### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis August 18, 2011

B - 1 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 

# APPENDIX B

Emission Reduction Analysis For Revised Proposed Amendments to Rule 4702

August 18, 2011

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis August 18, 2011

B - 2 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 

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### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis August 18, 2011

B - 3 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 

### EMISSION REDUCTION ANALYSIS FOR REVISED PROPOSED RULE 4702 (INTERNAL COMBUSTION ENGINES)

I. SUMMARY

The purpose of this rule project is to obtai n as much reductions nitrogen oxides (NOx) emission from the source category as expediti ously practical, technologically feasible, and economically reasonable, as determined by the District’s Governing Board. The District committed to amending Rule 4702 as part of both the District’s 2007 Ozone Plan and the 2008 PM2.5 Plan; however, neither pl an committed the District to a specific amount of emission reductions. This appendix det ails the calculations and assumptions used to estimate the NOx emission r eductions associated with the proposed amendments to Rule 4702. Emission reductions were estimated using permit conditions of the individual engine and t he proposed rule’s emission limits.

Previous drafts of the rule during this rule-amending project included the potential for carbon monoxide (CO) and volatile organic compounds (VOC) reductions; however, no change in CO or VOC emission limits are in cluded in the revised proposed rule. There are no VOC or CO emission reductions associated with the proposed amendments for this rule project.

In order to determine the emission reductions associated with the changes, District staff queried the District Permit Services Dat abase for all engines, and then manually sorted the engines into one of three categories: emergency standby, rich-burn, and lean-burn. No analysis was done for emergency standby engines because the proposed rule amendments do not affect this type of engine. Of the remaining engines, District staff determined that out of 326 rich-burn engi nes, only 160 engines would be required to reduce their NOx emissions. For lean-burn engines, District staff found a total of 97 lean-burn engines, of which, 62 have permit limit s higher than the proposed rule limits.

District staff estimates that the proposed c hanges in the rule limits for non-AO sparkignited engines would lead to approximately 1.4 tons per day (tpd) of NOx emission reductions. However, in the strictest s ense, these emission reductions cannot be directly credited to the District’s attainm ent plans for State Implementation Plan (SIP) purposes because at least a portion of them will come as part of the fee payment program. Emission reductions in a fee pay ment program cannot be credited to the District until they are actually achieved. Although District staff expects that the Rule 4702 program will generate more emission reduc tions than what has been calculated, this rule project will take no credits for SIP purposes at this time. Although not taking credit for the emission reductions for SIP purposes, the NOx emission reductions are used in determining the cost effectivene ss of the proposed rule amendments. A summary of the emission reduction analysis results is shown in Table 1 and details of the calculations are explained later in this appendix.

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis August 18, 2011

B - 4 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 

### Table 1 – Summary of Estimated NOx Reductions Used for Cost Effectiveness Calculations

Engine Type Total Permitted

Engines Number Affected Engines Total Rated Power (bhp) Estimated NOx Reductions (tpy) Estimated NOx Reductions (tpd) Rich-Burn 326 160 80,738 131.5 0.360 Lean-Burn 97 62 123,886 390.9 1.071 Totals 423 222 204,624 522.4 1.431

II. BACKGROUND

There are two types of non-AO spark-ignit ed engines that would be affected by the proposed rule changes: rich-burn and lean-burn engines. District staff estimates that there are 326 rich-burn engines and 97 l ean-burn non-emergency-standby engines that are currently under permit with the District and ar e subject to Rule 4702. Over 75% of the 222 engines affected by the proposed rule amendments are used in the oil fields.

Effective NOx emission control equipment for rich-burn engines is non-selective catalytic reduction systems (NSCR). Fo r lean-burn engines, the most common NOx emission control equipment is selective cata lytic reduction (SCR). Both control systems require catalysts to convert NOx to nitrogen gas. The NSCR tends to be less expensive to install and operate than a SCR system, but requires high temperature at the engine’s outlet in order to be effective. Because of this temperature requirement, NSCR is usually installed on rich-burn engines and SCR is confined to lean-burn engines.

III. EMISSION REDUCTION ANALYSIS

It is the District’s experience that, when an em ission limit is reduced, a small percentage of operators will choose to replace their inte rnal combustion (IC) engines with electric motors rather than retrofit with an emission control system. Based on past experience with engine rule amendments, staff estimate t hat there would be two to three engines replaced by electric motors. It would be speculative, at best, to determine which engines would electrified, t herefore the following the em ission reduction analysis does not include any estimate of NOx reductions for electrification.

A. Affected Engines

District staff queried the Permit Services Pe rmits Database for non-AO spark-ignited engines. The returned records were then manually sorted into one of three groups: emergency standby/dormant engines; rich- burn engines; and lean-burn engines. The emergency standby engines and dormant engines were removed from the analysis. The information about the remaining engines’ facility and the permit information were

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis August 18, 2011

B - 5 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 

### scrutinized to estimate which engines woul d fit the limited-use definition and which engines would fit the cyclic-loaded field gas f ueled definition and the waste gas fueled definitions. These engines were analyzed separate from rich-burn and lean-burn engines.

B. NOx Emission Reduction Calculations

After the initial sorting, District staff r ead each permit to determine the engine’s current NOx emission limit. The emission limit was then converted from ppmvd to gram per brake horsepower-hour (g/hp-hr) The di fference between the permit limit and the proposed rule limit was then multiplied by a 65% load factor and by assuming that the engine operated 6,570 hours annually (75% of the ti me). An example calculation for an 800 hp rich-burn engine is shown below. Note that 0.359 grams per brake horsepowerhour (g/bhp-hr) is equivalent to 25 ppmvd and 0.153 g/bhp-hr is equivalent to 11 ppmvd.

Emission Reduction = (0.359 - 0.153 g NOx/ bhp-hr) X (800 bhp) X (6570 hr/yr) X (0.65 load factor) X (1 lb/453.6 g) x (1 ton/2,000 lb) = 0.78 tons NOx/year

The individual engine emission reductions were added together to get the total emission reductions for the engine type (rich-burn or lean- burn) and for the rule project overall. Results of the calculations are shown in Table 1 above.

Individual equipment descriptions were scrut inized to determine which engines would fall into the variable load category. NOx emission reductions associated with lean burn engines used for gas compression were calculated by assuming that the uncontrolled emission factor is 1125 ppmvd corrected to 15% oxygen then applying the 93% reduction to the uncontrolled emissions. Us ing this methodology, the emissions from variable load engines is 79 ppmv at 15% oxygen.

Details of the rich-burn estimations are show n in Table 2 and details of the lean-burn engine estimations are shown in Table 3. Table 2 and Table 3 are located at the end of this appendix.

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis August 18, 2011

B - 6 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 

### Special Engine Categories Some engines will not see a change in the NOx em ission limit as a result of this ruleamending project, based on technological and cost effectiveness considerations. The three groups that will not see a change in NO x emission limits are waste-gas fueled, cyclic-loaded field gas-fueled and limited use engines.

Due to the heat content variability of wast e gas, NOx control can be problematic for engines fired on waste gas, therefore, District staff is proposing that there be no change to the NOx emission concentration limit fo r waste gas fueled engines. No emission reductions are estimated for this group of engines.

Cyclic-loaded field gas-fueled engines have reta ined the current emission concentration limit due to technology constraints. Bec ause the exhaust temperature fluctuates, the total exhaust heat from these engines is not high enough for a NOx emission control system to work effectively. Therefore, the proposed rule would not change the NOx emission concentration limit from its pres ent limit. No emission reductions are estimated for this group of engines.

District staff propose not lowering the em ission concentration limit for non-AO, nonemergency, and limited-use engines. The co st effectiveness for limited-use engines (engines operating less than 4,000 hours annually) is considered too high. Details of the cost effectiveness calculation are shown in Appendix C of this staff report. No leanburn engines and only eleven rich-burn engines are expected to be limited-use engines. If the emission limit for these engines were lo wered to 11 ppmvd, only 1.4 tons per year (tpy) or 0.004 tpd of NOx emi ssion reductions will be achieved.

IV. GREENHOUSE GAS (GHG) EMISSIONS FOR CEQA PURPOSES

It is assumed that rich burn engines affe cted by this rule amendment already are equipped with NSCR. As such, there will be no GHG increase attributed to the richburn engine category at this time because t here is no change to the control technology.

For purposes of assessing environmental impac t, District staff assumes that operators of the lean-burn engines affected by the proposed rule amendments do not currently have SCR units, but will install SCR units as the control technology of choice In order to meet the rule’s stringent NO x emission limits. SCR cont rol technology can reduce the fuel efficiency of an engine by as much as 5%, meaning that 5% more fuel must be burned in order to have the same power output. Utilizing 5% as a conservatively high assumption for an engine's power penalty due to the use of an SCR system, and conservatively applying that power loss to the total rated horsepower of all engines affected by the rule changes (a total of 123,886 bhp), there is a 6,194 bhp increase.

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis August 18, 2011

B - 7 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 

### A carbon dioxide equivalents (CO2e) emi ssion factor of 385 g CO2e/bhp-hr was multiplied by the 6,194 hp of increased fuel usage, a 0.75 load factor; 8500 hours/year and some conversion factors to get an annual increase of 1,520 metric tons CO2e.

Based on the US Department of Energy’s “B uying an Energy-Efficient Electric Motor” Motor Challenge Fact Sheet, figures 1 and 2, an electric motor efficiency (mechanical power output divided by electric power input) of 90% or greater is expected for electric engines rated at 50 HP or greater and operating at 40% or greater load. Based on this document, the CO2e emissions from electric motors are 29% less than for natural gas fired engines. The 1,520 ton per year CO2e increase could be offset by 2.2 engines ([CO2e increase/(1-0.29)]/average hp of affect ed engines). Electrification of two to three engines is a plausible compliance outcome. Thus, the District concludes that implementation of the proposed revisions woul d have a less than cumulative significant impact on global climate change.

V. CONCLUSION

District staff estimated emission reductions fr om a subset of engines subject to Rule 4702. Using information from each permit, Distr ict staff calculated emission reductions from each affected engine. Emission reductions from individual engines were added together to get the total estimated emissi on reductions from all affected engines. District staff estimates that the pr oposed amendments to Rule 4702 will reduce NOx emissions by about 1.4 tpd. However, sinc e operators have the option to pay a fee in place of complying with the emission limits, no SIP credit can be taken for the emission reductions calculated as part of the rule pr oject. Emission reductions associated with fee payment programs allow the District to take credit for the emission reductions at the time the fee is paid rather than when the rule is submitted for inclusion in the SIP. Results of the emission reduction calcul ations are used for estimating cost effectiveness. The summarized emission reduc tions estimates are shown in Table 1 at the beginning of this appendix.

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis August 18, 2011

B - 8 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 Table 2 — Estimated Rich-Burn NOx Reducti ons for Calculating Cost Effectiveness

Power Output (bhp) Current PTO NOx Limit (ppmv) Proposed NOx Limit (g/bhp-hr) NOx Emission Reduction (tons/yr) SIC 80 25 11 0.08 1311 95 25 11 0.09 1311 95 50 11 0.26 1311 104 25 11 0.10 1311 115 20 11 0.07 1311 120 25 11 0.12 2911 120 25 11 0.12 2911 150 25 11 0.15 2911 151 25 11 0.15 1311 157 25 11 0.15 1311 157 25 11 0.15 1311 157 25 11 0.15 1311 157 25 11 0.15 1311 162 50 11 0.44 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis August 18, 2011

B - 9 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 Table 2 — Estimated Rich-Burn NOx Reductions for Calculating Cost Effectiveness (cont’d)

Power Output (bhp) Current PTO NOx Limit (ppmv) Proposed NOx Limit (g/bhp-hr) NOx Emission Reduction (tons/yr) SIC 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 162 25 11 0.16 1311 163 19 11 0.09 1311 165 25 11 0.16 2911 165 25 11 0.16 2911 165 25 11 0.16 2911 180 25 11 0.18 2911 180 25 11 0.18 2911 180 25 11 0.18 2911 180 25 11 0.18 1311 193 114 11 1.40 1389 195 25 11 0.19 1311 195 25 11 0.19 1311 195 25 11 0.19 1311 195 50 11 0.53 1311 195 25 11 0.19 1311 195 25 11 0.19 1311 195 25 11 0.19 1311 195 25 11 0.19 1311 195 25 11 0.19 1311 195 25 11 0.19 1311 195 25 11 0.19 1311 195 13 11 0.03 1311 195 25 11 0.19 1311 197 25 11 0.19 2099 199 25 11 0.20 1311 200 25 11 0.20 1311 208 50 11 0.57 1311 208 25 11 0.20 1311 208 25 11 0.20 1311 208 90 11 1.15 1311 208 25 11 0.20 1311 208 25 11 0.20 1311 220 50 11 0.60 1311 316 25 11 0.31 1311 316 25 11 0.31 1311 316 25 11 0.31 1311

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis August 18, 2011

B - 10 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 Table 2 — Estimated Rich-Burn NOx Reductions for Calculating Cost Effectiveness (cont’d)

Power Output (bhp) Current PTO NOx Limit (ppmv) Proposed NOx Limit (g/bhp-hr) NOx Emission Reduction (tons/yr) SIC 316 25 11 0.31 1311 325 25 11 0.32 1311 330 25 11 0.32 1311 365 25 11 0.36 1311 370 25 11 0.36 1311 370 25 11 0.36 1311 400 25 11 0.39 1311 400 25 11 0.39 1311 490 59 11 1.65 1311 490 59 11 1.65 1311 490 59 11 1.65 1311 490 59 11 1.65 1311 498 25 11 0.49 1311 498 25 11 0.49 1311 500 25 11 0.49 1311 500 25 11 0.49 1311 525 25 11 0.52 1311 525 25 11 0.52 1311 525 25 11 0.52 1311 525 25 11 0.52 1311 525 25 11 0.52 1311 525 25 11 0.52 1311 600 25 11 0.59 1311 615 25 11 0.60 1311 625 25 11 0.61 1311 640 25 11 0.63 1311 650 59 11 2.19 1311 650 59 11 2.19 1311 650 59 11 2.19 1311 650 59 11 2.19 1311 660 59 11 2.22 1311 765 25 11 0.75 1311 765 25 11 0.75 1311 765 25 11 0.75 1311 767 25 11 0.75 1311 767 25 11 0.75 1311 767 25 11 0.75 1311 800 25 11 0.79 1311 800 25 11 0.79 1311 880 25 11 0.86 1311 1000 59 11 3.37 1311 1000 59 11 3.37 1311

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis August 18, 2011

B - 11 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 Table 2 — Estimated Rich-Burn NOx Reductions for Calculating Cost Effectiveness (cont’d)

Power Output (bhp) Current PTO NOx Limit (ppmv) Proposed NOx Limit (g/bhp-hr) NOx Emission Reduction (tons/yr) SIC 1000 59 11 3.37 1311 1000 59 11 3.37 1311 1000 59 11 3.37 1311 1000 59 11 3.37 1311 1000 59 11 3.37 1311 1000 59 11 3.37 1311 1000 59 11 3.37 1311 1000 59 11 3.37 1311 1000 59 11 3.37 1311 1000 59 11 3.37 1311 1000 59 11 3.37 1311 1000 59 11 3.37 1311 1000 59 11 3.37 1311 1000 59 11 3.37 1311 1000 59 11 3.37 1311 1024 25 11 1.01 1311 1024 25 11 1.01 1311 1215 25 11 1.19 1311 1478 25 11 1.45 1311 1478 25 11 1.45 1311 1478 25 11 1.45 1311 1478 25 11 1.45 1311 1478 25 11 1.45 1311 1493 25 11 1.47 2037 1585 15 11 0.45 4931 1585 15 11 0.45 4931 1585 15 11 0.45 4931 1585 15 11 0.45 4931 1585 15 11 0.45 4931 1585 15 11 0.45 4931 1680 25 11 1.65 1311 1680 25 11 1.65 1311

TOTAL 131.5 (0.360 tons/day)

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis August 18, 2011

B - 12 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 Table 3 — Estimated Lean-Burn NOx Reducti ons for Calculating Cost Effectiveness

Power Output (bhp) Current PTO NOx Limit (ppmv) Proposed NOx Limit (ppmv) NOx Emission Reduction (tons/yr) SIC

220 75 11 0.91 4952

220 75 11 0.91 4952

220 75 11 0.91 4952

330 75 11 1.36 2911

330 75 11 1.36 2911

450 65 11 1.57 1311

450 65 11 1.57 1311

455 65 11 1.58 1311 577 64 11 1.97 4952

615 65 11 2.14 4941

615 65 11 2.14 4941

620 50 11 1.56 4952

620 65 11 2.16 4952

670 65 11 2.33 4952

892 50 11 2.24 4952

930 65 11 3.24 4953 1,000 123 79 2.85 1311 1,000 123 79 2.85 1311 1,000 123 79 2.85 1311 1,000 148 79 4.46 1311 1,000 148 79 4.46 1311 1,070 65 11 3.72 4941 1,070 65 11 3.72 4941 1,070 65 11 3.72 4941 1,150 65 11 4.00 4922 1,150 65 11 4.00 4911 1,150 65 11 4.00 4911 1,200 65 11 4.17 1311 1,200 65 11 4.17 1311 1,200 65 11 4.17 4941 1,408 65 11 4.90 4922 1,408 54 11 3.88 4952 1,408 62 11 4.66 4952 1,408 62 11 4.66 4952 1,500 65 11 5.22 4922 1,500 65 11 5.22 4922 1,500 148 79 6.69 1311 1,500 148 79 6.69 1311 2,000 65 11 6.96 1311 2,000 65 11 6.96 1311 2,000 65 11 6.96 1311 2,000 144 79 8.41 1311

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis August 18, 2011

B - 13 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 Table 3 — Estimated Lean-Burn NOx Reductions for Calculating Cost Effectiveness (Cont’d)

Power Output (bhp) Current PTO NOx Limit (ppmv) Proposed NOx Limit (ppmv) NOx Emission Reduction (tons/yr) SIC 2,000 144 79 8.41 1311 2,000 144 79 8.41 1311 2,000 144 79 8.41 1311 2,000 144 79 8.41 1311 4,000 136 79 14.75 1311 4,000 136 79 14.75 1311 4,000 136 79 14.75 1311 4,000 136 79 14.75 1311 4,000 136 79 14.75 1311 4,445 11.9 11 0.26 4922 4,445 11.9 11 0.26 4922 4,445 11.9 11 0.26 4922 4,445 11.9 11 0.26 4922 5,500 136 79 20.29 1311 5,500 136 79 20.29 1311 5,500 136 79 20.29 1311 5,500 136 79 20.29 1311 5,500 136 79 20.29 1311 5,500 136 79 20.29 1311 TOTALS 390.87

(1.0709 tons/day)

### SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emission Reduction Analysis August 18, 2011

B - 14 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4702 

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