SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reducti ons October 8, 2009



### APPENDIX B

BASELINE EMISSIONS AND EMIS SION 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 4692SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reducti ons October 8, 2009



### APPENDIX B Baseline Emissions and Emission Reduction Analysis

I. SUMMARY

The purpose of this analysis is to estima te the PM2.5 emission reductions for the revised proposed amendments Rule 4692 (Commerc ial 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 fa ctors 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 t he relative percentage of beef, chicken, and other meats cooked by restaurants, or for th at 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 em ission 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, al though the area source methodology has some flaws, an emissions/emission reductions analysis based on a
distribution of meats-cooked fr om this methodology would come closer to estimating
actual emissions and emission reductions. Wi th 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 am endments are estimat ed to have PM2.5
reductions of about 24% of baseli ne emission inventory (EI).

Table 1 - Baseline PM2.5 Emissi ons and Emission Reductions

Baseline PM2.5 Emissions – ch ain-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 4692SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reducti ons October 8, 2009

II. EMISSIONS AND EMISSION REDUCTION ANALYSIS

Although this rule project is based on a c ontrol measure in the District’s 2008 PM2.5 Plan, all of the protocols for charbroile r 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 em issions 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, Dis trict staff cannot
determine the number of restaur ants and by extension, the baseline emission inventory for this source category. In 2006, a consul tant was retained by the District to evaluate this source category to determine emissi on factors and to estimate the emission inventory for these sources. The cons ultant’s final product was an area source emission inventory methodology . In the general sense, the area source emission inventory methodology uses information fr om a South Coast Air Quality Management District restaurant survey and applies the su rvey 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 sour ce emission inventory methodology estimates
that there are a total of 427 chain-driven uni ts 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 em ission factor was taken from the area source emission inventory methodol ogy 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 st aff assumed that the profile of meat in the methodology is representative of what is act ually cooked. The fraction of meat cooked was multiplied by the emission fa ctor to yield a weighted emission factor. Adding all of the weighted em ission factors together is how the composite emission factor was calculated. This composite emission factor was us ed to calculate the baseline emissions and the rule project emission reductions. Table 2 shows the calculation for compos ite emission factor.

B-3 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4692SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reducti ons October 8, 2009

Table 2 – Composit e 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 subj ect to the control requi rements of Rule 4692, operators reported that they averaged about 1,100 pounds per week of meat cooked.
District staff used this number and the estimat ed 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 ex empt. Lacking data, Dis trict staff assumed
that 30% of the uncontrolled units c ook 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 ar e 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, t hese are called “exempt units.” Following the outlined steps,
District staff estimates that chain-driven c harbroilers 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 4692SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reducti ons October 8, 2009

Table 3 - Chain-Driven Charbro iler PM2.5 Baseline Emissions Emissions from Controlled Units that Cook 1,100 lb/week Amount of meat cooked per cont rolled 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 a ffected 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 ex empt 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 ch arbroilers (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 r equirements would affect only large and medium-sized restaurants, since owner/operat ors have two different ways to exempt their operations from cont rol 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 am endments. 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 4692SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT

Appendix B: Emissions and Emission Reducti ons October 8, 2009

this project, District staff assumed t hat an additional 30% of the chain-driven
charbroilers that are not curr ently subject to the rule wo uld become subject to control requirements due to the change in the exempti on level. A device control efficiency of 83% was applied for the emission reducti on 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 fr om 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 Operati ons” revised July 23, 2009.

2. Renald Harris, Air Quality Engineer SJVAPCD – personal communication January 2009.

3. Yu Vu, Air Quality Specialist SJ VAPCD – personal communication December
2008.

B-6 Final Staff Report with Appendices For Revised Proposed Amendments to Rule 4692