GOVERNING BOARD

Tom Wheeler, Chair Supervisor, Madera County

Oliver L

. Baines III
, Vice Chair Councilmember, City of Fresno

Sally J

. Bomprezzi Councilmember, City of Madera

Dennis Brazil Mayor, City of Gustine

John Capitman, Ph.D. Appointed by Governor

David Couch Supervisor, Kern County

Bob Elliott Supervisor, San Joaquin County

Virginia R. Gurrola Councilmember, City of Porterville

Harold Hanson Councilmember, City of Bakersfield

Buddy Mendes Supervisor, Fresno County

William O’Brien Supervisor, Stanislaus County

Craig Pedersen Supervisor, Kings County

Alexander C

. Sherriffs, M.D. Appointed by Governor

Hub Walsh Supervisor, Merced County

J

. Steven Worthley Supervisor, Tulare County

Seyed Sadredin Executive Director Air Pollution Control Officer

Northern Region Office 4800 Enterprise Way Modesto, CA 95356

- 8718 (209) 557

- 6400 • FAX (209) 557

- 6475

Central Region Office 1990 East Gettysburg Avenue Fresno, CA 93726

- 0244 (559) 230

- 6000 • FAX (559) 230

- 6061

Southern Region Office 34946 Flyover Court Bakersfield, CA 93308

- 9725 (661) 392

- 5500 • FAX (661) 392

- 5585

www.valleyair.org DATE: June 18, 2015

TO: SJV UAP CD G overning B oard

FROM: Seyed Sadredin, Executive Director/APCO Project Coordinator: Sheraz Gill

RE: ITEM NUMBER 7 : APPROVE NEXT STEPS FOR ADDRESSING EMISSIONS FROM UNDER

- FIRED COMMERCIAL CHARBROILERS AT VALLEY RESTAURANTS

RECOMMENDATION S :

1. Approve the proposed Restaurant Char broiler Technology Partnership program to fund particulate emission control technology demonstration projects for under

- fired charb r oilers at Valley restaurants

.

2. Appropriate $1.5 million for the Restaurant Charbroiler Technology Partnership program

.

3. Authorize Executive Director/APCO , on behalf of your board, to execute contract s with the Board Cha i r’s signature for projects selected under the Restaurant Charbroiler Technology Partnership program

.

BACKGROUND :

Due to the Valley’s geography, topography, and meteorology, the challenges that we face in meeting the federal health

- based ambient air quality standards are unmatched by any other region in the nation. In response to these federal mandates and to improve quality of life for Valley residents, the District has developed and implemented multiple generations of rules on various sources of air pollution. Since 1992, the District has adopted over 500 rules, requiring the installation and operation of the most effective air pollution control technologies and processes. Valley businesses are currently subject to the most stringent air quality regulations in the nation.SJV U

APCD Governing Board ITEM NUMBER 7: APPROVE NEXT STEPS FOR ADDRESSING EMISSIONS FROM UNDER

- FIRED COMMERCIAL CHARBROILERS AT VALLEY RESTAURANTS June 18, 2015
Despite significant progress in improving the Valley’s air quality, more reductions in emissions are needed to attain the ever toughening federal standards. Under the District’s 2012 PM2.5 Plan , 283.5 to ns per day of reductions in PM2.5, NOx and SOx are needed. The attainment plan contains a number of groundbreaking regulatory and incentive

- based measures to achieve these reductions. Consistent with the “leave no stone unturned” strategy, the District h as also been pursuing a measure aimed at reducing emissions from under

- fired commercial charbroilers with the goal of reducing emissions by 0.4 tons of PM2.5 per day.

Despite extensive efforts by California air districts, other states, and federal EPA, working control technologies for reducing particulate emissions from under

- fired charbroilers have remained elusive. The purpose of this item is to authorize investment and research to assess the feasibility and effectiveness of potential control technolo gies in real life use in San Joaquin Valley restaurants. If these efforts are successful in identifying cost

- effective technologies that can accommodate real life operating conditions, the District can then adopt a rule that would require utilization of s uch controls.

DISCUSSION :

Beginning in 2002, the District required installation and operation of particulate matter control devices on chain

- driven commercial charbroilers. The unavailability of a feasible and cost

- effective control technology has been the barrier to the District’ s attempt to impose similar requirements for under

- fired charbroiling operations. Other air districts in California have encountered similar difficulties in identifying and requiring compliant control technologies for under

- fired charbroilers.

Bay Area A ir Quality Management District In December 2007, Bay Area Air Quality Management District (BAAQMD) adopted Regulation 6, Rule 2 (Commercial Cooking Equipment) to regulate both chain

- driven and under

- fired charbroilers. Newly installed under

- fired charbroi lers with more than 10 square feet of cooking area are requir ed to limit emissions to 1 lb of PM10 per 1,000 lbs of cooked beef (greater than 90 % reduction in emissions ) . Effective January 2013, the same emissions requirements also apply to pre

- existing u nits. Under this rule, restaurants subject to the emission control requirements are required to install emission control technologies that are certified to meet the expected emissions reductions and obtain registrations. Although this rule was adopted in 2007 and has had requirements in effect since 2010, a significant portion of under

- fired charbroilers in the Bay Area are below the applicability thresholds based on the grill size or are below the throughput limits , and are thus exempt from rule requirem ents . Additionally, since adoption of the rule, the BAAQMD has not been able to certify any compliant control devices and subsequently has not registered any new or existing restaurants under their rule.

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APCD Governing Board ITEM NUMBER 7: APPROVE NEXT STEPS FOR ADDRESSING EMISSIONS FROM UNDER

- FIRED COMMERCIAL CHARBROILERS AT VALLEY RESTAURANTS June 18, 2015
South Coast Air Quality Management District In November 1997 South Coast Air Quality Management District ( SCAQMD ) adopted Rule 1138, which achieved 0.5 tons per day of PM10 emissions from chain

- driven charbroilers. In 1999 they amended their attainment plan to include a commitment to further reduce 0.9 tons per day of VOC and 7.0 tons per day of PM10 emissions. However, in August 2000, SCAQMD staff reported that cost

- effective controls for under

- fired charbroilers were limited and recommended substituting the remaining 0.9 tons per day of VOC emiss ions reductions assigned to this category with reductions from another control measure. Their 2003 air quality management plan (AQMP) included reducing PM10 from under

- fired charbroilers by 1 ton per day by 2010. However, a report to the SCAQMD Board in 2004 demonstrated that controls from under

- fired charbroilers were infeasible and again substituted emissions reductions from other adopted rules. To help advance the demonstration of these technologies, South Coast recommended funding for demonstration p rojects and their Board approved $200,000 to fund six to eight new or retrofit demonstration sites on large restaurants. However, no applications were received for that program. In 2008

- 2009, AQMD staff reinitiated rule development for restaurants with u nder

- fired charbroilers and held a series of working group meetings and a public workshop. Due to lack of demonstrable cost

- effective and affordable control technologies SCAQMD staff determined rule adoption at that time was not feasible. Based on the re search work discussed above, South Coast has tentative plans to adopt potential amendments to their charbroiling rule (Rule 1138) to establish control requirements for under

- fired charbroiling restaurants by the end of 2016.

**District’s Ongoing Evaluation**  **of Under**

**- Fired Charbroiler Control Technologies** 

As part of the September 2009 Rule 4692 amendments, the District conducted research and outreach to Valley restaurants to determine whether the rule applicability could be expanded to include under

- fired cha rbroilers and determined that there was a lack of credible and verifiable information necessary to evaluate the costs and reliability in the field of these technologies. Based on that determination, your Board directed staff to initiate the Charbroiler In centive Program (ChIP) to advance development of under

- fired charbroiler emissions control technologies, and authorized $500,000 of funding for the program. The Charbroiler Incentive program was open for 18 months, however, the program did not receive any applications.

Since 2009, the District has partnered with the South Coast Air Quality Management District (AQMD), Bay Area Air Quality Management District (AQMD), and EPA to further the r esearch and evaluation of emission control technologies for under

- fired charbroilers . Through this effort, under

- fired c harbroiler technology assessments have been conducted at UC

- Riverside College of Engineering’s Center for Environmental Research & Technology (CE

- CERT) . The District provided in

- kind technical support and the research was funded with over $500,000 in contributions provided by South Coast AQMD, Bay Area AQMD, and EPA. The initial task under this effort was to review commercially available, prototype, an d experimental charbroiler control technologies. The evaluation identified three technologies to be tested by CE

- CERT in

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APCD Governing Board ITEM NUMBER 7: APPROVE NEXT STEPS FOR ADDRESSING EMISSIONS FROM UNDER

- FIRED COMMERCIAL CHARBROILERS AT VALLEY RESTAURANTS June 18, 2015
the final phase of the study. The three technologies chosen represented a cross

section of control options, including a rooftop venti lation system design, a dedicated hood design, and a process design. Additional testing has been performed on several other systems and is ongoing as more technologies have been identified to be potentially feasible solutions.

While the testing methods used in this CE

- CERT testing process have been rigorously evaluated and determined to be highly accurate, the entire process is performed in CE

CERT’s charbroiler test kitchen. The preparation and execution of the cooking process is highly controlled and precise ly repeated for every test run for each control system so that the results are comparable for each device. Although the controlled nature of this test kitchen is able to effectively quantify the control efficiency of each control system, it does n ot allow for an appropriate assessment of the feasibility of installation or ongoing operation and maintenance.

**Proposed Restaurant Charbroiler Technology Partnership**

The District committed in the 2012 PM2.5 Plan to achieving 0.4 tons per day of directly

emitted PM2.5 emissions through the extension of Rule 4692 requirements to under

fired charbroilers. In recognition of the many questions and concerns remaining with respect to feasibility and cost, the District established a target date of 2016 for adop tion of these new requirements, with an anticipated compliance date of 2017 for restaurants subject to the new emission control requirements

.

A lthough under

- fired charbroiler technology advancements have been made, including successful testin g of technologies in the CE

- CERT test kitchen , these technologies are still un

- tested in real

- life application s and need further evaluation and demonstration at Valley restaurants

. With the importance of achieving direct PM2.5 emissions reductions from under

- f ired charbroilers and i n order to consider the potential requirements to install control system s during the upcoming amendments to Rule 4692, t he District must have a comprehensive understanding of the under

- fired charbroiler restaurant industry and the sp ecifics of each technology. T echnological feasibility issues and logistical issues such as the need to modify hoods and exhaust systems and reinforce roof supports in addition to the purchase, installation, maintenance, and labor costs must all be evaluat ed.

The proposed Restaurant Charbroiler Technology Partnership (RCTP) will connect under

- f ired charbroiler control system manufacturers with restaurants who are interested in installing these control systems. Since these restaurants will be early adopters of under

- fired charbroiler technology and will be providing a platform to demonstrate the effectiveness of the control systems, the District is proposing to fund these demonstration pro jects including the full cost of purchase, installation, operation, maintenance of control equipment, and other costs such as modifications to the existing system configurations and structural reinforcements.

According to estimates submitted by manufact urers for RCTP, the initial capital costs of

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APCD Governing Board ITEM NUMBER 7: APPROVE NEXT STEPS FOR ADDRESSING EMISSIONS FROM UNDER

- FIRED COMMERCIAL CHARBROILERS AT VALLEY RESTAURANTS June 18, 2015

fe asible control technologies could range from $40,000 to over $100,000, with monthly operation and maintenance costs ranging from a few thousand dollars to tens of thousands of dollars per year

. It i s possible that different facility types or facilities with different average throughputs will require different control technologies

. As such, the District believes it is critical to develop and demonstrate as many different technologies as possible.

Restaurants eligible for funding under the proposed program will be required to follow the below guidelines :

• T echnology manufacturer must partner with a Valley restaurant and enter a three

- party agreement with the District.

• T echnology should be operated and maintained for at least two years.

• The participants will be required to continually evaluate the control system and submit reports to the District , including information necessary to evaluate the technological feasibility and cost of installing and operating the control system

.

• Funding should not be used for indirect costs, including travel costs, administrative costs, or report generation

.

• Funding should not be used for staff time not related to installation, maintenance, or operation of the control equipment

.

• Participants will be required to meet minimum performance criteria outlined in the Statement of Work, specific to each project

.

• Participants will be required to make fiscally reasonable efforts to continue operating the control equipment even after demonstration project completion

.

Th e demonstration projects will provide important data integral to the success of potential rule amendments to Rule 4692. Data resulting from these projects will include real

- world costs for the installation, operation, and maintenance of the units as well as provide a demonstration of the overall effectiveness of various available technologies, thus providing more options for restaurants to choose from in order to comply with potential rule requirements.

I f the Restaurant Charbroiler Technology Partnership is approved by your Board, t he District will expand its outreach efforts with Valley restaurants and restaurant representatives to build partnerships and encourage participation in the program. Through t he proposed $1.5 million in funding, the District anticipates funding up to 10 projects at Valley restaurants

. Over the past year, the District has been working closely with technology manufacturers and Valley restaurants to identify several potential projects . One potential project is estimated to achieve emissions reductions with a cost effectiveness of approximately $8,200 per ton of particulate emissions reduced. As a result of this early outreach effort, the District could offer funding and begin demonstration projects with Valley

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APCD Governing Board ITEM NUMBER 7: APPROVE NEXT STEPS FOR ADDRESSING EMISSIONS FROM UNDER

- FIRED COMMERCIAL CHARBROILERS AT VALLEY RESTAURANTS June 18, 2015

restaurant partners in the next few months.

FISCAL IMPACT :

Sufficient appropriations are included in the 2015

- 16 Budget to fund the proposed program under the Technology Advancement Program.

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