# SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Emissions Reduction Analysis Octo ber 16, 2008

Final Draft Staff Report with Appendices

For Proposed Amendments to Rule 430 6

and Rule 4307 and Proposed New Rule 4320 

# B - 1 

# APPENDIX B

EMISSIONS REDUCTION ANALYSIS FOR PROPOSED AMENDMENT S

TO RULE 4306 AND RULE 4307 AND PROPOSED NEW RULE 43 20

October 16, 2008

# SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Emissions Reduction Analysis Octo ber 16, 2008

Final Draft Staff Report with Appendices

For Proposed Amendments to Rule 430 6

and Rule 4307 and Proposed New Rule 4320 

# B - 2 APPENDIX B

EMISSIONS REDUCTION CALCULATIONS FOR RULES 4306, 43 07, AND 4320

I. Summary

As shown in this analysis, the proposed amendments will result in total emission

reductions of 4.5 tons NOx/Day and 3.6 tons SOx/day

.

Table B-1 Emission Summaries

Rule NOx Baseline

(tons/day) NOx Reductions

(tons/day) SOx Baseline

(tons/day) SOx Reductions

(tons/day)

4320 7.1 3.3 4.9 3.6

4307 1.8 1.2 Not calculated 0.0

Totals 8.9 4.5 4.9 3.6

II. Emissions Reductions for NOx – Rule 4320

District staff used the Permit Database to identify the number of boilers, steam

generators, and process heaters as well as the rate d heat input of each unit so they

could be appropriately distributed in the range of rated heat inputs for which different

emission limits are established. There are approxi mately 1,176 permitted boilers,

steam generators, and process heaters that would be affected by amendments to Rule

4320.

The NOx emissions reductions, as shown in the Emiss ions Reduction Calculation

Tables B-2 and B-3, are derived for two scenarios. Reductions in the first scenario,

Table B-2, were calculated with the assumption that the affected units would comply

with the standard limits in Rule 4320. The second scenario, Table B-3, reductions were

calculated assuming that the affected units would c omply with the applicable enhanced

limits in Rule 4320. District staff identified 50 units that currently meet the applicable

proposed emission limit in Rule 4320. No additiona l reductions were assumed to occur

from these units in either of the two scenarios.

The Current Emissions of the affected units was cal culated in based on the assumption

that all units were meeting the current NOx limits in the rule. Based on the Emission

Inventory data, the oilfield steam generators and r efinery units were assumed to be

operated at 75% of their maximum rated heat input c apacity while all other units were

assumed to operate at 50% capacity. The New Emiss ions were calculated in the same

manner but assuming the units met the applicable pr oposed NOx limits in new Rule

4320. Again, no emission reductions were assumed f or the 50 units currently operating

at less than 5 ppmv NOx.

# SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Emissions Reduction Analysis Octo ber 16, 2008

Final Draft Staff Report with Appendices

For Proposed Amendments to Rule 430 6

and Rule 4307 and Proposed New Rule 4320 

# B - 3 Based on the calculations shown in Table B-2, the p roposed controls would result in

emission reductions of 3.3 tons of NOx/day. This i s a reduction of 46.5% from the

calculated baseline of 7.1 tons of NOx/day.

The 2007 Ozone Plan had a 2011 baseline of 4.6 tons of NOx per day with a

commitment to reduce emissions by 0.71 tons NOx/day or 15%. To effectively

compare the two baselines, the calculated percent r eduction is multiplied by the Plan

baseline.

Normalized emission reduction = 4.6 tons per day NOx x 46.5%

= 2.1 tons per day NOx

Therefore the proposed controls satisfy the 2007 Oz one Plan commitment of 0.71 tons

NOx/Day and provide a surplus reduction of 1.2 tons NOx/day.

The Table B-3 calculations were based on the same a ssumptions but assumed that the

operators would choose to comply with the Enhanced schedules. This would result in

an emission reduction of 3.9 tons NOx/day which is an additional 0.6 tons NOx/day.

This would represent the maximum reductions which w ould be expected from Rule

4320 implementation.

III. Emissions Reductions for SO2 – Rule 4320

Rule 4320 Section 5.4 (Particulate Matter Control R equirements) gives operators three

options to comply with the particulate matter contr ols:

1. Fire exclusively on PUC-quality natural gas, com mercial propane, butane, or

liquefied petroleum gas, or a combination of these gases; or

2. Limit fuel sulfur content to no more than five g rains of total sulfur per one

hundred standard cubic feet; or

3. Install and properly operate an emission control system that reduces SO 2 

# emissions by at least 95% by weight; or limit exhau st SO 2 

# to less than or equal to 9

ppmv corrected to 3.0% O2.

Staff believe the majority of units would comply wi th Options 1 and 2 since these units

are either fired with PUC quality natural gas or pr opane, or at facilities which have fuel

sulfur scrubbers as part of their operation. No ad ditional reductions are expected from

these units. SO2 emission reductions would, howeve r, be achieved if an operator

chooses to comply with option 3 and installs and op erates an emission control system.

# SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Emissions Reduction Analysis Octo ber 16, 2008

Final Draft Staff Report with Appendices

For Proposed Amendments to Rule 430 6

and Rule 4307 and Proposed New Rule 4320 

# B - 4 District staff identified approximately 230 permitt ed boilers, steam generators, and

process heaters that may need to install and operat e an emission control system

reducing SO2 emissions by at least 95%.

The SO2 emissions reductions, Table B4, assume the emissions are reduced from an

uncontrolled level of 300 ppmv to 80 ppmv H2S which is the equivalent of the sulfur

content of PUC quality natural gas. Calculations w ere performed using capacity factors

of 75% and 50% for the entire group.

Because these units are primarily oilfield steam ge nerators or refinery units, they would

most likely be operated at the higher capacity fact or of 75%. This would result in

emission reductions of 5.4 tons of SO2/day. This i s a reduction of 73.9% from the

calculated baseline of 7.3 tons of SO2/day.

IV. Emissions Reductions for NOx – Rule 4307

NOx emission reductions from Rule 4307 would be ach ieved by replacing and retrofitting

school boilers, steam generators, and process heate rs that are currently exempt by Rule

4307. Additionally, emissions reduction would come from units with a heat input between

1.8 billion and 5.0 billion Btu per calendar year; atmospheric units in an oilfield or refinery;

and glycol reboilers.

District consultant Pacific Environmental Services, Inc. (PES) prepared a report titled

Emission Inventory Improvements For Selected Source Categories: External Combustion

Boilers, Steam Generators and Process Heaters . In the report, PES stated that

approximately 4% of the affected units use less tha n 1.8 billion Btu per calendar year heat

input. Four percent of the 1,179 total affected un its, estimated at when Rule 4307 was

adopted, would equal 47 operating at less than 1.8 billion Btu/year.

District staff also estimated that approximately 10 1 units qualified for the 5.0 billion Btu

per calendar year fuel usage limit. Subtracting th ese 47 units from the 101 low use units

at 5.0 billion Btu per calendar year heat input equ als 54 units with fuel inputs between

1.8 billion Btu/year and 5.0 billion Btu/year.

In addition to these 54 low-use units, District rec ords indicate there are 8 glycol

reboilers, 27 atmospheric heater treaters, and 380 units at schools. Table B-5 details the

calculations for these units assuming a current unc ontrolled NOx emission level of 82

ppmv NOx and a final level of 30 ppmv of NOx. It w as assumed that school units

operate at 55% of rated capacity and the other unit s operate at 75% of their rated

capacity.

# SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DI STRICT

Appendix B: Emissions Reduction Analysis Octo ber 16, 2008

Final Draft Staff Report with Appendices

For Proposed Amendments to Rule 430 6

and Rule 4307 and Proposed New Rule 4320 

# B - 5 Based on these assumptions, total estimated NOx emi ssions are 1.8 tons per day. The

total estimated NOx emissions reductions are 1.2 to ns per day or 64.2% of the initial

baseline.

No calculations are made for units installed to mee t the 12 ppmv and 9 ppmv emission

limits since that will depend on unit turnover. Su ch calculations may be provided in the

future as the final equipment registrations are rec eived and the emissions inventory is

updated.

In the 2008 PM10 Plan, estimated that total NOx emi ssions from this category (all units

rated between 2.0 and 5.0 MMBtu/hr) was 3.78 ton/da y (winter 2009 average). Final

reductions were not presented in the Plan since the y will occur after the 2014 deadline.

As is shown in this analysis, the proposed rule wou ld achieve NOx emissions reduction

of 64.2% of the calculated baseline. Applying this percent reduction to the planning

baseline produces a Normalized emission reduction:

Normalized emission reduction = 3.78 ton NOx/day x 64.2%

= 2.4 ton NOx/day reduction

This number may be applied to the final emissions i nventory and used in future plan

updates.

V. Emissions Reductions for SOx – Rule 4307

According to the District records, a large majority of the units are already firing on PUC

quality natural gas, propane, butane, or LPG and wo uld be in compliance with the

proposed SO2 control requirements, and therefore wo uld not have any additional

compliance costs. If a unit units is fired on refi nery gas or thermally enhanced oil

recovery gas along with a mixture of such gases and PUC quality natural gas, that unit

could comply by limiting the fuel gas sulfur conten t to the level being proposed in the draft

rule. Preliminary information obtained from some s takeholders indicate that the fuel gas

sulfur content being proposed is currently being ac hieved without installing additional

sulfur control system, and therefore no additional costs are anticipated to comply with

SO2 requirements.SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTAppendix B: Emissions Reduction Analysis October 16, 2008Final Draft Staff Report with AppendicesFor Proposed Amendments to Rule 4306and Rule 4307 and Proposed New Rule 4320B - 6Table B-2 NOx Emissions Reduction Calculation forRule 4320 Standard LimitsCategory Category # of UnitsTotalMMBtu/hrOperatingCapacityCurrentppmvCurrentlb/MMBtuCurrentEmission(tpd)NewppmvNewlb/MMBtuNewEmission(tpd)Reduction(tpd)ReductionbyCategory(tpd)> 5 to 20.0MMBtu/hr A3746,128.990.50150.0180.66290.0110.4050.257Units currently< 5 ppm A’447.270.5050.00620.00250.00620.0020.0000.257> 20.0MMBtu/hr B28318,103.130.5090.0111.19570.0080.8690.326Units currently< 5 ppm B’462,466.020.5050.00620.09250.00620.0920.0000.326Oilfield SteamGenerators C 16107.500.75150.0180.01790.0110.0110.007C 223216,196.860.75150.0182.62470.0081.1661.458C 320911,475.200.75150.0181.859120.0141.4460.413C 320911,475.200.75120.0141.44690.0111.1360.3102.187Refinery Units D 131361.700.75300.0360.11790.0110.0360.081D 2392,126.350.75250.0310.59360.00740.1420.452D 32409.000.7550.00620.02350.00620.0230.0000.533TOTAL1,1767.093.883.303.304PercentReduction46.5%Percent Reduction = (Reductions / Current Emissions) * 100 = (3.30 / 7.09) * 100 = 46.5%SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTAppendix B: Emissions Reduction Analysis October 16, 2008Final Draft Staff Report with AppendicesFor Proposed Amendments to Rule 4306and Rule 4307 and Proposed New Rule 4320B - 7Table B-3 NOx Emissions Reduction Calculation forRule 4320 Enhanced LimitsCategory Category#UnitsTotalMMBtu/hrOperatingCapacityCurrentppmvCurrentlb/MMBtuCurrentEmission(tpd)NewppmvNewlb/MMBtuNewEmission(tpd)Reduction(tpd)ReductionbyCategory(tpd)> 5 to 20.0MMBtu/hr A3746,128.990.50150.0180.66260.00740.2720.390Units currently< 5 ppm A’447.270.5050.00620.00250.00620.0020.0000.390> 20.0MMBtu/hr B28318,103.130.5090.0111.19550.00620.6730.521Units currently< 5 ppm B’462,466.020.5050.00620.09250.00620.0920.0000.521Oilfield SteamGenerators C 16107.500.75150.0180.01760.00740.0070.010C 223216,196.860.75150.0182.62490.0111.6031.020C 223216,196.860.7590.0111.60350.00620.9040.700C 320911,475.200.75150.0181.859120.0141.4460.413C 320911,475.200.75120.0141.44690.0111.1360.3102.453Refinery Units D 131361.700.75300.0360.11760.00740.0240.093D 2392,126.350.75250.0310.59390.0110.2110.383D 2392,126.350.7590.0110.21150.00620.1190.092D 32409.000.7550.00620.02350.00620.0230.0000.568TOTAL1,17666,383.937.093.253.933.93PercentReduction55.4%Percent Reduction = (Reductions / Current Emissions) * 100 = (3.93 / 7.09) * 100 = 55.4%SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICTAppendix B: Emissions Reduction Analysis October 16, 2008Final Draft Staff Report with AppendicesFor Proposed Amendments to Rule 4306and Rule 4307 and Proposed New Rule 4320B - 8Table B-4 SO2 Reduction Calculation for Rule 4320Total #of UnitsRatedHeat InputMMBtu/hrCapacityFactor Hours/yrUncontrolledEFA,lb/MMBtuUncontrolledSO2 emissionstons/dayControlledEFB,lb/MMBtuControlled SO2emissions,tons/daySO2Reductionton/day230.012827.975%87600.06337.310.01691.955.36230.012827.950%87600.06334.870.01691.303.57AUncontrolled EF = 0.0633 lb SO2/MMBtu based on assumption of uncontrolled 300 ppmvS (measured as H2S) in fuel gasBControlled EF = 0.0169 lbSO2/MMBtu based on limit of 80 ppmv S (measured as H2S) in fuel gasTable B-5 Calculated Emissions Reductions from Rule 4307#UnitsTotalMMBtu/hrOperatingCapacityCurrentppmvCurrentlb/MMBtuCurrentEmission(tpd)NewppmvNewlb/MMBtuNewEmission(tpd)Reductions(tpd)Natural Draft Units27 92.55 0.75 82 0.1 0.083 30 0.036 0.030 0.053Glycol Reboilers8 33.9 0.75 82 0.1 0.031 30 0.036 0.011 0.020School Units380 1900 0.55 82 0.1 1.254 30 0.036 0.451 0.803Low Use Units >1.854 469.2 0.75 82 0.1 0.422 30 0.036 0.152 0.269Total 469 1.79 0.644 1.15PercentReduction64.2%Percent Reduction = (Reductions / Current Emissions) * 100 = (1.15 / 1.79) * 100 = 64.2%The PM10 Plan baseline (2006) emission inventory for boilers, steam generators, and process heaters is8.6 tons/dayPercent Reduction = Total Reductions divided by Total Current Emissions multiplied by 100 = 1.15/1.79x 100 = 64.2%Total Emissions Reduction based on PM10 Plan baseline (2006) emissions inventory = 2.59 tons per day