SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emissions Reduction Analysis October 16, 2008

 Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4306 

and Rule 4307 and Proposed New Rule 4320

B - 1 

APPENDIX B 

EMISSIONS REDUCTION ANALYSIS FOR PROPOSED AMENDMENTS 

TO RULE 4306 AND RULE 4307 AND PROPOSED NEW RULE 4320 

October 16, 2008
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emissions Reduction Analysis October 16, 2008

 Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4306 

and Rule 4307 and Proposed New Rule 4320

B - 2 

APPENDIX B 

EMISSIONS REDUCTION CALCULATIONS FOR RULES 4306, 4307, 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 rated 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 approximately 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 Emissions 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 comply 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 additional reductions were assumed to occur 

from these units in either of the two scenarios. 

The Current Emissions of the affected units was calculated 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 refinery units were assumed to be 

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

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

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

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

at less than 5 ppmv NOx. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emissions Reduction Analysis October 16, 2008

 Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4306 

and Rule 4307 and Proposed New Rule 4320

B - 3 

Based on the calculations shown in Table B-2, the proposed controls would result in 

emission reductions of 3.3 tons of NOx/day. This is 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 reduction 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 Ozone 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 assumptions 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 would be expected from Rule 

4320 implementation. 

III. Emissions Reductions for SO2 – Rule 4320 

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

options to comply with the particulate matter controls: 

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

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

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

hundred standard cubic feet; or

3. Install and properly operate an emission control system that reduces SO2

emissions by at least 95% by weight; or limit exhaust SO2 to less than or equal to 9 

ppmv corrected to 3.0% O2. 

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

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

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

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

chooses to comply with option 3 and installs and operates an emission control system. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emissions Reduction Analysis October 16, 2008

 Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4306 

and Rule 4307 and Proposed New Rule 4320

B - 4 

District staff identified approximately 230 permitted boilers, steam generators, and 

process heaters that may need to install and operate 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 were performed using capacity factors 

of 75% and 50% for the entire group. 

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

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

emission reductions of 5.4 tons of SO2/day. This is 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 achieved by replacing and retrofitting 

school boilers, steam generators, and process heaters 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 than 1.8 billion Btu per calendar year heat 

input. Four percent of the 1,179 total affected units, 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 101 units qualified for the 5.0 billion Btu 

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

at 5.0 billion Btu per calendar year heat input equals 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 records 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 uncontrolled NOx emission level of 82 

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

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

capacity. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emissions Reduction Analysis October 16, 2008

 Final Draft Staff Report with Appendices 

 For Proposed Amendments to Rule 4306 

and Rule 4307 and Proposed New Rule 4320

B - 5 

Based on these assumptions, total estimated NOx emissions are 1.8 tons per day. The 

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

baseline. 

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

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

future as the final equipment registrations are received and the emissions inventory is 

updated. 

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

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

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

As is shown in this analysis, the proposed rule would 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 inventory 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 would be in compliance with the 

proposed SO2 control requirements, and therefore would not have any additional 

compliance costs. If a unit units is fired on refinery 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 content to the level being proposed in the draft 

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

sulfur content being proposed is currently being achieved 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 DISTRICT 

Appendix B: Emissions Reduction Analysis 

 Final Draft Staff Rep

 For Proposed Amen

and Rule 4307 and Prop

B - 6 

Table B-2 NOx Emissions Reduction Calculation for Rule 4320 Standard Limits

Category Category # of Units

Total 

MMBtu/hr 

Operating 

Capacity

Current 

ppmv 

Current 

lb/MMBtu

Current 

Emission 

(tpd) 

New 

ppmv

New 

lb/MMBtu

New 

Emission 

(tpd) 

> 5 to 20.0 

MMBtu/hr A 374 6,128.99 0.50 15 0.018 0.662

9 0.011 0.405 

Units currently 

< 5 ppm A’ 

4 47.27 0.50

5 0.0062 0.002

5 0.0062 0.002 

> 20.0 

MMBtu/hr B 283 18,103.13 0.50

9 0.011 1.195

7 0.008 0.869 

Units currently 

< 5 ppm B’ 46 2,466.02 0.50

5 0.0062 0.092

5 0.0062 0.092 

Oilfield Steam 

Generators C 1 

6 107.50 0.75 15 0.018 0.017

9 0.011 0.011 

C 2 232 16,196.86 0.75 15 0.018 2.624

7 0.008 1.166 

C 3 209 11,475.20 0.75 15 0.018 1.859 12 0.014 1.446 

C 3 209 11,475.20 0.75 12 0.014 1.446

9 0.011 1.136 

 

Refinery Units D 1 31 361.70 0.75 30 0.036 0.117

9 0.011 0.036 

 D 2 39 2,126.35 0.75 25 0.031 0.593

6 0.0074 0.142 

 D 3 

2 409.00 0.75

5 0.0062 0.023

5 0.0062 0.023 

 

TOTAL 1,176 7.09 3.88 

Percent Reduction 

Percent Reduction = (Reductions / Current Emissions) * 100 = (3.30 / 7.09) * 100 = 46.5% 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emissions Reduction Analysis 

 Final Draft Staff Rep

 For Proposed Amen

and Rule 4307 and Prop

B - 7 

Table B-3 NOx Emissions Reduction Calculation for Rule 4320 Enhanced Limi

Category Category #Units 

Total 

MMBtu/hr 

Operating 

Capacity

Current 

ppmv 

Current 

lb/MMBtu

Current 

Emission 

(tpd) 

New 

ppmv

New 

lb/MMBtu

New 

Emission 

(tpd) 

> 5 to 20.0 

MMBtu/hr A 374 6,128.99 0.50 15 0.018 0.662

6 0.0074 0.272 

Units currently 

< 5 ppm A’ 

4 47.27 0.50

5 0.0062 0.002

5 0.0062 0.002 

> 20.0 

MMBtu/hr B 283 18,103.13 0.50

9 0.011 1.195

5 0.0062 0.673 

Units currently 

< 5 ppm B’ 46 2,466.02 0.50

5 0.0062 0.092

5 0.0062 0.092 

Oilfield Steam 

Generators C 1 

6 107.50 0.75 15 0.018 0.017

6 0.0074 0.007 

C 2 232 16,196.86 0.75 15 0.018 2.624

9 0.011 1.603 

C 2 232 16,196.86 0.75

9 0.011 1.603

5 0.0062 0.904 

C 3 209 11,475.20 0.75 15 0.018 1.859 12 0.014 1.446 

C 3 209 11,475.20 0.75 12 0.014 1.446

9 0.011 1.136 

 

Refinery Units D 1 31 361.70 0.75 30 0.036 0.117

6 0.0074 0.024 

 D 2 39 2,126.35 0.75 25 0.031 0.593

9 0.011 0.211 

 D 2 39 2,126.35 0.75

9 0.011 0.211

5 0.0062 0.119 

 D 3 

2 409.00 0.75

5 0.0062 0.023

5 0.0062 0.023 

 

TOTAL 1,176 66,383.93 7.09 3.25 

Percent Reduction 

Percent Reduction = (Reductions / Current Emissions) * 100 = (3.93 / 7.09) * 100 = 55.4% 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: Emissions Reduction Analysis 

 Final Draft Staff Rep

 For Proposed Amen

and Rule 4307 and Prop

B - 8 

Table B-4 SO2 Reduction Calculation for Rule 4320 

Total # 

of Units

Rated 

Heat Input 

MMBtu/hr 

Capacity 

Factor Hours/yr 

Uncontrolled 

EF

A

, 

lb/MMBtu

Uncontrolled 

SO2 emissions 

tons/day

Controlled 

EF

B

, 

lb/MMBtu

Controlle

emiss

tons/

230.0 12827.9 75% 8760 0.0633 7.31 0.0169 1.9230.0 12827.9 50% 8760 0.0633 4.87 0.0169 1.3

AUncontrolled EF = 0.0633 lb SO2/MMBtu based on assumption of uncontrolled 300 ppmv S (measured as H2S) in fuel gas BControlled EF = 0.0169 lbSO2/MMBtu based on limit of 80 ppmv S (measured as H2S) in fuel gas 

Table B-5 Calculated Emissions Reductions from Rule 4307

 #Units 

Total 

MMBtu/hr 

Operating 

Capacity 

Current 

ppmv 

Current 

lb/MMBtu 

Current 

Emission 

(tpd) 

New 

ppmv 

New 

lb/MMB

Natural Draft Units 27 92.55 0.75 82 0.1 0.083 30 0.036 

Glycol Reboilers 8 33.9 0.75 82 0.1 0.031 30 0.036 

School Units 380 1900 0.55 82 0.1 1.254 30 0.036 

Low Use Units >1.8 54 469.2 0.75 82 0.1 0.422 30 0.036 

Total 469 1.79 

 Percent Reduction 

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 is 8.6 tons/day Percent Reduction = Total Reductions divided by Total Current Emissions multiplied by 100 = 1.15/1.79 x 100 = 64.2% Total Emissions Reduction based on PM10 Plan baseline (2006) emissions inventory = 2.59 tons per day