## 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 CONTRO L 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 Qua lity 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 Declaration1 

### I. EXECUTIVE SUMMARY

Every day in the Bay Area, commercial c harbroiling operations collectively emit an estimated 6.9 tons of particulate ma tter (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 fu rther 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 wit h 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 r educing emissions from two types of
charbroilers: chain-driven charbroilers and under-fired charbroilers. Charbroilers are a central appliance for most rest aurant 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 conduct ed 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 re staurant 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 c ook at least 800 pounds of beef per week on the charbroiler will be required to install a control device certif ied to reduce PM emissions. The proposed rule will become e ffective one year after the rule is adopted for chain-driven charbroilers and two or five years for under-fired charbroilers, depending on whether the char broilers were new or existing, respectively. The District anticipates these proposed standards will result in an 85% reduction in PM emitted by all affe cted 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 c oncludes that the rule w ould not cause significant adverse environmental impacts, and a CE QA 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, includi ng individual restaurant owners, hood manufacturers, restaurant trade organiza tions and industry representatives, county health departments, and vendors and installers of commercial kitchen appliances. The District held four pub lic 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. T he 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 determi ne charbroiler grill sizes and types and amounts of meats grilled. Based on analysis of the surv ey results, staff revised the proposed regulation. In addition, District staff refined its cost analysis based on further discussions with restaurant owners, cont rol 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 in corporated into the final proposal and into this staff report, as appropriate.

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

to Regulation 3, Schedule R: E quipment Registration Fees and Regulation 6:
Particulate Matter and Visible Emissions . The amendments to Schedule R propose a reduction in fees for restaur ants and the amendments to Regulation 6
renumber and rename the ru le. The amendments to Regulation 6: Particulate
Matter and Visible Emissions do not have any substantive effect.3 

### II. BACKGROUND

A. Introduction

Restaurants vent substant ial amounts of particulate matter (PM) and volatile organic compounds (VOC) into the atmos phere. Every day in the Bay Area, commercial charbroiling operations collectiv ely 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 st udy 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 adopt ed a rule that limits emissions from restaurant charbroilers. Each of these ru les requires chain-driven charbroilers to operate with a control device to limit the emissions of VOC and PM.

Currently, no District rule directly regulat es emissions from restaurants. The District proposes adoption of Regulation 6, Rule 2 to fulfill a commitment in its Senate Bill (SB) 656 Particulate Matte r 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 pr esented before the Board of Directors at the May 16, 2007 public hearing. At the conclusion of the meeting, the B oard 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 rest aurants 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 duri ng the public hearing. District staff conducted a survey of Bay Area restaurant s 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 ki tchen ventilation system includes an exhaust hood, ductwork, and fan system t hat extracts heat and pollutants and captures grease using filters, extracti on baffles, or water mist systems. The cooking plume rises from the cooking appliance through the f ilters aided by the suction of the exhaust fan, located in most cases on the roof of the restaurant. Large particulates are generally captur ed in the filters while additional particulates condense in the duct work or in the exhaust fan.

Broilers are the central appliance for mo st 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 ar e 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 i ndirectly by way of a radiant surface.

Proposed Regulation 6, Rule 2 would regul ate two types of charbroilers: chaindriven and under-fired. Figure 1 presents examples of a chain-driven charbroiler and an under-fired charbroiler. A chain-dr iven (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 gr ill. 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 a5 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 inte rwoven 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 thr ough combustion. The air pollutants are primarily generated from incomplete com bustion of grease and meat additives,
such as tenderizers and marinade. The air contaminants are released when grease and meat additives fall ont o 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, al cohol, 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 c an 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 PM 10 . PM 10 generated by cooking appliances passes through the v entilation system and is exhausted into the atmosphere. Particulate matter great er than 10 microns in diameter is typically captured in the gr ease filter in the ventilati on hood, and is not exhausted to the atmosphere.6 Both VOC and PM 10 present public health risks. Ozone produced from chemical reactions involving VOC may damage lung tissues and the respiratory tract. Once inhaled, PM 10 may become lodged in the resp iratory tract and lead to wheezing, nose and throat irritation, bronchitis, aggravated asthma, and lung damage.

The SCAQMD and the California Air Re sources Board (CARB) sponsored
several studies in order to determine the percentage of rest aurants that use charbroilers, the amount and type of meat cooked on charbroilers, and the amount of PM 10 and VOC produced from meat c ooked on charbroilers. The
District relied on these research studi es, and on information provided by the health department of each of the nine Bay Area counties, to estimate the amount of PM 10 and VOC emitted from restaurant charbr oilers in the Bay Area. A more detailed description of the methodology is presented in Appendix A.

District staff estimated the number of re staurants in operation in the Bay Area with assistance from the heal th department of each county in the District. Each county health department provided the Distr ict with the number of restaurants permitted within the county. District st aff refined the number of restaurants by eliminating the establishment s 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 t hat are less likely to cook, such as, ice cream parlors
and delicatessens were also eliminated. The District estimates that there are approximately 14,838 restaur ants 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 charbroile rs and 3.7% operate chain-driven broilers. The District verified these percentages by conducting an independent survey of Bay
Area restaurants. District st aff interviewed a random sample of approximately
400 restaurants that included fast food chains and franc hises and found that the SCAQMD percentages are r epresentative of the Bay Area. Based on these percentages, the District estimates that approximately 4,897 Bay Area restaurants operate under-fired charbro ilers and 554 operate chain-driven
charbroilers.

The District used several studies to es timate 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 Universi ty of California Riverside (UCR) and the University of Minnesota were used to quantify average emissions from each type of meat cooked on under-fired char broilers including hamburger, steaks, chicken with or without skin, pork, and s eafood. For chain-driven charbroilers, emission factors for poultry, pork, and s eafood were estimated from the factors developed for under-fired charbroilers. The estimated emissions of PM 10 and VOC by chain-driven and under-fired broile rs 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

Chain-driven Broiler Under-Fired Broiler Type of Food

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 si gnificant portion of the PM 10 and VOC emissions from charbroilers are produced from beef products such as hamburgers and beef steaks. Beef products account for approximately 62% of PM 10 and VOC
emissions from chain-driven charbr oilers and approximately 75% of PM 10 and8 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 restaur ants 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, cook ing operations also produce carbon dioxide (CO 2 ), 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 st udy found that gas charbro ilers generated most of the CO 2 emitted by cooking operati ons. Charbroilers generate CO 2 through the combustion of natural gas and when greas e drippings combust on hot radiant surfaces. The District estimates that the average CO 2 emissions for cooking activities per restaurant ar e approximately 25,000 pounds of CO 2 annually based on operation of the cook ing appliances and energy usage for the associated ventilation system 1

.
D. Regulatory Framework

The District is proposing Regulation 6, Ru le 2, in accordanc e with the District’s SB 656 Particulate Matter Implementati on 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. T he Bay Area is not yet in attainment of the State ozone and particulate matter st andards, 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 meas ures for reducing PM emissions. The District’s Particulate Matter Implem entation Schedule, adopt ed 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 f easibility of reducing ozone precursor emissions from re staurants. 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 regulat es 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 wit h the District’s regul ations of general

1 Energy usage only accounts for the energy required to operate the cooking appliances and associated ventilation system. It does not in clude the energy required to power the air conditioning and heating systems, re frigeration 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. Regulat ion 7 restricts the discharge of odorous
substances.

Bay Area restaurants are issued permi ts 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. Thes e codes require restaurants to install an exhaust ventilation hood with a fire suppression system above commercial cooking equipment that gener ates grease, smoke, st eam, and vapor. The health departments also monitor t he handling of food and ensure that all of the grease traps and hood filters ar e 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 charbroile rs be operated with a control device to limit emissions of VOC and PM.

In addition, the City of Aspen Envir onmental Health Department has an ordinance regulating restaur ant charbroiler emissions under Municipal Code Section 13.08.100: Restaurant Grills. The ordinance requires a ll restaurants that operate any charbroiler to install a control device that is certified by the manufacturer to reduce PM 10 emissions by 90%.



### III. AVAILABLE CONTROL TECHNOLOGY

The District considered a variety of te chnologies to control emissions from charbroilers. District staff reviewed r eports and studies conducted by the UCR, College of Engineering, Center for En vironmental Research and Technology (CE-CERT), on available control tec hnologies 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 re staurant 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 e ffective at removing either or both PM and VOC from charbroilers include catalyti c oxidizers and thermal incinerators. Each of these is a reliable, proven, and commonly-used control technology. The District also considered wet scrubbers, elec trostatic 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 VO C has not been investigated in an independent research study. High-efficiency filters have a significantly lower PM removal efficiency in comparison to t he proven control technologies discussed
below.

Catalytic Oxidizers (flameless)

A catalytic oxidizer is a flameless incinerat ion 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 mi xing of PM and VOC with oxygen. The PM and VOC oxidize into carbon diox ide and water vapor once the mixture reaches the combustion temperature. The released combustion energy is absorbed by the catalyst bed and is transfe rred to the heat recovery system. The
control device is activated by the heat of the charbro iler and does not require any additional fuel to operate. The catalyst, whic h 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 c apable of an overall PM and VOC removal efficiency of approximately 85% (83% for PM and 86% for VOC). Catalytic oxidizers are highly effective and virtua lly maintenance-free control devices for chain-driven charbroilers. However, th is technology is not used to control emissions from under-fired charbroilers because the temperat ure at which the catalyst operates would require signific ant energy usage. Control equipment for
under-fired charbroilers is mounted in t he 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 co mmercial 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 wit h 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 cont act 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 co mbustion chamber where they are converted to carbon dioxi de 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 typi cally 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-al one control devices or in conjunction
with another control device such as a wet scrubber. Fiber- bed filters use a combination of impaction, intercepti on and Brownian diffusion to remove particulate matter from an air stream. Pa rticulates become trapped in the fibers of the filter and eventually dr ain 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 concent ration, exhaust flow, and temperature of the air stream.

Figure 4. Operation of Ty pical Fiber-Bed Filters

Source: Kimre, Inc.12 Periodically the filters must be replac ed 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; howev er, they are not used in restaurants that operate under-f ired 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 industr ies. An ESP functi ons by screening out large PM with a pre-filt er, 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 char ged 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 frequent ly 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 introduc ed from the top of the wet scrubber and flows down to each successive plate, count er to the exhaust flow. The cooking exhaust rises through the grated grills and cool s once it contacts the water. The particles adhere to the water droplets whic h are then collected as liquid waste. The liquid waste collected at the bo ttom of the scrubbers requires either treatment for reuse or disposal. Liqui d particles entrained in the exhaust gas leaving the scrubber are removed using an a fter 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 firs t filter is called a pr e-filter, which is a fully disposable pleated filter that must be replaced every four (4) weeks. The second filter is a medium filt er that is a fully disposabl e bag filter that is replaced every eight (8) weeks. The final filter is a fully disposable 12 in ch HEPA filter that is replaced every six (6) months. The PM removal efficiencies of HEPA filters13 varies from 95% to 99%. HEPA filters have been exclusively used at restaurants that operate under-fired char broilers. 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 c harbroiler emissions. This chapter describes the proposed standards in Regulation 6, Rule 2.

A. Proposed Standard for Chain-Driven Charbroilers

Based on studies conducted by t he UCR CE-CERT (1997), chain-driven charbroilers account for 4% of re staurant 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 Distric t-approved catalytic oxidizer or other certified control. Restaur ants that demonstrate, thr ough meat purchase invoices or other documentation, t hat they cook less than 400 lbs. of beef per week on their charbroilers would be exempt from this proposed rule.

Currently, three California air distri cts regulate chain-driven charbroiler emissions: SCAQMD, San Joaquin Valley Un ified Air Pollution Control District, and Ventura County Air Pollution Control Dis trict. 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 anestablished track record and has been proven capable of reliably reducing chaindriven charbroiler emissions of PM 10 by 83% and VOC by 86%. The South Coast AQMD has already approved cataly tic oxidizers from a variety of manufacturers to meet the same em issions 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 t he 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 flexib ility 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 PM 10 per 1,000 lbs. of beef cooked. Alter native controls, such as elec trostatic precipitators, are capable of achieving a higher PM 10 removal efficiency, but at greater cost, than a catalytic oxidizer. In some cases, ot her controls have already been installed on District restaurants. The manufactu rer is required to have an independent laboratory perform the certification test, in accordance with specific procedures prescribed in the rule, to det ermine the ability of the cont rol to meet the emission14 standards the rule requires.

B. Proposed Standard for New Under-Fired Charbroiler Installations

Under-fired charbroilers account fo r 82% of PM emi ssions generated by restaurants, according to t he 1997 University of Califor nia, Riverside study. The focus of the proposed rule for newly-insta lled under-fired charbroilers is to reduce emissions from high-production restaurants that cook large quantities of beef on under-fired charbroilers and, consequently, ar e responsible for a large portion of the emissions. Effective January 1, 2010, the proposal calls for any owner or operator of any restaurant t hat 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 emissi ons to no more than 1.0 lbs. of PM 10 per 1,000 lbs. of beef cooked, as meas ured by the test method set out in section 603 of the proposed rule. Any restaurant that demonstrat es that it grills less than 800 lbs. of beef per week on its charbroiler(s) would be exempt.

The rule recognizes that effective cont rol equipment that m eets 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 restaur ant and thereby become subject to the rule will have to install an approved control device. Alternatively, the restaurant owner may elect to install cooki ng equipment other than an under-fired charbroiler, such as a clam shell griddle or over-fired ch arbroiler, 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 Ba y Area PM emissions from commercial cooking are attributable to the approxim ately 5,000 under-fired charbroilers in use in the Bay Area. PM emissions from already-e xisting 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 charbroile rs with an aggregate grill surface area of 10 square f eet or more and that purc hase 1,000 lbs of beef or more per week to install control technology certified to emit no more than 1.0 lbs. of PM 10 per 1,000 lbs. of beef cooked, as m easured by the test method set out in section 603 of the proposed rule. This will reduce PM 10 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 availabl e that can be retrofitted into existing restaurants. However, some restaurant s may require remodeling, additional plumbing, or additional struct ural support in order to install and operate currently
available control devices. As a resu lt, an extended implementation date for existing under-fired charbroilers is propos ed to allow adequate time for restaurant owners to plan, obtain the necessary build ing 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 hav e been certified for use in the South Coast will be approved and listed on t he District web site as well as new, Districtcertified catalytic oxidizers. Re staurant owners will be assessed an initial registration fee and recurring annual fee to recover the District’s costs of administering and enforcing t he 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 recordkeepi ng provision that requires owners and operators to record the date of insta llation of, and any maintenance and repairs performed on, the control device. The r epair logs will contain the date, time, and description of the work that was perform ed. The owner or operator must keep the records for at least five years. The purpose of this recordkeeping requirement is to ensure that the c ontrol 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 r equired to register the under-fired charbroiler(s) and the control device. Restaurant owners will be assessed an initial registration fee, fo llowed by a recurring annual fee to recover the District’s costs of administering and enforci ng the proposed rule. The proposed registration fee is $360 and the proposed annual fee is $100, cons istent with the fees for chain-driven charbroilers. T he 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 le ss than five years. The records must include date of installation of any contro l device operated to comply with the rule and records of any maintenance or repairs performed on the cont rol device. The16 maintenance and repair records must contai n the date, time, and description of the work that was performed. The purpose of this reco rdkeeping 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 contro l device must contract an independent laboratory to perform a test, in accordanc e with specific procedures prescribed in the rule, to certify the ability of the control to meet t he 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 certificat ion 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, re spectively. The test protocol are
intended to measure PM 10 , excluding condensable vapors.

The proposed sections 6-2- 602 and -603 protocols employ EPA Method 5, which measures total particulate, and not PM 10 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 PM 10

.

According to the CE-CERT study, “Furt her Development of Emission Test Methods and Development of Emission Fa ctors for Various Commercial Cooking Operations” (1997), particulate matter greater than 10 microns in size is generally
not emitted into the atmo sphere, because the standard ba ffle filters installed in restaurant kitchen ventilation systems captur e particles greater than 10 microns in size, termed coarse particulate. The CE-CERT study showed that the particulate matter that passed th rough the baffle filter was all PM 10 . 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 pr otocol 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 v apors from measurement. Emissions from charbroiling include particulate matter and compounds that condense into particulate matter as they cool. T hese latter compounds are termed condensable vapors, and are included in t he definition of total PM 10 . As condensable vapors leave the very hot surface of a charbro iler, 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 re move only the vapors that condense prior to reaching the contro l 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 cond ensable 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 th rough incomplete combustion of tenderizers, marinade, and fats in the meat cooked. The District estimates that chain-driven charbroilers in the Bay Area em it a total of 0.34 t ons 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 appr oximately 62% of the particulate emissions from chain-driv en 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 ti mes the emission rate of chicken, pork, or seafood. A more detailed di scussion 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 Ba y Area restaurant survey, it is estimated that approximately 80% of all chain-driven char broilers will be subject to this proposed rule; the remaining 20% of restaurants wit h 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 charbroile rs. The installation of control equipment is anticipated to reduc e emissions of PM from these chaindriven charbroilers by 83% (0.27 t pd) 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 achi eving these emission reductions.

New Under-Fired Charbroilers

The proposed standards for new installations of large under-fir ed 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 new18 installations will add an additional 0.010 tons of PM production per day that will be subject to the requirements of the ru le. 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 esti mates that approximately 40% of these restaurants (about 200 restaurant s) 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 charbr oilers, or 0.32 tpd. Effective January 1, 2013, the rule is anticipated to reduc e total PM emissions from under-fired charbroilers by 14% (0.28 tpd) (90% fr om 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 r eductions for charbroilers subject to the proposed rule.

Table 3. Emission Reductions from Charbroilers Subject to Proposed Rule

Type of Charbroiler Uncontrolled
PM 10 Emissions (tpd) PM 10 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 co sts associated with the proposed rule.

A. Cost Analysis for Charbroilers

The District investigated the technical feasibility, potential emission reductions, and costs of installing and operat ing 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 t he annualized capital costs and the annual19 recurring operation and maintenance (O&M) costs.

The District estimated capital costs usi ng the capital recovery method, which accounts for depreciation and interest (i.e., in flation) costs over the useful life of
the control. The District annualized the c apital 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 te chnology 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 Distr ict Draft Staff Report for Commercial Charbroiling (2001). The District veri fied 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 pres ents the cost-effectiveness. Because catalytic oxidizers have been designed to work wit h chain-driven char broilers and are certified for use in other di stricts, and because of their low costs relative to other controls, is the District expects that re staurants with chain-dr iven 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 wit h a catalytic oxidizer that includes costs for installing the control, initial catalyst, and replacement catalyst after 5 years ($4,000). The cost w ould essentially be the same if an existing broiler was retrofitted with a catalytic oxidizer. In stallation of the equipment was assumed to be $1,000, although typical installati on costs ranges from $500 to $1,000.

Operating Costs: Annual O&M costs of cleaning the catalyst are expected to be20 $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 ca talytic 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 estima tes 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% remo val efficiency for VOC. The costeffectiveness to reduce emissions from a ll 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, in cluding surfactant f eeder, controller, remote start/stop control, re-circula tion pump, valves, and exhaust blower.

Operating Costs: Annual O & M costs are ant icipated to not exceed $2,000. O&M includes the energy cost for operati ng the controller and exhaust blower as well as the monthly expense of purchasi ng 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 cont rol 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-effectivene ss to reduce emissions from a chaindriven charbroiler by installing a wet scr ubber 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) wit h ducting, exhaust fan, and one set of replacement plates: $20,000 for a ventilati on rate of 2,000 cfm to $40,000 for a ventilation rate of 5,000 cfm. The Dis trict assumed a cost of $20,000 for an ESP that operates at a ventilati on 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 desi gned to enhance the performance and operation of the electrosta tic precipitator and reduce the overall maintenance

costs:

• First pass autowash module, including timer, to automatically wash the plates - $4,00021 • 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 captur e 55% to 60% of the large particles and consequently r educes the cleaning frequency of the plates - $1,500.

A hot water line, drain, and wiring to t he 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 we re included in the cost estimate. Restaurants may purchase a single pass el ectrostatic 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, equiva lent 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 ensur e 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 them selves. 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 t he detergent for the autowash unit. If the restaurant opts to inst all more efficient hood filters, then the cleaning frequency and, thus, the cost of cleaning, can be reduced by half.

Restaurant owners may also purchase opt ional odor control units that will increase the cost of the unit by at leas t $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 tp d of PM (total of 105 tons per year) emission reductions c an 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 co st 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 c ents 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 r ange 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 Po tential 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 Distric t evaluated the technical feasibility, potential emission reductions, and costs of installing an ESP, t hermal 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 equipm ent, and Table 7 presents the costeffectiveness. Catalytic oxidizers, designed to fit directly on t op of a chain-driven charbroiler, have not been developed for unde r-fired charbroilers. The currently available control options for an under-f ired 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 co st 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 antic ipated 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 disposabl e pleated filter that cost $6 per filter and must be repl aced every four (4) weeks. The second filter is a medium filter that is a fu lly 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 cost s $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 captur ed using this control device. Based on estimate of 0.31 tpd of PM emissions from restaurants affe cted 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 precipitat or (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 cont rol an under-fired charbroiler, a maximum ventilation rate of 4,000 cfm wa s used. This ventilation rate is typical required for a large under-fired charbroile r. The cost of an ESP that operates at this ventilation rate is $27,500. Installati on 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 automat ic 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 electr ostatic precipitator may be as low as $20,000, if fewer options were install ed, or may be higher if the ESP must accommodate a higher ventilation rate.

Operating Costs: The annual O&M cost is antic ipated 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 precipit ator 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 ru le, it is expected t hat 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 restaur ant chooses to contract with a service company for monthly cleani ng 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–effectivene ss of $11,899 per ton of PM.

Wet Scrubbers

Capital Costs: A wet scrubber unit has a capita l 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 accessori es necessary for the complete operation of the unit.

Operating Costs: The annual O&M cost is antic ipated 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 mont hly expense of purc hasing non-foaming surfactants detergent.

The total annualized cost of installing th is 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 Dis trict, wet scrubbers are not commonly used in restaurants loca ted 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 co st 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 c ents 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 r ange 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 re staurants 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 Califor nia Health and Safety Code requires an air district to perform an incremental cost analysis fo r any proposed Best Available Retrofit Control Technology rule or feasible measur e. The air district must: (1) identify one or more control options achieving t he emission reduction objectives for the proposed rule, (2) determine the cost e ffectiveness for each option, and (3) calculate the incremental cost effect iveness for each option. To determine incremental costs, the air district must “c alculate the difference in the dollar costs divided by the difference in the emi ssion reduction potentials between each progressively more stringent potential cont rol option as compared to the next less expensive control option.”

To determine incremental co sts, 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 oxid izer is the most cost-effective control device for chain-driven charbroiler. T he 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 ener gy supply since it uses the heat generated from t he 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 te chnologies 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 emissi ons. The wet scrubber is also a viable control option to restaurant owners given its proven control efficiencies in other
industries. The thermal incinerator has subs tantially 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 $41,143ChainDriven 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 th is rule will require District resources from several divisions including Comp liance 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 propos al calls for all owners and operators of
restaurants that have chain- driven charbroilers and t hat 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 contro l device certified for use under the rule. There are approximately 443 c hain-driven charbroilers cu rrently 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 progr am analyst and an air quality engineer will be required to develop the registration fo rm, maintain the registration database, review registrations, and respond to public i nquiries. This is estimated to cost approximately $45,800 (0.21 FTE). Bec ause 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 operat ors of restaurants that have newly-installed under-fired charbr oilers with a total of at least ten square feet of grill surfac e area would have to insta ll 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 f eet of grill surface ar ea 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 f eet of grill surface area. The rule would apply to approximately 200 of these re staurants. Inspections are anticipated to cost $23,219 based on 217 hours per y ear (0.11 FTE, Air Quality Inspector). Maintenance of the web-based registra tion system will cost $11,235 (0.05 FTE, Air Quality Engineer). Revi ew 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 registra tion fee of $360 and annual recurring fee of $100 is proposed. The fee schedule for re staurants 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, Berk eley, California, has prepared a socioeconomic analysis. The analysis conc ludes that the affected restaurants
should be able to absorb t he costs of compliance wit h 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 Californi a Environmental Quality Act, the District has had an initial study for the propos ed amendments prepared by Envi ronmental Audit, Inc. The initial study concludes that ther e are no potential significant adverse environmental impacts associated wit h the proposed amendments. A negative declaration is proposed for adoption by the Dis trict 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 distri ct rules. The district must then note any differences betw een these existing requirem ents and the requirements imposed by the proposed change.

Adoption of this rule would not conflic t with any existing federal or District requirement. Under the federal air polluti on requirements, there is no rule that limits emissions from restaurants. The District also does not have any rules that are applicable to restaurants except t hose 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 comprehensiv e public outreach program to involve all stakeholders in developing this pr oposal, including individual restaurant owners, hood manufacturers, restaurant trade organizations and industry representatives, county health departm ents, 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 SC AQMD 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 depar tments 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 c ounties of the District’s intent to
consider restaurant controls. The Distr ict held two meetings with county health officials, one on January 19, 2006, and anot her on July 28, 2006. The purpose30 of the meetings was to di scuss the current emission inv entory, solicit suggestions for ways to control emissions, and devel opment of a cooperat ive enforcement strategy between the District and the various counties.

The District also initiated contacted wit h the Golden Gate Restaurant Association in February 2006 to invite their participati on in the rule development process. The District met with representat ives of the Golden Gate Restaurant Association on February 24, 2006, and had follow-on telephone di scussions as the rule evolved.

District staff contacted the PG&E Food Service Technology Center in San Ramon, California in May 2006 regarding em ission factors for specific types of commercial cooking equipment. After conducti ng a site walk of their facility, District staff has been in continuous discu ssions with representatives from the Food Service Technology Center in developing this proposal. The Center represents the interests of the rest aurant 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 Ba y Area. District staff tested two restaurants that operated either a chain-dr iven charbroiler or under-f ired charbroiler that exhausted their emissions through a cont rol device. For comparison purposes, the District also collected particulate ma tter samples from two restaurants that operated either a chain-driv en charbroiler or under-fir ed charbroiler without any
control device. The emission estima tes 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 prov ided 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. Simult aneous to the posting on the District web site, the District sent out approximately 17,000 postc ards to individual restaurant owners, hood vendors, and installers informing them of the rule and the then-upcoming public workshop. The District also devel oped 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 r egarding specific topics and issues about the draft rule and workshop report.

The District held four (4) public works hops 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 people31 attended these workshops, with most of the interested parties being hood manufacturers, a restaurant organizati on, and independent local restaurants. The District received written comments from hood manufacturers that were identical to comments provided by t he restaurant organization.

Overall, the public comments suppor ted the standard for chain-driven charbroilers. Input from the first workshop raised concerns about the technical feasibility and costs of installing high effici ency filters, a modes t 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 t he installation of controls on restaurants that utilize low emission cooking equipment. Another comment suggested that the rule would result in more energy cons umption 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 dire ctly to developing a second draft of Regulation 6, Rule 2 to address emissions from only charbro ilers. A supplement to the workshop report was generated to summarize the differences from the original proposal. The District pres ented the revised proposal before the American Society of Heating, Refri geration, and Air-Conditioning Engineers (ASHRAE) Technical Committee 5.10 Ki tchen 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 wo rkshop 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 fr om 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 heari ng was conducted by the Board of Directors on proposed Regulation 6, Rule 2. Comments and questions at the hearing addressed issues including: the num ber of restaurants with charbroilers larger than 10 square feet; emissions fr om meats other t han beef; and potential impacts to small businesses. The Distric t Board directed staff to do additional research and referred the rule to the Stationary Source Committee.

Staff conducted a survey of Bay Area rest aurants, focusing on the grill size and amounts and types of meats cook ed on under-fired and chain-driven charbroilers. District inspectors interv iewed a representative sample of over 40032 randomly selected restaurant s from all nine Bay Area counties. The survey verified that the grill size specified in the rule focuses control requirements on large, high-production rest aurants that represent appr oximately 4% of the restaurants that operate an under-f ired charbroiler. In add ition, staff has further investigated emissions from various ty pes of meats and costs to operate and maintain control technologies. District st aff also met with representatives from the Golden Gate Restaurant Associat ion 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 wit h restaurant associations, the proposed rule was revised to focus control requirements on those restaurants that purchase and grill large quant ities of beef. District st aff revised the proposed Regulation 6, Rule 2 and held a works hop on the revised proposal on October 23, 2007.

The District sent approximately 13,300 pos tcards to Bay Area restaurants to notify them of the revised proposal and the public workshop. Comments at the workshop and in subsequent letters primar ily focused on questions concerning the certification testing procedures to demonstrate compliance with the emission standard. One commenter not ed the lack of a testing pr ocedure in the proposed rule for new catalytic oxidizers and a question was asked about how a restaurant would demonstrate an exemption under t he proposed rule. The proposed rule
has been restructured based on these comments such that catalytic oxidizers certified by the SCAQMD ar e acceptable for installation in the Bay Area. The certification testing procedures have been revised for consistency with the definitions and the emissi on standards. Compliance advisories can provide guidance on how to demonstrate an exemption.

The District will continue to follow the dev elopment 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 cu rrently make up ov er 6% of all PM 10 emissions in the Bay Area. This rule is an important first step in achieving emission reductions from a source cat egory that has not been regulated in the past. District staff is committed to work ing with industry representatives and to provide the Board of Dir ectors with periodic updates on the development of control technology for under-fired charbroile rs. This rule is an opportunity for hood manufacturers, abatement equipment manufacturers, and cooking equipment manufacturers and vendors to wo rk together in developing new and adapting existing technologies.33 Catalytic oxidizers, a highly cost-effect ive 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 thes e cooking devices. A regulatory mandate will help to create a market for under-fired charbroiler abatement technology. For this reason, the compliance date for exis ting 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 st ep in an ongoing commitment to reduce emissions from commercial cooking appliances. As additional data becomes available, District staff will be evaluati ng possible controls on other types of cooking equipment, including griddl es, woks, and wood-fired cooking appliances. There are over 7,000 griddl es that operate in the Bay Area that, collectively, are responsible fo r about 14% of commercial cooking emissions. Studies conducted on wok cook ing indicate woks emit a number of toxic compounds from volat ilization and partial combustion of the cooking oils. Combustion of wood in wood-fired cook ing appliances produces the same emissions as wood stoves and fireplaces and occurs much more frequently than residential wood burning. District investi gation 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. T he District will closely monitor research which could be used to refine the emissi on inventory, assess risk factors, and identify whether additional rule making should be conducted.



### XI. CONCLUSION

Pursuant to Section 40727 of the Calif ornia Health and Safety Code, the proposed rule must meet findings of nece ssity, 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 Sc hedule 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 admin istrative requirements for industry subject to this rule, so that it s meaning can be easily understood by the34 persons directly affected by it;

• Consistent with other Distr ict rules, and not in conflict with state or federal law;

• Non-duplicative of other statut es, 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 not icing requirements, has been discussed with the regulated community and other interested parties, and reflects the input and comments of many affected and intere sted parties. In addition to Regulation 6, Rule 2, fees for registering charbr oilers under Regulati on 3 would be reduced, and Regulation 6: Particulate Matter and Visible Emissions would be renumbered and renamed for consistency. Distric t 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 amendment s to Regulation 6: Particulate Matter and Visible Emissions, and adoption of t he 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 Performanc e. Selecting and Sizing Exhaust
Hoods.

4. Hildemann, L.M., Cass, G.R., Mark owski, G.R., 1989. A Dilution Stack Sampler for Collection of Organi c 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. Ident ification and Characterization of Effluents from Various Cooking Appli ances and Processes as Related to Optimum Design of Kitchen Ventilati on 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-C onditioning Engineers, Inc. (ASHRAE) Journal. Downloaded from www.ashr aejournal.org. Dated November
2002.

8. Kuehn, T.H., Olson, B.A., Ramsey, J. W., Friell, J., and Rocklage, J., 2004. Development of a Standar d Method of Test for Commercial Kitchen Effluent Grease Removal Systems. Draft Final Report. Reported conducted by the University of Mi nnesota, 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., Fuji ta, E.M., Sagabiel, J.C., Chow, J.C., and Watson, J.G., 2003. Emissions fr om Charbroiling and Grilling of Chicken and Beef. J. Air & Waste Manage. Assoc. 53: 185-184. February
2003.

10. National Fire Protection Associat ion, 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 Oper ations in the South Coast Air Basin. Submitted to South Coast Air Quality Management District on February 5, 1999. Contract No. 98089.

12. Public Research Inst itute, 2001. Charbroiling Activity Estimation. Prepared for the California Air Re sources Board and the California Environmental Protection Agen cy. Dated June 30, 2001.

13. San Joaquin Valley Unified Air Polluti on 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.ferm ag.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. B oard Meeting Date: August 18, 2000. Agenda No. 20.

16. South Coast Air Quality Management District, 2004. Staff Recommendations Regarding Controlli ng Emissions from Restaurant Operations. Board Meeting Date: De cember 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 Technol ogy, (CE-CERT) 1997. Further Development of Emission Test Me thods and Development of Emission Factors for Various Commercial Cooki ng Operations. Contract No. 96027, July 1997.

19. University of California Riverside, College of Engineering, Center for
Environmental Research and Technol ogy, (CE-CERT) 2002. Assessment of Emissions from a C hain-Driven Charbroiler (Nieco Model 9025, Golden West Equipment, Inc) Using a Cataly tic Control Device (Model 7-193), Final Report, for Engelhard Corporat ion. 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 count ies: Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, Solano, and Sonom a. County health agencies maintain
lists of restaurants and other facilities in order to inspect and regulate food handling practices within the county’s jurisd iction. Table A-1 presents the results of the survey. Restaurants situated in the City of Berkeley are under the jurisdiction of the local health depar tment and not regulated by the Alameda County health department. The number of rest aurants in the City of Berkeley is
included in Table A-1.

Table A-1. Commercial Restaurants by County

County/City Total Number of
Restaurants A djusted 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 Sol ano and Sonoma counties was adjusted based on the percentage of the total population within the Dist rict jurisdiction (71.2% for Solano County and 87.7% for Sonoma County).

The initial estimate of 20,707 restaurants in the Distr ict 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. Bec ause 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 toA-2 determine the number of commercial rest aurants under its jurisdiction and found that on average, approximatel y 77% of the facilities classified as restaurants were commercial facilities that served f ood 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 commercia l restaurants. In addition, PES also determined that approximately 6.97% of the restaurant s have gone out of business since the health department lists were compiled.

Using the results of t he 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 t he next whole number, the final number of
commercial restaurants in the Distr ict 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 VO C) from cooking operations are generated from chai n-driven and under-fired broilers.

Chain-driven broilers consist of conveyor ized belts that carry meat to a flame
area that broils the m eat on the top and bottom simultaneously. Under-fired broilers have three components: a heati ng source, high temperature radiant surface, and slotted grill. The grill holds t he meat while it is cooked from radiant heat. The study found that the fraction of facilities in the SC AQMD that operated
chain-driven and under-fir ed broilers based on 95 th 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 Re search Institute (PRI) in 2001 for the California Air Resources Board and the California En vironmental Protection Agency found that approximatel y 8% of the restaurants had chain-driven broilers while 45% of the restaur ants 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 fo cused 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 theA-3 percentages of restaurants that operate a chain-driv en charbroiler and/or underfired charbroilers are consist ent 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 restaur ants 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 t he 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 co mparable number of responders (543 for PES andA-4 655 for PRI), the major differences bet ween the PES and PRI studies were: (1) the PRI study used computer-assisted te lephone interviews instead of PES’s use of a self-administered (mail-out) questi onnaire; (2) PRI used a more detailed restaurant classification scheme and not all categories of restaurants were surveyed; (3) the PRI study focused on re staurants 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 t he survey while PRI had a response rate of 41%. Given that PES did not receiv e 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 c ooked on chain-driven broilers. (A majority of this type of equipment is ut ilized by fast food restaurants). It should be noted that PES did receive responses from local chain and fast food
restaurants that were not considered “nat ional” chains. PRI received responses from 157 fast food restaurants, whic h 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 re staurants, 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 y ear. The Bay Area restaurant responses on the amount of m eat 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 River side, College of Engineering – Center for Environmental Research and Technology (CE-CERT) in 1997 to develop a test method that estimates emission factors for PM 10 and VOC
released from various restaurant cooki ng operations. The resulting study (the “CE-CERT study”) included tests conduct ed for hamburger cooked on under-fired
and chain-driven broilers. A subs equent study sponsored by ASHRAE, published in 1999 by Gerstler, et al., fr om the University of Minnesota, Department of Mechanical Engineering (t he “Gerstler study”) characterized the effluent emissions from various grease pr oducing cooking processes. The study measured grease particulate and vapor emissions and real time particulate size
distributions within the exhaust duct us ing 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 bec ause 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 t he ventilation hood, but may condense into particulate form (i.e., liquid or solid st ate) in the duct wo rks, on exiting the exhaust fan, or in the at mosphere. The CE-CERT study included the emissions from condensable vapors into its total parti culate emission factor. Because theseA-5 vapors behave as gases, they cannot be re moved through mechanical filtration. Particulate matter greater than 10 microns in size are generally not emitted into the atmosphere, the CE-CER T study confirmed. Standar d baffle filters capture particles coarse particulate, those great er than 10 microns in size. Previous testing conducted by CE-CERT for the SCAQMD showed that the particulate
matter emitted was all PM 10 . US EPA Method 5 measures total particulates, including particulates greater than 10 micr ons 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 diamet er because the test protocol requires a baffle filter (as part of standard kitc hen 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 bu ilt 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 es timated for particulates less than PM 10 and for VOC.

Figure A-1. Average Grease Di stribution by Appliance

Source: Gerstler et al, 1999

A total of 50 lbs. of emissions is generat ed 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 greas e emissions, 42% ( 21.5 lbs) of the particulates are greater t han 10 microns and 15% (7.3 lbs) of the emissions are less than 2.5 microns in size. Signific antly 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 to tal 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 t he 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)

Under-Fired Broiler Type of

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 m eats from the Gerstler study compared well with previous emission factors dete rmined 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 em issions 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 particu late matter less than 2.5 microns. The DRI study collected samples from a stainle ss 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 condi tions experienced by the sample more closely match those experienced by the ex haust 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 us ing traditional impinger test methods due to the presence of random non-combustion generated particles that lead to artifact formation in the liquid impingers. Ar tifacts result in a large positive bias in the condensable particle measurement usi ng traditional methods (England et al., 2001). Unfortunately, the DRI study only quantified emissions for particulates less than 2.5 micron and a portion of condens able vapors that solidified in the dilution tube. For this reason, the DRI emission factors are not directly comparable to either those of the CE-C ERT study or the Gerstler study.

Thus, District staff used the emission factor s from the Gerstler study to estimate
emissions of PM 10 from under-fired charbroilers. Because the Gerstler study did
not test chain-driven charbr oilers or determine emissions factors for VOC, DistrictA-7 staff used emission factors developed in t he CE-CERT study to estimate PM and VOC emissions from chain-driven char broilers, 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 fact ors for each meat to hamburgers, for the under-fired charbroiler to the hambur ger 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 unde r-fired broilers. District staff used emission factors for seafood developed in the CE-C ERT 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 Under-Fired Broiler Type of Food

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 appli ed 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 t he 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.A-8 Table A-6 presents the final estimated emissions of PM 10 and VOC for broilers.

Table A-6. Emissions from Broilers

Chain-driven Broiler Under-Fired Broiler Type of
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