SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reductions October 8, 2009 

APPENDIX B 

BASELINE EMISSIONS AND EMISSION REDUCTION ANALYSIS 

FOR REVISED PROPOSED AMENDMENTS TO 

RULE 4692 (COMMERCIAL CHARBROILERS) 

October 8, 2009 

 B-1 Final Staff Report with Appendices 

For Revised Proposed Amendments to Rule 4692 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reductions October 8, 2009 

APPENDIX B 

Baseline Emissions and Emission Reduction Analysis 

I. SUMMARY 

The purpose of this analysis is to estimate the PM2.5 emission reductions for the 

revised proposed amendments Rule 4692 (Commercial Charbroiling) and to outline the 

methodologies used to calculate the emission reductions. This analysis also includes 

the assumptions made for the calculations. 

Although the rule itself controls PM10, this analysis uses the emission factors for PM2.5 

contained in the District’s 2006 Area Source Emissions Inventory Methodology for 

commercial cooking operations. Using the factors in this document allows a direct 

comparison between emission reductions achieved by the rule project and the emission 

reductions estimated in the District’s 2008 PM2.5 Plan. Because under-fired 

charbroilers would not be affected by Revised Proposed Rule 4692, no analysis of the 

baseline emissions was performed for these sources. 

There is no way to independently verify the relative percentage of beef, chicken, and 

other meats cooked by restaurants, or for that matter, how much meat is cooked per 

charbroiler. The June 2009 version of Appendix B made no attempt to apportion the 

estimated total amount of meat cooked per charbroiler between various types of meat. 

District staff used the highest single-meat emission factor and the lowest single-meat 

emission factor to place an upper and lower bound on the emission inventory. Because 

there is a 10-fold difference between the highest and lowest single-meat emission 

factors, the emission inventory and emission reductions showed a 10-fold difference. 

This did not provide clarity to the reader. For this analysis, District staff is using the 

meat-cooked profile from the area source methodology to estimate baseline emission 

inventory and emission reductions. District staff believes that, although the area source 

methodology has some flaws, an emissions/emission reductions analysis based on a 

distribution of meats-cooked from this methodology would come closer to estimating 

actual emissions and emission reductions. With a single number to work with, cost and 

cost effectiveness comparisons would have more utility. 

Table 1 summarizes the baseline emissions and estimated emission reductions from 

the proposed rule amendments. The calculation methodology is outlined in Section II of 

this appendix. Overall, the proposed amendments are estimated to have PM2.5 

reductions of about 24% of baseline emission inventory (EI). 

Table 1 - Baseline PM2.5 Emissions and Emission Reductions 

Baseline PM2.5 Emissions – chain-driven charbroilers 0.072 

PM2.5 Emission Reductions (tpd) 0.018 

Percent PM2.5 Reduction 24.4% 

 B-2 Final Staff Report with Appendices 

For Revised Proposed Amendments to Rule 4692 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reductions October 8, 2009 

II. EMISSIONS AND EMISSION REDUCTION ANALYSIS 

Although this rule project is based on a control measure in the District’s 2008 PM2.5 

Plan, all of the protocols for charbroiler testing use a test method that does not 

differentiate between PM, PM10, and PM2.5. For purposes of this analysis, it is 

assumed that reducing PM also reduces PM2.5 in the same proportion. This analysis 

will apply the control efficiency to PM2.5 emissions as estimated using the District’s 

2006 Area Source Emissions Inventory Methodology for commercial cooking 

operations. 

A. Baseline Emission Inventory 

Because very few restaurants hold a District Permit-to-Operate, District staff cannot 

determine the number of restaurants and by extension, the baseline emission inventory 

for this source category. In 2006, a consultant was retained by the District to evaluate 

this source category to determine emission factors and to estimate the emission 

inventory for these sources. The consultant’s final product was an area source 

emission inventory methodology. In the general sense, the area source emission 

inventory methodology uses information from a South Coast Air Quality Management 

District restaurant survey and applies the survey results to the San Joaquin Valley 

APCD based on the relative size of each air district’s population. District staff used 

information from the methodology in this rule project to calculate the baseline emission 

inventory and to estimate emission reductions. 

Chain-driven charbroilers can be divided into two groups – those currently subject to the 

rule and those that are not. The area source emission inventory methodology estimates 

that there are a total of 427 chain-driven units in the District. A query of the Permit 

Services Department database revealed that there are 215 units currently under permit 

(subject to the rule), leaving an estimated 212 chain-driven charbroilers that are not 

subject to the rule. 

An emission factor is a number that relates the amount of pollutant emitted to a unit of 

process activity. In this rule project, the emission factor was taken from the area source 

emission inventory methodology and has units of pounds of PM2.5 per ton (2,000 

pounds) meat cooked. There are different emission factors depending on the type of 

meat being grilled. For chain-driven charbroilers, District staff assumed that the profile 

of meat in the methodology is representative of what is actually cooked. The fraction of 

meat cooked was multiplied by the emission factor to yield a weighted emission factor. 

Adding all of the weighted emission factors together is how the composite emission 

factor was calculated. This composite emission factor was used to calculate the 

baseline emissions and the rule project emission reductions. Table 2 shows the 

calculation for composite emission factor. 

 B-3 Final Staff Report with Appendices 

For Revised Proposed Amendments to Rule 4692 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reductions October 8, 2009 

Table 2 – Composite Emission Factor 

 Fraction 

PM2.5 EF 

(lb/ton meat cooked) Partial EF 

Steak 0.1454 14.6 2.123

Hamburger 0.4915 14.6 7.176

Poultry (all) 0.2543 19.8 5.035

Pork 0.0355 19.8 0.703

Seafood 0.0733 6.4 0.469

Total (composite emission factor) 15.506

In a recent survey of operators already subject to the control requirements of Rule 4692, 

operators reported that they averaged about 1,100 pounds per week of meat cooked. 

District staff used this number and the estimated control efficiency of the control device 

to determine the emissions from controlled units. For uncontrolled units, District staff 

divided it into two sub-groups – units that would become subject to the rule’s control 

requirements and units that would remain exempt. Lacking data, District staff assumed 

that 30% of the uncontrolled units cook between 400 and 875 pound hamburgers per 

week, and average 600 pounds per week. These units would be affected by the 

proposed rule amendments and are tagged as “affected units.” The remaining 70% of 

the uncontrolled units cook less than 400 pounds per week with a group average of 250 

pounds per week. These units would remain exempt from the control requirements of 

the rule. In the tables, these are called “exempt units.” Following the outlined steps, 

District staff estimates that chain-driven charbroilers emit about 0.07 tons per day of 

PM2.5. Table 3 shows the steps in the calculation. 

 B-4 Final Staff Report with Appendices 

For Revised Proposed Amendments to Rule 4692 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reductions October 8, 2009 

Table 3 - Chain-Driven Charbroiler PM2.5 Baseline Emissions 

Emissions from Controlled Units that Cook 1,100 lb/week 

Amount of meat cooked per controlled charbroiler (tpy) 28.60

Composite emission factor (lb PM2.5/ton meat cooked) 15.51

Uncontrolled PM2.5 emissions per controlled charbroiler (tpy) 0.222

Percent control 83%

PM2.5 emissions (ton PM2.5/controlled charbroiler) 0.038

Number of controlled charbroilers 215

Total for all controlled charbroilers (tpy) 8.105

Total for all controlled charbroilers (tpd) 0.022

 

Emissions from Uncontrolled Units that Cook 600 lb/week 

(Affected) 

Amount of meat cooked per affected charbroiler (tpy) 15.60

Composite emission factor (lb PM2.5/ton meat cooked) 15.51

PM2.5 emissions per affected charbroiler (tpy) 0.121

Number of affected charbroilers (30% of all uncontrolled units) 64

Total for all affected charbroilers (tpy) 7.741

Total for all affected charbroilers (tpd) 0.021

 

Emissions from Uncontrolled Units that Cook 250 lb/week 

(Exempt) 

Amount of meat cooked per exempt charbroiler (tpy) 9.10

Composite emission factor (lb PM2.5/ton meat cooked) 15.51

PM2.5 emissions per exempt charbroiler (tpy) 0.071

Number of exempt charbroilers (70% of all uncontrolled units) 148

Total for all exempt charbroilers (tpy) 10.443

Total for all exempt charbroilers (tpd) 0.029

 

Total PM2.5 Baseline Emissions (controlled + uncontrolled) 

tons PM2.5 per year 26.29

tons PM2.5 per day 0.072

B. Estimated PM2.5 Emission Reductions 

For emissions reductions, the proposed rule requirements would affect only large and 

medium-sized restaurants, since owner/operators have two different ways to exempt 

their operations from control requirements: grill usage, and using low-emitting 

charbroilers. There is no data available to determine, in advance, how many units 

would be affected by the proposed rule amendments. Restaurant owner/operators are 

not required to report their meat purchases or cooking quantities to any agency. For 

 B-5 Final Staff Report with Appendices 

For Revised Proposed Amendments to Rule 4692 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reductions October 8, 2009 

this project, District staff assumed that an additional 30% of the chain-driven 

charbroilers that are not currently subject to the rule would become subject to control 

requirements due to the change in the exemption level. A device control efficiency of 

83% was applied for the emission reduction analysis. Following the methodology 

outlined above, estimated emission reductions are about 0.018 tons PM2.5 per day. 

Results of the calculations are shown in Table 4. 

Table 4 - PM2.5 Emission Reduction Calculations 

Number of Affected Units (Table 3) 64

Uncontrolled PM2.5 Emissions from Affected Units (tpy) 7.74

Required Control Efficiency 83%

PM2.5 Emission Reductions (tpy) 6.43

PM2.5 Emission Reductions (tpd) 0.018

III. REFERENCES 

1. San Joaquin Valley APCD - Area Source Emissions Inventory Methodology: 690 

– Commercial Cooking Operations” revised July 23, 2009. 

2. Renald Harris, Air Quality Engineer SJVAPCD – personal communication 

January 2009. 

3. Yu Vu, Air Quality Specialist SJVAPCD – personal communication December 

2008. 

 B-6 Final Staff Report with Appendices 

For Revised Proposed Amendments to Rule 4692