revised for consistency with the 

definitions and the emission standards. Compliance advisories can provide 

guidance on how to demonstrate an exemption. 

The District will continue to follow the development of cost effective control 

technologies for existing under-fired charbroilers and provide technical updates to 

the Board of Directors. 

X. FUTURE RESEARCH 

Emissions from restaurant operations currently make up over 6% of all PM10

emissions in the Bay Area. This rule is an important first step in achieving 

emission reductions from a source category that has not been regulated in the 

past. District staff is committed to working with industry representatives and to 

provide the Board of Directors with periodic updates on the development of 

control technology for under-fired charbroilers. This rule is an opportunity for 

hood manufacturers, abatement equipment manufacturers, and cooking 

equipment manufacturers and vendors to work together in developing new and 

adapting existing technologies. 
33 

Catalytic oxidizers, a highly cost-effective and virtually maintenance-free control 

device for chain-driven charbroilers were developed in response to the SCAQMD 

Regulation 1138, adopted in 1997. Because the SCAQMD rule did not regulate 

under-fired charbroilers, there has been limited research and development 

directed at control technologies for these cooking devices. A regulatory mandate 

will help to create a market for under-fired charbroiler abatement technology. For 

this reason, the compliance date for existing under-fired charbroilers is set five 

years in the future, to allow time for development of better, more cost-effective 

technologies. 

The proposed rule is only the first step in an ongoing commitment to reduce 

emissions from commercial cooking appliances. As additional data becomes 

available, District staff will be evaluating possible controls on other types of 

cooking equipment, including griddles, woks, and wood-fired cooking 

appliances. There are over 7,000 griddles that operate in the Bay Area that, 

collectively, are responsible for about 14% of commercial cooking 

emissions. Studies conducted on wok cooking indicate woks emit a number of 

toxic compounds from volatilization and partial combustion of the cooking oils. 

Combustion of wood in wood-fired cooking appliances produces the same 

emissions as wood stoves and fireplaces and occurs much more frequently than 

residential wood burning. District investigation into possible controls on these 

and other types of cooking equipment will be part of efforts to reduce PM 

emissions in order to achieve state PM standards and (if necessary) the new 

federal 24-hour PM standard. 

Staff is interested in further research in this field to support further development 

of data on emissions from griddles, woks, wood-fired cooking appliances, and 

other types of cooking appliances. The District will closely monitor research 

which could be used to refine the emission inventory, assess risk factors, and 

identify whether additional rule making should be conducted. 

XI. CONCLUSION 

Pursuant to Section 40727 of the California Health and Safety Code, the 

proposed rule must meet findings of necessity, authority, clarity, consistency, 

non-duplication, and reference. The proposed regulation is: 

• Necessary to protect public health by reducing ozone precursors and 

particulate matter emissions to meet the requirements of Senate Bill 656 

Particulate Matter Implementation Schedule and further study commitment 

of the Bay Area 2005 Ozone Strategy; 

• Authorized by California Health and Safety Code Sections 40000, 40001, 

40702, and 40725 through 40728; 

• Clear, in that the new regulation specifically delineates the affected 

industry, compliance options, and administrative requirements for industry 

subject to this rule, so that its meaning can be easily understood by the 
34 

persons directly affected by it; 

• Consistent with other District rules, and not in conflict with state or federal 

law; 

• Non-duplicative of other statutes, rules, or regulations; and 

• Implementing, interpreting and making specific the provisions of the 

California Health and Safety Code sections 40000 and 40702. 

The proposed rule has met all legal noticing requirements, has been discussed 

with the regulated community and other interested parties, and reflects the input 

and comments of many affected and interested parties. In addition to Regulation 

6, Rule 2, fees for registering charbroilers under Regulation 3 would be reduced, 

and Regulation 6: Particulate Matter and Visible Emissions would be renumbered 

and renamed for consistency. District staff recommends adoption of proposed 

Regulation 6, Rule 2: Commercial Cooking Equipment, adoption of proposed 

amendments to Regulation 3, Schedule R: Equipment Registration Fees, 

adoption of proposed amendments to Regulation 6: Particulate Matter and 

Visible Emissions, and adoption of the CEQA Negative Declaration. 

XII. REFERENCES 

1. England, G.C., Wien, S., Chang, M.C., Gurney, M. D., and Loos, K., 2001. 

Fine Particle and Precursor Emissions from Power, Oil, and Gas Industry 

Combustion Sources. 

2. Foodservice Consultants Society International North America (FCSI), 

2006. FCSI White Paper, Commercial Kitchen Ventilation, “Best Practice” 

Design and Specification Guidelines, September 2006. 

3. Food Service Technology Center. Design Guide 1: Improving Commercial 

Kitchen Ventilation System Performance. Selecting and Sizing Exhaust 

Hoods. 

4. Hildemann, L.M., Cass, G.R., Markowski, G.R., 1989. A Dilution Stack 

Sampler for Collection of Organic Aerosol Emissions: Design, 

Characterization and Field Tests. Aerosol Sci. Technol. 10: 193-204. 

5. Gerstler, W.D., Kuehn, T.H., Pui, D.Y., Ramsey, J.W., Doerr, M.P., 1996. 

Identification and Characterization of Effluents from Various Cooking 

Appliances and Processes as Related to Optimum Design of Kitchen 

Ventilation Systems. ASHRAE 745-RP, Phase I, Final Report. Dated 

June 13, 1996. 

6. Gerstler, W.D., Kuehn, T.H., Pui, D.Y., Ramsey, J.W., Rosen, M., Carlson, 

R.R., and Petersen, S.D., 1999. Identification and Characterization of 

Effluents from Various Cooking Appliances and Processes as Related to 

Optimum Design of Kitchen Ventilation Systems. ASHRAE 745-RP, Phase 

II, Final Report. Dated February 9, 1999. 
35 

7. Gerstler, W.D., 2002. New Rules for Kitchen Exhaust. American Society 

of Heating, Refrigerating, and Air-Conditioning Engineers, Inc. (ASHRAE) 

Journal. Downloaded from www.ashraejournal.org. Dated November 

2002. 

8. Kuehn, T.H., Olson, B.A., Ramsey, J.W., Friell, J., and Rocklage, J., 2004. 

Development of a Standard Method of Test for Commercial Kitchen 

Effluent Grease Removal Systems. Draft Final Report. Reported 

conducted by the University of Minnesota, Department of Mechanical 

Engineering, Minneapolis, MN for Nickel-Fisher, Inc. Food Service 

Technology Center, San Ramon, CA. Dated July 31, 2004. 

9. MacDonald, J.D., Zielinska, B., Fujita, E.M., Sagabiel, J.C., Chow, J.C., 

and Watson, J.G., 2003. Emissions from Charbroiling and Grilling of 

Chicken and Beef. J. Air & Waste Manage. Assoc. 53: 185-184. February 

2003. 

10. National Fire Protection Association, Inc. (NFPA), 2004. NFPA 96 

Standard for Ventilation Control and Fire Protection of Commercial 

Cooking Operations. 2004 Edition. 

11. Pacific Environmental Services, Inc., 1999. Final Report. A Detailed 

Survey of Restaurant Operations in the South Coast Air Basin. Submitted 

to South Coast Air Quality Management District on February 5, 1999. 

Contract No. 98089. 

12. Public Research Institute, 2001. Charbroiling Activity Estimation. 

Prepared for the California Air Resources Board and the California 

Environmental Protection Agency. Dated June 30, 2001. 

13. San Joaquin Valley Unified Air Pollution Control District, 2001. Draft Staff 

Report. Commercial Charbroiling. Dated October 27, 2001. 

14. Sherer, M., 2003. Special Report: Clearing the Air. New Hood and Fan 

Technologies are Doing a Better Job for Less. Foodservice Equipment 

Reports. Downloaded from www.fermag.com./sr/v7i6_sr_hood.htm. 

Dated June 2003. 

15. South Coast Air Quality Management District, 2000. Status Report on 

Controlling Particulate Matter and Volatile Organic Compound Emissions 

from Restaurant Operations. Board Meeting Date: August 18, 2000. 

Agenda No. 20. 

16. South Coast Air Quality Management District, 2004. Staff 

Recommendations Regarding Controlling Emissions from Restaurant 

Operations. Board Meeting Date: December 3, 2004. Agenda No. 39. 
36 

17. University of California Riverside, College of Engineering, Center for 

Environmental Research and Technology, (CE-CERT) 1999. 

Development and Demonstration of Emission Control Technologies for 

Commercial Underfired Broilers. Contract No. 98015, February 1999. 

18. University of California Riverside, College of Engineering, Center for 

Environmental Research and Technology, (CE-CERT) 1997. Further 

Development of Emission Test Methods and Development of Emission 

Factors for Various Commercial Cooking Operations. Contract No. 96027, 

July 1997. 

19. University of California Riverside, College of Engineering, Center for 

Environmental Research and Technology, (CE-CERT) 2002. Assessment 

of Emissions from a Chain-Driven Charbroiler (Nieco Model 9025, Golden 

West Equipment, Inc) Using a Catalytic Control Device (Model 7-193), 

Final Report, for Engelhard Corporation. Dated September 13, 2002. 
A-1 

APPENDIX A 

EMISSIONS CALCULATIONS 

The following sections describe the method used to quantify PM and VOC 

emissions from broilers for the nine Bay Area counties. 

A. Estimated Number of Restaurants with Charbroilers 

To obtain an accurate estimate of the total number of commercial restaurants in 

the District, staff contacted the health and environmental departments from each 

of the nine Bay Area counties: Alameda, Contra Costa, Marin, Napa, San 

Francisco, San Mateo, Solano, and Sonoma. County health agencies maintain 

lists of restaurants and other facilities in order to inspect and regulate food 

handling practices within the county’s jurisdiction. Table A-1 presents the results 

of the survey. Restaurants situated in the City of Berkeley are under the 

jurisdiction of the local health department and not regulated by the Alameda 

County health department. The number of restaurants in the City of Berkeley is 

included in Table A-1. 

Table A-1. Commercial Restaurants by County 

County/City Total Number of 

Restaurants 

Adjusted Total for 

Commercial 

Restaurants 

Alameda County 3,700 2,651 

Contra Costa County 1,989 1,425 

City of Berkeley 468 336 

Marin County 607 435 

Napa County 345 248 

San Francisco County 3,997 2,863 

San Mateo County 2,018 1,446 

Santa Clara County 4,933 3,534 

Solano County* 1,146 821 

Sonoma County* 1,504 1,078 

TOTAL 20,707 14,838 

Note: * - The number of restaurants for Solano and Sonoma counties was adjusted based on the 

percentage of the total population within the District jurisdiction (71.2% for Solano County and 

87.7% for Sonoma County). 

The initial estimate of 20,707 restaurants in the District includes establishments 

that do not cook (i.e., delicatessens, ice cream parlors, juice bars, etc), 

institutional eating facilities (i.e., school cafeterias, lodges, retirement homes), 

and restaurants that have gone out of business. Because the restaurant names 

and addresses were not requested as part of the survey, the exact number of 

facilities that would normally be excluded as “noncommercial” restaurants could 

not be determined. Pacific Environmental Services (PES) conducted a similar 

study for the South Coast Air Quality Management District (SCAQMD) in 1999 to 
A-2 

determine the number of commercial restaurants under its jurisdiction and found 

that on average, approximately 77% of the facilities classified as restaurants 

were commercial facilities that served food to the general public. The study was 

based on a restaurant survey conducted in the City of Pasadena, the City of 

Vernon, and Riverside County where 19.4, 16.7 and 23.9 percent, respectively, 

of the facilities were not commercial restaurants. In addition, PES also 

determined that approximately 6.97% of the restaurants have gone out of 

business since the health department lists were compiled. 

Using the results of the PES study, a factor of 0.7163 (0.77 for commercial 

restaurants multiplied by 0.9303 for open business) was then applied to the total 

number of restaurants in the District to exclude those facilities from the survey 

that did not serve food, were not open to the public, or have gone out of 

business. Rounding all estimates to the next whole number, the final number of 

commercial restaurants in the District was projected at 14,838. 

The PES study further surveyed the type of equipment that was used in the 

cooking operations of the commercial restaurants. Based on the SCAQMD 

report, the majority of emissions (87% of PM and 82% of VOC) from cooking 

operations are generated from chain-driven and under-fired broilers. 

Chain-driven broilers consist of conveyorized belts that carry meat to a flame 

area that broils the meat on the top and bottom simultaneously. Under-fired 

broilers have three components: a heating source, high temperature radiant 

surface, and slotted grill. The grill holds the meat while it is cooked from radiant 

heat. The study found that the fraction of facilities in the SCAQMD that operated 

chain-driven and under-fired broilers based on 95th percent confidence limits (in 

parenthesis) was: 

Under-fired broilers: 0.330 (0.29 – 0.37), or 33% 

Chain-driven broilers: 0.0373 (0.0212 – 0.0534), or 4% 

A state-wide study conducted by Public Research Institute (PRI) in 2001 for the 

California Air Resources Board and the California Environmental Protection 

Agency found that approximately 8% of the restaurants had chain-driven broilers 

while 45% of the restaurants had under-fired broilers. The PRI study determined 

a higher average percentage of broilers per restaurant than the PES study mainly 

due to the fact that the PRI study focused on restaurants thought to conduct 

more broiling activities than other types of restaurants. Given this bias, District 

staff considered the PES study results more reflective of the likely representation 

of broilers in the Bay Area. 

The District conducted an independent survey of Bay Area restaurants to verify 

the findings from the PES study. District inspectors surveyed over 400 randomly 

selected restaurants in the Bay Area and questioned them on the type of cooking 

equipment they used, the size of the equipment, and the amount and type of 

meat that is cooked per week. The Bay Area survey confirmed that the 
A-3 

percentages of restaurants that operate a chain-driven charbroiler and/or underfired charbroilers are consistent with the PES study findings. 

Multiplying by the fraction of broilers determined in the PES study, the estimated 

number of broilers in the District is (rounding up to the nearest whole number): 

Under-fired broilers: 4,897 

Chain-driven broilers: 554 

B. Amount and Type of Meat Cooked on Charbroilers 

The PES study asked the restaurants to report their average weekly use of 

hamburger, steaks, poultry (with and without skin), pork and seafood, based on 

the type of cooking equipment used. The average food throughput for chaindriven broiler and under-fired broiler restaurants is presented in Table A-2. 

Table A-2. Average Pounds of Meat Cooked Per Year Per Charbroiler (PES 

Study) 

Type of Food Chain-driven Broiler 

(lbs/year) 

Under-Fired Broiler 

(lbs/year) 

Hamburger 108,846 7,795 

Steaks 9,443 6,474 

Poultry with Skin 5,200 15,226 

Poultry without Skin 18,413 6,027 

Pork 6,932 1,404 

Seafood 7,457 5,673 

TOTAL 156,291 42,599 

In a state-wide phone survey conducted by PRI, the average amount of meat 

cooked per year varied significantly from the results of the PES study. Table 3 

presents the results of the PRI study. 

Table A-3. Average Pounds of Meat Cooked Per Year Per Charbroiler (PRI 

Survey) 

Type of Food Chain-driven Broiler 

(lbs/year) 

Under-Fired Broiler 

(lbs/year) 

Hamburger 41,486 14,049 

Steaks 12,281 9,363 

Poultry with Skin 7,651 7,485 

Poultry without Skin 13,842 9,311 

Pork 2,997 7,699 

Seafood 6,179 7,416 

TOTAL 84,436 55,323 

Although both studies had comparable number of responders (543 for PES and 
A-4 

655 for PRI), the major differences between the PES and PRI studies were: (1) 

the PRI study used computer-assisted telephone interviews instead of PES’s use 

of a self-administered (mail-out) questionnaire; (2) PRI used a more detailed 

restaurant classification scheme and not all categories of restaurants were 

surveyed; (3) the PRI study focused on restaurants most likely to use broilers; 

and (4) PRI surveyed restaurants throughout California while PES investigated 

restaurants within SCAQMD. Overall, PES had a low response rate with only 

12.9% of the restaurants responding to the survey while PRI had a response rate 

of 41%. Given that PES did not receive any responses from the 210 national 

chain restaurants in its study area, it is unknown if this would significantly impact 

their estimated amount of hamburger cooked on chain-driven broilers. (A 

majority of this type of equipment is utilized by fast food restaurants). It should 

be noted that PES did receive responses from local chain and fast food 

restaurants that were not considered “national” chains. PRI received responses 

from 157 fast food restaurants, which equated to 23.9% of the responders. 

Based on the broader geographic coverage of the responders and the inclusion 

of cooking practices from fast food restaurants, District staff considered the 

results of the PRI study (Table A-3) a more representative estimate of the 

amount of meat cooked on broilers per year. The Bay Area restaurant responses 

on the amount of meat purchased per week were not included due to the low 

response rate (less than 14% of the restaurants responded to the question). 

C. Emission Factors from Broilers 

SCAQMD contracted the University of California Riverside, College of 

Engineering – Center for Environmental Research and Technology (CE-CERT) in 

1997 to develop a test method that estimates emission factors for PM10 and VOC 

released from various restaurant cooking operations. The resulting study (the 

“CE-CERT study”) included tests conducted for hamburger cooked on under-fired 

and chain-driven broilers. A subsequent study sponsored by ASHRAE, 

published in 1999 by Gerstler, et al., from the University of Minnesota, 

Department of Mechanical Engineering (the “Gerstler study”) characterized the 

effluent emissions from various grease producing cooking processes. The study 

measured grease particulate and vapor emissions and real time particulate size 

distributions within the exhaust duct using a sample probe and following US EPA 

Method 5. 

Figure A-1 shows the average grease distribution emitted from each appliance as 

determined by the Gerstler study. The actual composition of the emitted 

products is complex and it is difficult to determine the portion of the emissions 

that are particulates. That is because condensable vapors such as water and 

grease are present in vapor as well as liquid form. Generally, condensables are 

vapors in gaseous form at entry into the ventilation hood, but may condense into 

particulate form (i.e., liquid or solid state) in the duct works, on exiting the 

exhaust fan, or in the atmosphere. The CE-CERT study included the emissions 

from condensable vapors into its total particulate emission factor. Because these 
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vapors behave as gases, they cannot be removed through mechanical filtration. 

Particulate matter greater than 10 microns in size are generally not emitted into 

the atmosphere, the CE-CERT study confirmed. Standard baffle filters capture 

particles coarse particulate, those greater than 10 microns in size. Previous 

testing conducted by CE-CERT for the SCAQMD showed that the particulate 

matter emitted was all PM10. US EPA Method 5 measures total particulates, 

including particulates greater than 10 microns in diameter. Although the rule 

requires the use of US EPA Method 5 for determining compliance with the 

emission standard, the effluent stream that will be sampled will only consist of 

particulates less than 10 microns in diameter because the test protocol requires a 

baffle filter (as part of standard kitchen exhaust equipment). The heated probe 

situated at the front of the sampling train will not condense vapors and in turn, 

skew the test results. 

Based on the emission factors from the Gerstler study, the District estimates that 

Type 1 hoods (hoods with fire suppression built into the exhaust system, required 

for all cooking appliances in restaurants) capture 1,573 tons per year (4.3 tons 

per day) of PM greater than 10 micron in size from the nine Bay Area counties. 

For this report, emissions were estimated for particulates less than PM10 and for 

VOC. 

Figure A-1. Average Grease Distribution by Appliance 

Source: Gerstler et al, 1999 

A total of 50 lbs. of emissions is generated from a gas broiler for every 1000 lbs. 

of hamburger cooked. Based on the Gerstler study, approximately 39% (19 lbs. 
A-6 

for every 1000 lbs. of meat cooked) of the total grease emitted from cooking 

hamburgers on an under-fired broiler is in the form of condensable vapors. Of 

the remaining 61% (31 lbs) of grease emissions, 42% (21.5 lbs) of the 

particulates are greater than 10 microns and 15% (7.3 lbs) of the emissions are 

less than 2.5 microns in size. Significantly lower emissions are generated from 

cooking chicken on under-fired broilers due to the very low fat content. The 

Gerstler study measured only 14 lbs of total grease emissions for every 1000 lbs. 

of chicken breast cooked. Approximately 69% of the emissions from chicken are 

in the form of condensable vapors while the remaining 31% are particulates. 

Table A-4 presents a summary of the emissions factors produced from the 

Gerstler study. 

Table A-4. PM Emission Factors for Under-Fired Broilers (lbs/1000 lbs of 

food cooked) 

Type of Under-Fired Broiler 

Food PM >10 micron PM < 10 micron 

Hamburger 21.5 9.5 

Chicken 

breast 

2.5 2.0 

Source: Gerstler et al, 1999 

The emission factors for both types of meats from the Gerstler study compared 

well with previous emission factors determined by the CE-CERT study. It should 

be noted that the impinger methods used by both studies may create positive 

mass artifacts that result in higher emissions rates (Hildemann et al., 1999). 

A study conducted in 2003 by MacDonald et al., from the Desert Research 

Institute (DRI) (the “DRI study”), used the same cooking equipment as at CECERT to estimate emissions of particulate matter less than 2.5 microns. The 

DRI study collected samples from a stainless steel dilution tube, rather than an 

impinger, because: (1) doing so allowed a broader range of sampling media and 

methods to be employed; and (2) the conditions experienced by the sample more 

closely match those experienced by the exhaust gas leaving the vent as they mix 

with the atmosphere (England et al., 2001). Hildemann et al., (1989) found that 

run-to-run variability is typically large using traditional impinger test methods due 

to the presence of random non-combustion generated particles that lead to 

artifact formation in the liquid impingers. Artifacts result in a large positive bias in 

the condensable particle measurement using traditional methods (England et al., 

2001). Unfortunately, the DRI study only quantified emissions for particulates 

less than 2.5 micron and a portion of condensable vapors that solidified in the 

dilution tube. For this reason, the DRI emission factors are not directly 

comparable to either those of the CE-CERT study or the Gerstler study. 

Thus, District staff used the emission factors from the Gerstler study to estimate 

emissions of PM10 from under-fired charbroilers. Because the Gerstler study did 

not test chain-driven charbroilers or determine emissions factors for VOC, District 
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staff used emission factors developed in the CE-CERT study to estimate PM and 

VOC emissions from chain-driven charbroilers, and VOC emissions from underfired charbroilers. For the chain-driven charbroiler, emission factors for poultry, 

pork, and seafood were estimated by applying the meat-specific ratios, 

determined by comparing the emission factors for each meat to hamburgers, for 

the under-fired charbroiler to the hamburger emission factor for chain-driven 

charbroiler, which is the only meat that was tested. Under-fired emission factors 

for chicken breast were used to estimate emissions from pork and chicken with 

and without skin cooked on under-fired broilers. District staff used emission 

factors for seafood developed in the CE-CERT study, because the Gerstler study 

did not develop any such emission factors. The final emission factors used in 

this study are presented in Table A-5. 

Table A-5. Emission Factors (lbs/1000 lbs of food cooked) 

Chain-driven 

Broiler 

Type of Food Under-Fired Broiler 

PM10 (b) VOC (b) PM10 (a) VOC (b) 

Hamburger 7.42 2.27 9.5 3.94 

Steaks 7.42 (c) 2.27 (c) 9.5 (c) 3.94 (c) 

Poultry with Skin 1.56 (e) 1.05 (e) 2 1.82 

Poultry without 

Skin 

1.56 (e) 1.05 (e) 2 (d) 1.82 (d) 

Pork 1.56 (e) 1.05 (e) 2 (d) 1.82 (d) 

Seafood 2.58 (e) 0.22 (e) 3.3 (b) 0.38 

Note: 

a: Emission factors are taken from Gerstler et al study. 

b: Emission factors are taken from CE-CERT study. 

c: Emissions factors for hamburger were applied to beef steaks since these meats were not 

tested on this equipment. 

d: Emission factors for chicken breast were applied to chicken with/without skin, and pork 

e: Emission factors for chicken breast were applied to chicken with/without skin, and pork 

D. Emission Inventory for Broilers

The emission inventory for chain-driven and under-fired broilers is estimated by 

multiplying the number of broilers by the average amount of meat cooked and the 

emission rates using the following relationship: 

EM = EF x Eall x M

 2000 lbs/ton 

Where: 

EM = Emission inventory from broilers (tons/year); 

EF = Emission factor (lbs of PM10 or VOC/1000 lbs of meat cooked); 

Eall = Total number of broilers in District (unitless); and 

M = Average pounds per year of meat cooked on one broiler. 
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Table A-6 presents the final estimated emissions of PM10 and VOC for broilers. 

Table A-6. Emissions from Broilers 

Type of Chain-driven Broiler Under-Fired Broiler 

Food PM10 

(tons/yr) 

VOC 

(tons/yr) 

PM10 

(tons/yr) 

VOC 

(tons/yr) 

Hamburger 85.3 26.1 327 136 

Steaks 25.2 7.72 218 90.3 

Poultry with 

Skin 

3.31 2.22 37 33.4 

Poultry 

without Skin 

5.99 4.02 45.6 41.5 

Pork 1.30 0.87 37.7 34.3 

Seafood 4.41 0.37 59.9 6.90 

Total 

(tons/year) 

126 41 724 342 

Total 

(tons/day) 

0.34 0.11 2.0 0.94