2008 PM2.5 Plan 

## Appendix I

Candidate Control Measures2008 PM2.5 Plan This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-1 

## Appendix I: Candidate Control Measures

The San Joaquin Valley Unified Air Pollution Control District (District) conducted an exhaustive search for emi ssions reductions to use in meeting federal Clean Air Act requirements for this 2008 PM2.5 Plan . Chapter 6 details the District’s process for developing control measures for reducin g emissions of primary PM2.5 and PM2.5 precursors. This Appendix pres ents the product of this pr ocess: a master list of all candidate control measure ideas identifi ed and evaluated for this plan. After assembling Appendix I, the District then scre ened the candidate measures into several categories: high priority measures to be im plemented in the years immediately following plan adoption; measures that might be implemented in future years to allow for expected technology development; and those m easures that require further study to identify when they could be im plemented and what reductions they could achieve.

Candidate control measure descriptions in Appendix I have the following major components:

 Title and Number

 Source Category Affected

 Emissions Inventory

 Current Control

 Future Control Options

 Future Incentive Options

 Discussion

 Recommendations

 Potential Projected Reductions (not applic able to feasibility study measures)

Not all of the candidate control measures in this appendix result in control measure commitments or feasibility study measures. Chapter 6 presents a schedule for control measure adoption and implementation commitm ents, as well as expected emissions reductions. Chapter 6 also includes the Distr ict’s list of feasibility study measures. Study measures that point toward possi ble emission reduction opportunities will be included in future plan updates as control measure commitments.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-2 This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-3 

## Appendix I - Table of Contents

Control Measure Title Reference Number * Page

Open Burning S-AGR-1 I-4

Conservation Management Practices S-AGR-2 I-7

Boilers, Steam Generators & Process H eaters >5 MM Btu/hr S-COM-1 I-10

Boilers, Steam Generators & Process H eaters 2-5 MM Btu/hr S-COM-2 I-14

Boilers, Steam Generators & Process H eaters > 0.075 MM Btu/hr S-COM-3 I-17

Solid Fuel Boilers, Steam Generators, Process Heaters S-COM-4 I-20

Stationary Gas Turbines S-COM-5 I-22

Reciprocating Internal Combustion Engines S-COM-6 I-25 Small Spark-Ignited Engines and Agricultural Spark-Ignited Engines S-COM-6A I-28

Glass Melting Furnaces S-COM-7 I-31

Lime Kilns S-COM-8 I-33

Residential Water Heaters S-COM-9 I-35

Natural Gas-Fired, Fan Type Residential Central Furnace S-COM-10 I-37

Dryers S-COM-11 I-39

Wood Burning Fireplaces and Wood Burning Heaters S-COM-14 I-41

Prescribed Burning and Hazard Reduction Burning S-GOV-6 I-43

Cotton Gins S-IND-8 I-45

Commercial Charbroiling S-IND-9 I-47

Fugitive PM10 Prohibitions (Reg ulation VIII) S-IND-10 I-49

Flares S-IND-21 I-71

Indirect Source Review (I SR) Enhancement M-OTH-8 I-73

Healthy Air Living M-OTH-9 I-75

Fireworks M-OTH-10 I-78

Employer Based Trip Reduction Programs M-TRAN-1 I-80San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-4 

### Open Burning (S-AGR-1) (Managed Burning and Disposal)

Source Category: This category includes the open burning of materials such as agricultural waste, diseased materials, and contraband materials, as well as fires set for fire department training purposes.

Emissions Inventory: Data reflects current controls and regulations, but not reductions from the June 2007 controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 8.16 8.03 8.00 7.97 7.94 7.91 7.88 PM2.5 10.70 10.54 10.50 10.46 10.42 10.38 10.34 SO 2 0.19 0.19 0.19 0. 19 0.19 0.19 0.19 Tons per day – annual average NOx 5.37 5.29 5.27 5.25 5.23 5.21 5.19 PM2.5 7.07 6.96 6.94 6.91 6.89 6.86 6.83 SO 2 0.13 0.13 0.13 0. 13 0.13 0.13 0.13

• Emission Inventory Code (EIC) Affected: 670-660-0262, 670-662-0262, 670-668-0000.

• The emission inventory will be further refined to ensure that it fully captures the reductions achieved by the recent 2007 amendments to existing Rule 4103.

Current Control: Rule 4103 has limitations on the amount and the types of ma terial that can be burned and restricts when such burning can occur. The rule provides exemptions for fires that serve a ceremonial purpose, and when t he District determines there would be an imminent and substantial economic loss if burni ng were to be prohibited. This rule reduces NOx emissions from between 58% and 100%, depending on the type of material burned.

Future Control Options:

• The District will gather information on economic ally feasible alternative methods to burning agricultural waste. District staff will report the findings to the California Air Resources Board in second quarter of 2008.

• District staff is committed to working with agr icultural industry stakeholders to identify feasible alternative methods to burning agricultural waste.

• District staff will conduct a f easibility study on biomass incentives for fourth quarter of 2008.

• Staff will address the burn prohibition requi rements of California State Senate Bill 705 (SB 705) according to the schedule detailed below.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-5 Open Burning (Continued)

Discussion:

• The District has legal authority to regul ate air emissions from burning conducted at stationary sources.

• On September 22, 2003, Governor Gray Davis signed SB 705. This action amended the California Health and Safe ty Code (CH&SC) Sections 41855.5 and 41855.6 to require the District to revise rules that regulate emissions from open burning of waste produced by agricultura l operations. The bill divided the agricultural wastes burn prohibitions into four phase:

o Phase I: Diseased Crops (June 1, 2005)

o Phase II: Field Crops, Prunings, and Weed Abatement (June 1, 2005); and Best Management Practices for W eed Abatement (June 1, 2006)

o Phase III: Orchard Removals (June 1, 2007)

o Phase IV: Other Materi als, Vineyard Removals, and Prunings from SurfaceHarvested Crops (June 1, 2010)

• The District’s Governing Board adopted rule amendments to District Rule 4103 for Phase I, Phase II, and Phase III in 2004, 20 05,and 2007, respectively. The next rulemaking project in 2010 will focus on Phas e IV - the prohibition on the burning of Other Materials, Vineyard Removals, and Pr unings from Surface-Harvested Crops. In addition, the postponement until 2010 for cert ain types of orchard removal and the phase down schedule for the burning of rice stubble that were created in 2007, will also be reconsidered under Phase IV.

• The District may postpone the burn prohibiti on commencement dates set forth in the CH&SC but cannot provide a permanent allo wance for burning. Each of the following criteria must apply for the District to postpone the burn prohibition commencement dates:

o The District determines that there is no economically feasible alternative of eliminating the waste.

o The District determines that there is no long-term federal or state commitment for the continued operation of biomass facilit ies in the San Joaquin Valley or the development of alternatives to burning.

o The District determines that the continued issuance of pe rmits for that specific category or crop will not cause, or substant ially contribute to a violation of an applicable federal ambient air quality standard.

o The California Air Resources Board c oncurs with the Distri ct’s determinations.

Recommendation:

• District staff recommends that the District continue to meet its legal obligation under the CH&SC (SB 705) through its rulemaking projects addressing the burning of agricultural waste.

• Currently this source category is not a candidate for incentive funding, but further analysis and study is necessary to determine if this source category may garner cost effective reductions in the future prov ided funding sources are available.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-6 Open Burning (Continued)

Projected Reductions: Provided the technical and econo mic limitations of the al ternatives to open burning, District staff anticipates that the recommended controls will yield the emissions reductions listed below.

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 1.84 2.96 4. 07 4.05 4.04 4.02 PM2.5 2.41 3.88 5. 34 5.32 5.30 5.28 SO 2 0.04 0.07 0.10 0.10 0.10 0.10 Tons per day – annual average NOx 1.21 1.95 2. 68 2.67 2.66 2.65 PM2.5 1.60 2.57 3. 53 3.52 3.50 3.49 SO 2 0.03 0.05 0.07 0.06 0.06 0.06

The baseline inventory does not reflect regulations adopted after December 2006, therefore, the indica ted reductions include those resultin g from both the completed June 2007 Phase III rule making and the proposed June 2010 Phase IV rule making.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-7 

### Conservation Management Practices (S-AGR-2) (Agriculture)

Source Category: This source category includes on-field farming operations.

Emissions Inventory: Data includes current controls and regulations but does not reflect reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 0 0 0 0 PM2.5 13.22 13.60 13.69 13.82 13.95 14.08 14.21 SO 2 0 0 0 0 0 0 0 Tons per day – annual average NOx 0 0 0 0 0 0 0 PM2.5 14.79 15.15 15.23 15.36 15.48 15.60 15.73 SO 2 0 0 0 0 0 0 0

• EIC Affected: The source category shares EI C inventory with Rule 8081, which covers off-field farming operations. The em ission inventory for t he operations in this control measure will be evaluated duri ng the Feasibility Study, but are not quantifiable at this time.

Current Control:

• Existing Rule 4550 requires agriculture growers and animal feeding operation producers to implement at least one met hod of Conservation Management Practice (CMP) for each of the applicable CMP ca tegories for their operations. The CMP selected by the growers and producers must be specified in their CMP Plan and approved by the District.

• The 18 categories in the CMP are:

o Cropland – Land Prepar ation/Cultivation

o Cropland – Harvest

o Cropland –Other

o Cropland – Unpaved Roads

o Cropland – Unpaved Vehicle/ Equipment Traffic Areas

o Poultry Operation – Manure Handling and Storage

o Poultry Operation – Feeding

o Poultry Operation – Open Areas

o Poultry Operation – Unpaved Roads

o Poultry Operation – Unpaved Ve hicle/Equipment Traffic Areas

o Dairy Operations – Corral/Manure Handling

o Dairy Operations – Overall Management/Feeding

Conservation Management PracticesSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-8 (Continued)

o Dairy Operations – Unpaved Roads

o Dairy Operations – Unpaved Ve hicle/Equipment Traffic Areas

o Feedlot Operations – Pens/Manure Handling

o Feedlot Operations – Overall Management/Feeding

o Feedlot Operations – Unpaved Roads

o Feedlot Operations – Unpaved V ehicle/Equipment Traffic Areas

The list of CMP (published in a handbook) is qui te extensive, containing more than 100 practices. For example, CMPs that reduce emissions include, but are not limited, to the following:

o Practices that reduce or eliminate the need to disturb the soil or manure;

o Practices that protect t he soil from wind erosion;

o Equipment modifications to physically produce less PM10;

o Applying water or dust suppressants to reduce emissions entrained by moving vehicles and equipment;

o Reducing speed or access on unpaved roads and parking areas;

o Other practices that reduce pestici de use and emission s from stationary agricultural internal combustion engines; and

o Alternative practices to agricultural waste burning.

• Growers and producers that are s ubject to the unpaved road and unpaved equipment traffic area provisi ons of Rule 8081 (Agricultu ral Sources) can comply with Rule 8081 requirements through their CMP Plans.

• Current Exemptions

o Agriculture operation sites with less than 100 contiguous acres.

o Animal feeding operations with less than 500 mature dairy cows, 190 beef cattle or heifers, 82,000 laying hens, 125,000 chic kens (except layers), and 55,000 turkeys

o Animal feeding operations, other than fo r mature dairy cows , cattle, turkeys, chickens, and laying hens

o Woodland and wasteland not actually in cultivation or used for pasture

o Land placed in the Conservation Reserve Program meeting the definition criteria set by NRCS.

o Agricultural parcels that are 3,00 0 feet or more above mean sea level.

o Agricultural operation parcel used for propagating young trees, shrubs or other crops for transplanting and ex hibiting plants inside a building, providing grazing rangeland or pasture, and forestry.

Control Options:

• Lower the current exemption thresholds fo r agricultural operation sites, number of cows, cattle, chickens, and turkeys. Evaluate feasibility of applying similar thresholds specified in Rule 4570 (C onfined Animal Feeding Operation)

• Remove the existing exemption category fo r certain Animal Feeding Operations.

• Increase the number of required CMP for each app licable CMP categories.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-9 Conservation Management Practices (Continued)

Discussion:

• These source categories are located at st ationary sources for which the District has legal authority to r egulate air emissions.

• A variety of studies have been conducted whic h may indicate that the PM2.5 fraction of the PM emissions from this may not be as significant as the PM coarse fraction. A better quantification of t he PM2.5 fraction is required to develop a more accurate emissions inventory for the vari ous activities in this category and to indicate the level of significance of those PM2.5 emissions.

• If the inventory study shows this to be a si gnificant source of PM 2.5, research would be needed to identify and characterize control techniques. At this time, PM2.5 emission control factors are not well defined and it is not known if controls for PM10 are effective for producing PM2.5 emissions reductions for this category. Further review of available research is necessa ry to determine feasible, cost-effective control measures, should they be necessary.

Recommendation: While PM10 emissions and controls for this category are well esta blished, there is evidence that such data may not apply directly to PM2.5 emission and controls. District staff recommends that a Feasibility Study be conducted and completed by 2010. The Study would first examine the PM2.5 fraction of the emissions from this category and would use that information to develop a repres entative emissions inventory. If that inventory appears to be significantly large and contribute to the non-attainment problem, staff would then exami ne control effectiveness for PM2.5 r eduction strategies that could be used to reduce the PM2.5 inventory.

Projected Reductions: Emission reductions will be calculated bas ed on the information derived from the Feasibility Study, but are not quantifiable at this time.

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 0 0 0 PM2.5 NQ NQ NQ NQ NQ NQ SO 2 0 0 0 0 0 0 Tons per day – annual average NOx 0 0 0 0 0 0 PM2.5 NQ NQ NQ NQ NQ NQ SO 2 0 0 0 0 0 0San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-10 

### Boilers, Steam Generators, a nd Process Heaters >5 MMBtu/hr (S-COM-1) (Electrical Utilities, Cogeneration, Oil & Gas Production – Combustion, Petroleum Refining – Combustion, Manufacturing & Indus trial, Food & Ag Processing, Service & Commercial)

Source Category: This source category includes a wide range of industries in cluding but not limited to those listed above.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 5.68 3.21 3.20 3.23 3.25 3.28 3.31 PM2.5 1.15 1.15 1.15 1.15 1.16 1.16 1.17 SO 2 2.56 2.56 2.56 2. 57 2.58 2.59 2.60 Tons per day – annual average NOx 5.97 3.34 3.34 3.36 3.39 3.42 3.44 PM2.5 1.21 1.21 1.21 1.21 1.22 1.23 1.23 SO 2 2.57 2.58 2.57 2. 59 2.60 2.61 2.62

• EIC Affected: 010-005-0110; 010-005-1220; 030-005-0110; 030-005-0124; 030-005-0130; 030-005-1220; 030-005- 1530; 030-010-0110; 030-010-1600; 030-015-0110; 030-015-0130; 040-005- 0110; 040-005-0130; 040-010-0100; 040-010-0110; 040-010-1000; 050-005- 0110; 050-005-0122; 050-005-0124; 050-005-0300; 050-005-1220; 050-010- 1220; 050-010-1224; 052-005-0110; 052-005-0122; 052-005-0124; 052-005- 1220; 052-005-1510; 052-005-1520; 052-010-0110; 052-010-0120; 052-010- 1224; 060-005-0110; 060-005-0122; 060-005-0124; 060-005-0144; 060-005- 0320; 060-005-1220; 060-005-1520; 060-010-1220

Current Control:

• Rule 4306 is currently the most stringent control measur e in the state and requires the most effective controls.

• Rule 4306 sets NOx limits, effective in 2007, of 9 ppmv for units greater than 20 MMBtu/hr and 15 ppmv for units less than 20 MMBtu/hr. For large refinery units >110 MMBtu/hr the limit is 5 ppmv.

• The rule has an optional, enhanced NOx limit of 6 ppmv for units greater than 20 MMBtu/hr, which becomes effective in 2008.

• Low-use units with an annual heat input of 9 billion Btu or less are only required to perform periodic tune-up or to limit exhaust oxygen to 3% or less.

• The current limits in Rule 4306 achieve 45 % reduction from the previously required emissions limit of 30 ppmv.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-11 Boilers, Steam Generat ors, and Process Heat ers, >5 MMBtu/hr (Continued)

Future Control Options:

• Lower NOx limits are achievable by usi ng selective catalytic reduction (SCR) or selective non-catalytic reduction (SNCR). Both technologies reduce NOx by injecting ammonia to the ex haust gas to convert NOx to elemental nitrogen and oxygen.

• Ultra Low NOx burner technolog y at this time is technol ogically capable of achieving 9 ppmv NOx, with some burners achieving 6 ppmv or lower.

• Low temperature oxidation may be technol ogically feasible for 5 ppmv, but its application on boilers is not considered to be achieved in practice or established as BACT for this source category.

Discussion:

• The District has legal authority to regulate air emissions from units in this source category located at stationary sources.

• There are approximately 1,600 permitted units currently oper ated by various types of industry in the District. Emissions reduc tion could be achieved by lowering the current emission limits based on burner r eplacement of exhaust control system retrofits.

• Lowering the current NOx limit of 9 ppm v to 5 ppmv for units greater than 20 MMBtu/hr would result to about 44% reducti on from current baseline emissions for units in this size category. The 5 ppmv limit is achievable by retrofitting existing units with selective catalytic reduction tec hnology (SCR). In fact , about 12 units in the District have been operating SCR and source testing re sults show that the 5 ppmv limit can be met. Data also shows that some units operating Ultra Low NOx Burner with flue gas recirculation coul d achieve the proposed NOx limit.

• Lowering the current standard option NOx limit of 15 ppmv to 9 ppmv for units equal to or less than 20 MMBtu would result to about 40% reduction from current emissions level for units in this size category can be achieved by retrofitting with Ultra Low NOx Burner (ULNB) technology. Some units, in the District, rated less than 20 MMBtu/hr, are already operating ULNB with flue gas recirculation that can meet the proposed 9 ppmv NOx limit.

• Older units, nearing the end of their usef ul life expectancy, may not be economical able to retrofit with SCR and it may be more co st effective to for operators to install complete replacement package with integral SCR or ULNB.

• Currently, there are no known units that operate with both PM2.5 and SO2 control devices for gaseous-fired or liquid-fired external combusti on equipment. A few steam generators operating in crude oil production facilitie s in the District fire on mixture of natural gas, field gas , and vapor recovery gas with SO 2 scrubbers or desulfurization equipment. However, most permitted units are firing on natural gas or back-up distillate oil fuel without PM2.5 or SO 2 control devices.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-12 Boilers, Steam Gener ators, and Process He aters >5 MMBtu/hr (Continued)

• PM control devices such as baghouse, elec trostatic precipitat ors, and scrubbers are available, but they have not yet been dem onstrated or achieved-in-practice for gaseous or liquid-fired units. Units firing on natural gas, propane, liquefied petroleum gas, or low sulfur diesel tend to emit very low levels of PM2.5 and SO 2

. AP-42 indicates that the uncontrolled tota l PM (condensable and filterable) is 0.007 pound per million Btu and uncontrolled SO 2 is 0.0006 pound per million Btu for natural gas-fired boilers. The PM and SO 2 emissions are less than 4% and 0.3%, respectively, of the AP-42 uncontroll ed NOx emission factor of 0.186 pound per million Btu from natural gas-fired boilers.

• Rule 4306 amendments currently under rule development to fulfill the commitment in the Ozone Plan. The focus of the amendment s would be to lower the existing NOx limits and establish PM and SO 2 standards.

• Physical space where the units are located is often limited and could impede installation of NOx, PM and SO 2 controls, which can be almost as large as the combustion units.

• Other constraints, not known at this ti me, may have to be considered when deciding the implementation schedule for this control m easure. Constraints such as lead-time to design, manufacture, deliver and inst all the technology could affect early implementation of lower limits. Availability of trained installation and source testing personnel will also be consider ed during rule development.

Recommendation:

• Staff recommends this source category be controlled through regulatory method with implementation starting in 2012, due to the constraints discussed above.

• An estimated 44% reduction from current emissions level could be achieved by lowering the NOx emission limit to 5 ppmv for units greater than 20 MMBtu/hr and by lowering the limit from 15 ppmv to 9 ppmv for units rated from 5 MMBtu/hr to 20 MMBtu/hr.

• Control of PM and SO 2 could be achieved by requiring units to be fired exclusively on PUC-quality natural gas, pr opane, or liquefied petroleum gas (LPG), except firing on liquid fuel would be allowed only dur ing PUC-quality natural gas curtailment periods, provided the sulfur content of liquid fuel does not exceed 15 ppm. Gaseous fuel other than specified above c ould be used provided the exhaust gas is controlled by a SO 2 and PM10 emission control system. Staff estimates about 38% of existing permitted units are cu rrently firing on mixture of PUC-quality natural gas, field gas, vapor recovery gas, and refinery gas. The estimated reduction in PM and SO2 is about 50% of the emissions from the units not fired exclusivel y with PUC-quality natural gas.

• Staff will consider inclusion of an Advanced Emission Control Options to mitigate the potentially high cost effectiveness of th is control measure for certain units.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-13 Boilers, Steam Gener ators, and Process H eaters >5 MMBtu/hr (Continued)

Projected Reductions: Calculated reductions assuming the re commended emission limits described below:

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 1.43 1.44 1.46 PM2.5 0 0 0 0.22 0.22 0.22 SO 2 0 0 0 0.50 0.50 0.50 Tons per day – annual average NOx 0 0 0 1.49 1.50 1.52 PM2.5 0 0 0 0.23 0.24 0.24 SO 2 0 0 0 0.50 0.50 0.50

• An estimated 44% reduction from current emissions level could be achieved by lowering the NOx emission limit to 5 ppmv for units greater than 20 MMBtu/hr and by lowering the limit from 15 ppmv to 9 ppmv for units rated from 5 MMBtu/hr to 20 MMBtu/hr.

• Staff estimates about 38% of existing permit ted units are currently firing on mixture of PUC-quality natural gas, fiel d gas, vapor recovery gas, and refinery gas. The estimated reduction in PM and SO2 is abou t 50% of the emissions from the units not fired exclusively with PU C-quality natural gas.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-14 

### Boilers, Steam Generators, and Process Heaters, 2 - 5 MMBtu/hr (S-COM-2) (Electrical Utilities, Cogeneration, Oil & Gas Production – Combustion, Petroleum Refining – Combustion, Manufacturing & I ndustrial, Food & Agricultural Products Processing, Service & Commercial, Other – Fuel Combustion)

Source Category: This source category includes a wide range of industries in cluding but not limited to medical facilities, educational institutions, o ffice buildings, prisons, military facilities, hotels and industrial industries.
Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 3.66 3.78 3.84 3.89 3.94 3.99 4.05 PM2.5 0.35 0.36 0.37 0.37 0.38 0.38 0.39 SO 2 3.17 3.30 3.37 3. 43 3.49 3.55 3.61 Tons per day – annual average NOx 3.47 3.59 3.65 3.70 3.75 3.80 3.86 PM2.5 0.32 0.33 0.34 0.35 0.35 0.36 0.36 SO 2 3.17 3.30 3.37 3. 43 3.49 3.55 3.61

• EIC Affected: 020-005-0110-0000; 050-070- 0110-0000; 050-995-0110-0000; 050-995-0120-0000; 050-995-150 0-0000; 052-070-0110-0000; 060-010-0110-0000; 060-995-0110-0000; 060-995-012 0-0000; 060-995-1500-0000; 099-995-0000-0000; 310-356-0110-0000; 310-995-160 0-0000; 410-400-2036-0000

• The EIC include emissions fr om all units rated less than 5 MMBtu/hr. To more accurately assess control measure reductions, half of the emissions in these EIC will be assumed to be controlled by S-COM-2 (2 to 5 MMBtu/hr) and half are controlled by S-COM-3 (0.075 to 2 MMBtu/hr).

• Current Rule 4307 requires registration of sm all units pursuant to District Rule 2250. When registration is completed within the next 3 years and the total number of medium size units has been determined, the District will re-calculate the emissions and then update the emissions inventor y for this source category.

Current Control:

• District Rule 4307 sets NOx limits at 30 ppmv effective in 2009. This is approximately 70% NOx contro l from uncontrolled levels.

• Natural draft units operating in oil fields or refineries, gl ycol reboilers, and units that operate no more than 5 billion Btu per year are not required to meet the emission limits of the rule. Such units are r equired to be tuned up twice a year, or be operated in such a manner that the exhaust oxygen does not exceed 3% by volume (dry basis) or comply with the emission limits.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-15 Boilers, Steam Generat ors, and Process Heaters, 2 - 5 MMBtu/hr (Continued)

Future Control Options:

• Mandate NOx limits for school boilers, natural draft units operating in oil fields or refineries, glycol reboilers, and units that op erate no more than 5 billion Btu per year. (currently undergoing rule am endment development process).

• Replacing with electric heaters is also an option since almost all facilities are in areas connected to existing comm ercial electric grid system.
Future Incentive Options

• Additional reductions can be achieved by providing incentives for replacement or retrofit of school boilers. Staff estimated there are at least 380 school boilers with uncontrolled emissions of about 0.8 tons per day of NOx.

• Electric heaters may also be feasible for some application, but have increased operational costs for electric ity compared to using natural gas as a fuel source. Availability of higher-Btu electrical heaters also limits feasibility of that option.

Incentive Option # of Units MMBtu/hr Capacity Factor Emissions (tons per

day) Emission Reductions

(tons per

day) Total Cost Capital Cost Cost Effectiveness

(dollars per ton)

Low NOx Retrofit (30 ppm) 380 3.5 0.5 0.798 0.511 $17, 733,460 $46,667 $11,124

Low NOx Replacement (30 ppm) 380 3.5 0.5 0.798 0.511 $24, 553,700 $64,615 $15,402

Ultra Low Nox Replacement (15 ppm) 380 3.5 0.5 0.798 0.694 $57, 000,000 $150,000 $26,327

Discussion:

• The District has legal authority to regulat e air emissions units located at stationary

sources.

• Except for the school boilers exemption, current Rule 430 7 is as stringent as other air district rules.

• Emission control devices such as baghous e, electrostatic precipitators, and scrubbers (wet or dry) are commercia lly available to reduce PM and SO 2 emissions. Units firing on natural gas, propane, liquefied petroleum gas, or low sulfur diesel tend to emit very low levels of PM2.5 and SO 2 . AP-42 indicates that the uncontrolled total PM (condensable and filt erable) is 0.007 pound per million Btu and uncontrolled SO 2 is 0.0006 pound per million Btu for natural gas-fired boilers. The PM and SO 2 emissions are less than 4% and 0. 3%, respectively, of the AP-42 uncontrolled NOx emission fact or of 0.186 pound per milli on Btu from natural gasfired boilers.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-16 Boilers, Steam Generat ors, and Process Heaters, 2 - 5 MMBtu/hr (Continued)

• Physical space where the units are loca ted could be limited and impede installation of NOx, PM and SO 2 controls, which can be almost as large as the combustion units.

• Other constraints not known at this time may have to be considered when deciding the implementation schedule for this control measure.

• Constraints such as longer lead-time to design, manufacture, deliver and install the technology could affect early implementation of lower limits.

Recommendation:

• Rule 4307 is currently under going rule development proce ss to implement the control measure in the Ozone Plan. The dra ft amendments would include removing the exemption for school boilers, glycol reboilers, and natural draft units located in the oilfields and refineries. The Ozone Plan calls for adopti on of rule amendments by third quarter of 2008.

• Due to limited state funding, school district s may need financial assistance to retrofit or replace aging equipment. Staff recommends in itially controlling this source category through an incentive program and will explore opportunities for incentive funding to achieve additional emission reductions from this source category.

• Control of PM and SO 2 can be achieved by specifying that be units be fired exclusively on PUC-quality nat ural gas, propane, or liquefied petroleum gas (LPG). The use of liquid fuel with a sulfur content of 15 ppm or less would be allowed only during PUC-quality natural gas curtailment period.

• Recommend full implementation of pr oposed changes to t he rule by 2015.

Incentives:

• Retrofit and replacement of school boilers to meet BARCT standards (30 ppm) are relatively cost effective incentive options. Grant history indicates that participation is higher for programs that offer full r eplacement as opposed to retrofit

• Consider adopting a backstop rule to assure participation in the incentive program and improve cost effectiveness.

Projected Reductions: Calculated reductions assuming the re commended emission limits described above: Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 0 0 0 PM2.5 0 0 0 0 0 0 SO 2 0 0 0 0 0 0 Tons per day – annual average NOx 0 0 0 0 0 0 PM2.5 0 0 0 0 0 0 SO 2 0 0 0 0 0 0San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-17 

### Boilers, Steam Generators, and Process Heaters, > 0.075 MMBtu/hr but < 2.0 MMBtu/hr (S-COM-3) (Electrical Utilities, Cogeneration, Oil & Gas Production – Combustion, Petroleum Refining – Combustion, Manufacturing & Indus trial, Food & Ag Processing, Service & Commercial, Other – Fuel Combustion)

Source Category: Facilities with boilers in this size range may include electrical utilities, crude oil production facilities, manufacturi ng facilities, food processing facilities, hospitals, office buildings, schools and universities.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 3.66 3.78 3.84 3.89 3.94 3.99 4.05 PM2.5 0.35 0.36 0.37 0.37 0.38 0.38 0.39 SO 2 3.17 3.30 3.37 3. 43 3.49 3.55 3.61 Tons per day – annual average NOx 3.47 3.59 3.65 3.70 3.75 3.80 3.86 PM2.5 0.32 0.33 0.34 0.35 0.35 0.36 0.36 SO 2 3.17 3.30 3.37 3. 43 3.49 3.55 3.61

• EIC Affected: 020-005-0110-0000; 050-070-0110- 0000; 050-995-0110-0000; 050-995-0120-0000; 050-995-150 0-0000; 052-070-0110-0000; 060-010-0110-0000; 060-995-0110-0000; 060-995-012 0-0000; 060-995-1500-0000; 099-995-0000-0000; 310-356-0110-0000; 310-995-160 0-0000; 410-400-2036-0000

• The EIC include emissions from all units rated less than 5 MMBtu/hr. To more accurately assess control measure reductions, half of the emissions in these EIC will be assumed to be controlled by S-COM-2 (2 to 5 MMBtu/hr) and half are controlled by S-COM-3 (0.075 to 2 MMBtu/hr).

Current Control:

• District Rule 4308 limits NOx emissions for new and replacement units to the following levels: 0.093 lb NOx/MMBtu for units rat ed between 0.075 and 0.4 MMBtu/hr, and 0.036 lb NOx/MMBtu for units rated between 0.4 and 2.0 MMBtu/hr.

Future Control Options:

• Ultra Low NOx Burner could achieve lowe r emission level but may not be available for smaller unit.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-18 Boilers, Steam Generat ors, and Process Heaters, 0.075 MMBtu/hr (Continued)

• Replacement of older exis ting units with new ones that already integrate low NOx technology is possibly the more cost effectiv e control options to th at of retrofitting existing units.

• Replacing with electric heaters may also be an option since most facilities are in areas connected to existing commer cial electric grid system.

Discussion:

• The District has legal authority to regul ate air emissions from units operated at stationary sources.

• Although current District Rule 4308 has a specific date for when new and replacement boilers must meet the emission lim it, it does not specify the turnover of boilers in service prior to that date. Mandat ing a specific date that all boilers in this size range must meet the cu rrent emission limit would gener ate faster turnover of the existing, boilers than natural attrition.

• At full implementation, NO x emission reductions were estimated to be 2.0 tons NOx per day, or about 60% of the baseli ne inventory of 3.3 tons per day.

• Currently, there are no known small gaseous -fired or liquid-fired units that operate with both PM2.5 and SO2 cont rol devices. Control devices such as baghouse, electrostatic precipitators, and scrubbers ar e available, but they have not yet been demonstrated or achieved-in-practice for t hese units. Units firing on natural gas, propane, liquefied petroleum gas, or low sulfur diesel tend to emit very low levels of PM2.5 and SO 2 . AP-42 indicates that the unc ontrolled total PM (condensable and filterable) is 0.007 pound per million Btu and uncontrolled SO 2 is 0.0006 pound per million Btu for boilers firing on natural gas. The PM and SO 2 emissions are less than 4% and 0.3%, respectively, of the AP-42 unc ontrolled NOx emission factor of 0.186 pound per million Btu from nat ural gas-fired boilers.

• Control of PM2.5 and SO 2 can be achieved by requiring the units be fired exclusively on PUC quality natural gas, propane or Liquefied Petroleu m Gas (LPG). Firing on other fuel types may only be allowed dur ing natural gas curtailment periods.

• Physical space where the units are located is often limited and could impede installation of PM and SO 2 control device, which can be almost as large as the combustion units.

• Other constraints, not known at this ti me, may have to be considered when deciding the implementation schedule for this control measure. Constraints such as longer lead-time to design, manufacture, deliver and install the technology could affect early implementation of lower limits. Availability of trained installation and source testing personnel will also be consider ed during rule development.

• Mandating conversion to electric boilers could be a possibility for this source category. Further study is needed to determine the most cost effective way to implement the standard for these units.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-19 Boilers, Steam Generat ors, and Process Heaters, 0.075 MMBtu/hr (Continued)

Recommendation:

• Accelerate the replacement of older units by 5% per year starting in 2011 with new units meeting the Rule 4308 NO x emission rate limits by a rule-based requirement (e.g. no units operating within the District th at are 10 years or older, unless a certain emission rate can be demonstrated ) or by the use of incent ives or a combination of both strategies. An additional reduction of 5% from baseline emissions could be achieved by amending the current rule to accelerate replacem ent of older units.

• Explore possibilities of converting units to electric boilers where cost effective and socioeconomically viable.

• Control PM2.5 and SO2 by requiring the uni ts be fired exclusively on PUC-quality natural gas, propane, or liquefie d petroleum gas (LPG). A llow units be fired on liquid fuel with a sulfur content of 15 ppm or less only during PUC-quality natural gas curtailment periods.

Projected Reductions: Calculated emission reductions, a ssuming the recommended controls:

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0.13 0.28 0.41 0.57 PM2.5 TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBD Tons per day – annual average NOx 0 0 0.12 0.27 0.39 0.55 PM2.5 TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBDSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-20 

### Solid Fuel Boilers, Steam Generators, and Process Heaters (S-COM-4) (Electric Utilities, Cogenerat ion, Service and Commercial)

Source Category: This source category includes facilitie s that operate boilers , steam generators, and process heaters (units) that are fired on solid fuel. These units are used in facilities that generate utility and industrial power (electrici ty and heat) by burning solid fuels including petroleum coke, coal, municipal solid wa stes, tires, or biomass wastes.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 4.06 4.11 4.16 4.16 4.16 4.15 5.15 PM2.5 0.59 0.59 0.60 0.60 0.60 0.60 0.60 SO 2 1.33 1.34 1.34 1. 34 1.34 1.34 1.34 Tons per day – annual average NOx 4.12 4.17 4.22 4.22 4.22 4.21 4.21 PM2.5 0.62 0.62 0.63 0.63 0.63 0.63 0.63 SO 2 1.36 1.37 1.37 1. 37 1.37 1.37 1.37

• EIC Affected: 010-005-0214; 010-005-0240; 010-005-0243; 010-005-0254; 020-005-0214; 020-005-0218; 020-005- 0220; 020-005-0230; 060-005-0250; 050-005-0214-0000; 052-005-0240-0000

• The emissions inventory will be further refi ned to ensure that it captures the NOx reductions from existing boiler permit NOx limi ts as well as current Rule 4352 limits.

Current Control: District Rule 4352 requires municipal solid waste units to meet a NOx limit of 200 ppmv @ 12% CO 2. For all other units, the NOx limits is 115 ppmv @ 3% O2.

Future Control Options:

• Current BACT is selective non-catalytic r eduction (SNCR) or ammonia injection for municipal waste-fired or bi omass-fired boilers. Sources subject to Rule 4352 are already operating at or below the BACT limits by using this control technology.

• ARB recommended that staff examine if t he NOx emission limit s from Sacramento AQMD (70 ppmv) or (40 ppmv) are achievable.

• There is some increased use of selectiv e catalytic reduction (SCR) with ammonia injection in new coal-fired boilers in easte rn states in the nation. European Best Available Technology (BAT) listed SCR for coal and lignite firing boilers.

• There are no biomass-fired or municipal wa ste-fired boilers that are currently using SCR in the nation or in Europe.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-21 Solid Fuel Boilers, Steam G enerators, and Process Heaters (Continued)

• Coal-fired units are not com parable to the District’s biom ass fired or municipal solid waste fired boilers, which are non-homogeno us fuel and therefore higher emission variability. Further research would need to be conducted to determine if SCR could be retrofitted to the existing boilers or if they also need combus tion retrofits that would require boiler rebuilds.

Discussion:

• The District has legal authority to regul ate air emissions from units operated at stationary sources.

• Rule 4352 was recently amended to im plement BARCT and All Feasible Control Measure as a commitment in the Distric t’s One-hour Extreme Ozone Attainment Demonstration Plan. A discussion of possible NOx emission levels and controls was included in the analysis for that rule amendment project.

• Facilities subject to Rule 4352 operate boilers that burn locally generated agricultural waste and municipal waste materials as well as waste materials imported into the Valley. Continued operation of these facilitie s is important to reduce emissions from open burning.

Recommendation:

• This source category is recommended fo r feasibility study to investigate the feasibility of retrofitting the units with SCR or other combustion modifications to achieve additional NOx emissions r eduction and controls for PM2.5 and SO 2

. Projected Reductions: Emission reductions will be calculated bas ed on the information derived from the Feasibility Study, but are not quantifiable at this time.

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQ Tons per day – annual average NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-22 

### Stationary Gas Turbines (S-COM-5) (Electric Utilities, Cogeneration, Oil & Gas Production – Combustion, Petroleum Refining – Combustion, Manufacturing & Indus trial, Service & Commercial, Other – Fuel Combustion)

Source Category: This source category includes any operations that use stat ionary gas turbines for the generation of electrical power.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 8.37 4.93 4.95 5.00 5.05 5.09 5.13 PM2.5 1.06 1.14 1.14 1.15 1.16 1.16 1.17 SO 2 0.18 0.19 0.19 0. 20 0.20 0.20 0.20 Tons per day – annual average NOx 8.40 4.94 4.97 5.02 5.06 5.10 5.15 PM2.5 1.06 1.14 1.14 1.15 1.16 1.17 1.17 SO 2 0.18 0.19 0.19 0. 20 0.20 0.20 0.20

• EIC Affected: 010-045-0110; 010-045-1200; 020-045-0110; 030-045-0110; 030-045-1200; 040-045-1412; 050- 045-1200; 060-045-0110; 060-045-1420

• The above emissions inventory does not re flect the reductions from the recent September 2007 amendments to Rule 4703.

Current Control:

• Due to the recent Septem ber 2007 amendments, District Ru le 4703 is considered to be the most stringent rule in California for this category.

• Rule 4703 applies to stationary gas turbi nes with rated 0.3 megaw att (MW) and/or a maximum heat input greater than 3 MMBtu/hr.

• Recent amendments in September 2007, established the fo llowing NOx emission limits corrected to 15% O 2 for gas fired turbines which will be effective in 2012 or within 90 days following the next major over haul in 2009, whichever occurs first:

o Less than 3 MW: 9 ppmv

o 3 MW to 10 MW pipeline gas turbine: 8 ppmv (steady state); 12 ppmv (nonsteady state)

o 3 MW to 10 MW, operating less than 877 hours/yr, except for above mentioned units: 9 ppmv

o 3 MW to 10 MW operating at 877 or greater hours/ year: 5 ppmv

o Greater than 10 MW, simple cycle and operat ing no greater than 200 hours/year: 25 ppmv

o Greater than 10 MW, simple cycle, operating no greater than 200 hours/year: 25 ppmvSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-23 Stationary Gas Turbines (Continued)

o Greater than 10 MW, simple cycle, oper ating greater than 200 hours/year, but less than 877 hours/year: 5 ppmv

o Greater than 10 MW, Combi ned cycle: 3 ppmv (enhanced compliance option) and 5 ppmv (standard compliance option).

o For liquid fired turbines the NOx limit is 25 ppmv (regardle ss of turbine size)

• The previous exemption for low-use tu rbines’ operating hours limitation has been lowered from 877 hours/year to 200 hours/year.

• Exemption includes laborat ory turbines used exclusively in turbine technology research, turbines used exclusively for fire fighting and/or flood control, emergency turbines operated < 100 hours per year.

Future Control Options:

• Rule 4703 was recently amended in Sept ember 2007which requires units to meet the most stringent NOx limits in the nation.

• Currently, there are no turbines firing on gas eous fuel in the nation or elsewhere that operate with PM2.5 and SO 2 control devices for units. Control devices such as baghouse, electrostatic precipitators, and sc rubbers are available, but they have not yet been demonstrated or achieved-in-practice for turbines.

• PM2.5 and SO 2 controls could include requiri ng firing the units on PUC quality natural gas, propane or liquefi ed petroleum gas. Combustion of these types of gases emits very low amount PM2.5 and SO 2 . If the units are not firing on PUC quality natural gas, propane or liquefied petroleum gas, cons ider requiring operation of PM2.5 and SO 2 control devices.

Discussion:

• The District has legal authority to regul ate air emissions from units operated at stationary sources.

• Controlling PM and SO 2 may be technologically feasible , but the cost effectiveness of controlling these pollutants from uni ts firing on natural gas with the above mentioned emission factors is expected to be prohibitive.

• The economic feasibility of controlling PM and SO 2 would need to be evaluated in light of the recent Septem ber 2007 amendments requiring most units to retrofit by 2012 to meet the most stringent NOx limits.

• Physical space where the units are locat ed could impede or present challenges to the effective installation of PM and SO 2 control device

, which can be almost as large as the combustion units.

• The proprietary SCONOX has achieved as low as 3 ppmv NOx for several categories and sizes of turbines compared to the limits specified in Rule 4703. But application of SCONOX has been limited to natural gas-fired combined cycle turbine using water injection. A simple-cycle tu rbine without water injection or combinedcycle turbines using dry low NOx could not use the SCONOx system. (Source “FinalSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-24 Stationary Gas Turbines (Continued)

Determination of Compliance Engineering Evaluation of A pplication No. 2686: Gilroy Energy Center LM600 Phase I Project Plant #11180, 8/28/01).

Recommendation:

• This control measure is recommended as a feasibility study to in vestigate the PM2.5 and SO 2 controls for this source category.

Projected Reductions: Calculated NOx emissions reflect the r eductions from September 2007 Rule 4703 amendments which have not been previously refl ected in the emissions inventory. The potential for emission reductions for PM2. 5 and SOx will be calcul ated based on the information derived from the Feasibility Study , but are not quantifi able at this time.

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 2.20 2.20 2.20 PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQ Tons per day – annual average NOx 0 0 0 2.21 2.21 2.21 PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-25 

### Reciprocating Internal Combustion Engines (S-COM-6) (Cogeneration, Oil & Gas Production – Combustion, Petroleum Refining – Combustion, Manufacturing & Industrial, Food & Ag Processing, Service & Commercial, Other – Fuel Combustion)

Source Category: This source category includes all reciproc ating internal combustion engines. District Rule 4702 currently applies to engines gr eater than 50 brake-horsepower (50 bhp).

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 20.39 20.23 19.86 19.47 19.08 18.68 18.27 PM2.5 1.09 1.00 0.98 0.96 0.93 0.91 0.89 SO 2 1.61 1.62 1.62 1. 62 1.62 1.63 1.63 Tons per day – annual average NOx 26.29 25.57 25.07 24.52 23.96 23.38 22.79 PM2.5 1.49 1.35 1.32 1.28 1.25 1.21 1.18 SO 2 2.22 2.22 2.22 2. 22 2.22 2.22 2.22

• EIC Affected: 010-040-0110; 010-040-1200; 020-040-0110; 020-040-1200; 030-040-0100; 030-040-0110; 030-040- 0124; 030-040-1100; 030-040-1200; 030-040-1210; 040-040-0110; 050-040- 0012; 050-040-0110; 050-040-0124; 050-040-1200; 050-040-1299; 050-040- 3220; 050-995-1220; 052-040-0110; 052-040-1200; 052-042-1200; 060-040- 0012; 060-040-0110; 060-040-0124; 060-040-0142; 060-040-0146; 060-040- 1100; 060-040-1200; 060-040-1210; 060-995-1220; 099-040-1200

• The emissions inventory does not reflect the reductions from the recent ARB Air Toxic Control Measures for stationary internal combustion engines.

Current Control:

• District Rule 4702 regulates NOx emissions from stationary s park-ignited engines and stationary compression ignited (diesel) engines greater than 50 horsepower.

• NOx limits for spark-ignited engines used excl usively in agricultural operations (AO) are: Rich burn – 90 ppmv or 80 percent reduction; lean-burn – 150 ppmv or 70 percent reduction. The full compliance schedul e for these engines is 2009, or 2010 if an operator has an agreement to replace an ex isting engine with an electric motor.

• For non-AO spark-ignited engines: Rich- burn – 25 ppmv or 96 percent reduction; lean-burn – 65 ppmv or 90 percent reduction. The full compliance schedule for nonAO engines is 2007.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-26 Reciprocating Internal Combustion Engines (Continued)

• NOx limits for compression ignited engines are: for non-EPA certified engines greater than 500 bhp and at least 1,000 annual operating hours – 80 ppmv and a full compliance schedule of 2008; 50 bhp to 750 bhp operating less than 1,000 hours per year – EPA certified Tier 3 to Tier 4 depending engine size and a compliance schedule of 2010 or 2011 based on engine size. For EPA certified compression ignited engines: EPA certified Tier I or Tier 2 must comp ly with Tier 4 standard by 2015 or 12 years after installation date whichever is later.
Future Control Options:

• Electrification - replacing engines with electric motors - where possible.

• Lower agricultural spark-ignited engine NOx em ission limits to the same level as the non-AO units.

• Consider the 2007 proposed South Coast Air Qualit y Management District (SCAQMD) Rule 1110.2 (Emissions from Gaseous- and Liquid-Fueled Engines) emissions standards as discussed below.

Discussion:

• The District has legal authority to regulate air emissions from units in this source category located at stationary sources.

• The current Rule 4702 is as stringent as other air district rules.

• SCAQMD is currently pr oposing amendments to Rule 1110.2 (Emissions from Gaseous- and Liquid-Fueled Engines). Ru le 1110.2 applies to all portable and stationary engines greater than 50 bhp-hr. The proposal would lower the NOx emissions limits for engines greater than or equal to 500 bhp-hr from 36 ppmv to 11 ppmv, and 45 ppmv for engines less than 500 bhp-hr effective July 1, 2010. Effective on and after July 1, 2011, the NOx limit would be 11 ppmv. For landfill and digester gas-fired engines the current limit would be lowered to 11 ppmv NOx effective on and after July 1, 2012.

• Electrification should also be considered as part of a strategy to reduce engine emissions. Operators are cu rrently electrifying 2,000 agric ultural diesel engines under an incentive program the utility company and the District.

• Technical and economic conditions may limit t he application of electric motors in some locations and possible impacts to the power grid should be examined.

• Current Rule 4702 goes beyond the ARB Sugges ted Control Measure for this source category.

• Currently, no PM and SO 2 control technologies have been demonstrated or achieved in practice for gaseous fired units. T he AP-42 uncontrolled emissions factors for natural gas-fired 4-stroke lean burn engi nes are 0.000077 lb/MMBtu for filterable PM2.5 and 0.000588 lb/MMBtu SO 2. The PM2.5 and SO 2 emissions are about 0.01% and 0.07%, respectively, of the AP-42 unc ontrolled NOx emissi on factor of 0.847 lb/MMBtu NOx emission factor for natural gas-fired 4-stroke lean burn engines. Diesel fired (compression ignited) engines are already required to meet 0.01 grams/bhp-hr PM limit imposed by the ARB Air Toxic Cont rol Measure, which was implemented in 2005.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-27 Reciprocating Internal Combustion Engines (Continued)

Recommendation:

• Since natural gas fuel is inherently low in sulfur content, additional controls have not been required or developed for spark-ignited engines that fire on natural gas to further reduce SO 2 emissions. The feasibility of controlling SO 2 emissions natural gas fired engines should be investigated.

• Since the ARB ATCM already established PM emission limit from stationary diesel engines, the District plans to implement the ATCM as part of the permitting process, which will require units to meet the s pecified PM limit by the ARB deadline.

• District staff recommends this source category as a control measure for rule amendments to consider SCAQMD’s Ru le 1110.2 proposed NOx limits, and to include PM2.5 and SO 2 controls. The emissions inv entory may need to be adjusted to account for SO 2 emissions reductions from the use of state-mandat ed low sulfur diesel fuel for stationary engines.

Projected Reductions: Emission reductions will be estimated during the plan rule development process.

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQ Tons per day – annual average NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-28 

### Small Spark-Ignited Engines and Agri cultural Spark Ignited Engines (S-COM-6A) (Cogeneration, Oil & Gas Production – Combustion, Petroleum Refining – Combustion, Manufacturing & Industrial, Food & Ag Processing, Service & Commercial, Other – Fuel Combustion)

Source Category: This source category includes stationary small internal co mbustion engines rated at less 50 brake-horsepower-hour (bhp-hr) or le ss and spark-ignited engines used in agricultural operations.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx TBD TBD TBD TBD TBD TBD TBD PM2.5 TBD TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBD TBD Tons per day – annual average NOx TBD TBD TBD TBD TBD TBD TBD PM2.5 TBD TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBD TBD

• EIC Affected: 010-040-0110; 010-040-1200; 020-040-0110; 020-040-1200; 030-040-0100; 030-040-0110; 030-040- 0124; 030-040-1100; 030-040-1200; 030-040-1210; 040-040-0110; 050-040- 0012; 050-040-0110; 050-040-0124; 050-040-1200; 050-040-1299; 050-040- 3220; 050-995-1220; 052-040-0110; 052-040-1200; 052-042-1200; 060-040- 0012; 060-040-0110; 060-040-0124; 060-040-0142; 060-040-0146; 060-040- 1100; 060-040-1200; 060-040-1210; 060-995-1220; 099-040-1200

• The ARB emissions inventory does not in clude the emissions from stationary internal combustion engines rated at 50 bhp-hr or less are not included in the emissions inventory. A survey of busi nesses and industries is needed to accurately determine the total number of small engi nes and to calculate their emissions.

• A survey of agricultural operation (AO) sources is needed to accurately determine the total number of AO spark-ignited engi nes and update the emissions inventory. Based on extrapolation from pr eliminary data provided by a stakeholder, there are at least 1,000 AO spark-ignited engines operating within th e District.

Current Control:

• Rule 4702 applies to stationary internal combustion engines gr eater than 50 bhp-hr. Small stationary spark-ignit ed engines rated at 50 bhp-hr or less are exempt from Rule 4702.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-29 Small Spark-Ignited Engines and Ag ricultural Spark-Ignited Engines (Continued)

• Rule 4702 NOx limits for spark-igni ted engines (greater than 50 bhp-hr) used exclusively in agricultural operations (AO) are: Rich burn – 90 ppmv or 80 percent reduction; lean-burn – 150 ppmv or 70 per cent reduction. The full compliance schedule for these engines is 2009, or 2010 if an operator has an agreement to replace an existing engine with an electric motor.

• For non-AO spark-ignited engines (greater than 5 bhp-hr): Rich- burn – 25 ppmv or 96 percent reduction; lean-burn – 65 ppmv or 90 percent reduction. The full compliance schedule for non-AO engines is 2007.

Future Control Options:

• Electrification – replacing engines wit h electric motors – where possible.

• Evaluate potential controls fo r small spark-ignited engines.

• Consider lowering the curr ent NOx emission limits in Rule 4702 for agricultural spark-ignited engine to the same level as non-AO units (i.e., rich-burn: 25 ppmv; lean-burn: 65 ppmv).

• Evaluate the feasibility of South Coast Air Quality Management District (SCAQMD) currently proposed amendments to Rule 1110.2 (Emissions from Gaseous- and Liquid-Fueled Engines) that would lower the NOx limit to 11 ppmv by July 1, 2011 to determine if agricultural spark-igni ted engines could meet the limit.

Discussion:

• The District has legal authority to regulate air emissions from units in this source category located at stationary sources.

• Federal law prohibits air districts from regulating stationary engines 25 bhp-hr or less. Therefore, the District could r egulate engines greater than 25 bhp-hr.

• SCAQMD is currently pr oposing amendments to Rule 1110.2 (Emissions from Gaseous- and Liquid-Fueled Engines). Ru le 1110.2 applies to all portable and stationary engines greater than 50 bhp-hr. The proposal would lower the NOx emissions limits for engines greater than or equal to 500 bhp-hr from 36 ppmv to 11 ppmv, and 45 ppmv for engines less than 500 bhp-hr effective July 1, 2010. Effective on and after July 1, 2011, the NO x limit would be 11 ppm v. For landfill and digester gas-fired engines the current limit would be lowe red to 11 ppmv NOx effective on and after July 1, 2012.

• Additional NOx reductions could be achieved by loweri ng the current emission limits for agricultural spark-ignited engines and by expanding the applicability of existing Rule 4702 so that engines rated at gr eater than 25 bhp-hr to 50 bhp-hr would be subject to the rule.

Recommendation:

• Explore opportunities for incentive fundi ng and regulatory action to achieve earlier and additional emission reductions from this source category.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-30 Small Spark-Ignited Engines and Ag ricultural Spark-Ignited Engines (Continued)

• Conduct an emissions inventory survey to determine the total number of small spark-ignited engines and agricultural operati ons spark-ignited engines operating in the District.

• Evaluate potential controls fo r small spark-ignited engines.

• Evaluate if SCAQMD’s propos ed 11 ppmv NOx limit is feasib le for agricultural sparkignited engines.

• District staff recommends this source cat egory as a control measure for Feasibility Study.

Projected Reductions: Emission reductions will be calculated bas ed on the information derived from the Feasibility Study, but are not quantifiable at this time.

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQ Tons per day – annual average NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-31 

### Glass Melting Furnaces (S-COM-7) (Glass and Related Products)

Source Category: This source category includes any glass-melt ing furnace. Within the District, there are four types of glass produced: container glass (bottles and jars ), flat glass (windows and automobile windshields), wool fiberglass ( building insulation), and continuous strand fiberglass (aircraft insulation and filter media for air and water).

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 9.38 8.16 8.37 8.56 8.73 8.94 9.08 PM2.5 1.03 1.10 1.12 1.15 1.17 1.20 1.22 SO 2 3.79 4.07 4.17 4. 26 4.34 4.44 4.52 Tons per day – annual average NOx 9.38 8.17 8.37 8.56 8.73 8.94 9.08 PM2.5 1.03 1.10 1.12 1.15 1.17 1.20 1.22 SO 2 3.79 4.07 4.17 4. 26 4.34 4.44 4.52

• EIC Affected: 460-460-7037, 460-460- 7038, 460-460-7039

Current Control: Rule 4354 regulates the emissions from furnaces use to melt sand and other ingredients to produce glass products. NO x emission limits r ange from 4.0 to 9.2 pounds NOx per ton of glass pulled, depending on market sector, firing technology, and emission averaging period. VOC emission limit s are 20 ppmv or range from 0.1 to 0.25 lb/ton glass pulled depending on market sector and firing technology. Operators meet current emission limits through a selection of furnace firing technology and glass raw materials.

With recent rule amendments, Rule 4354 applie s to all industrial glass-melting furnaces in the District. The NOx emissions are cont rolled 67% to 76% compared to uncontrolled glass-melting furnaces.

Future Control Options:

• NOx controls: 100% Oxy gen fired (Oxy-fueled), proprietary 3R technology, Selective Catalytic Reduction (SCR), and electric furnaces.

• Particulate controls: Gaseous fuel, Bag house (mechanical filter), wet scrubber, and electrostatic precipitator.

• SOx controls: Raw material se lection, and scrubbers (wet or dry).San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-32 Glass Melting Furnaces (Continued)

Discussion:

• Lower NOx emissions have been achieved within the District with changes to traditional firing technology, gl ass formulations, and controls.

• SCR is an add-on control that may help oper ators meet lower NO x limits. SCR has been used by other source categories to reduce NOx emissions. Glass melting furnaces in Europe and Asia have successfu lly used SCR to control NOx emissions, but to date; no facility in the US has implemented this control technology.

• Emission reductions from the last fur naces to meet the 2002 rule amendments will begin starting in 2008. There are four furnaces with NO x limits greater than these limits that are expected to be rebuilt by 2012: three c ontainer glass furnaces and one flat glass furnace. The most cost-e ffective time to change NOx controls is during furnace rebuild. To ensure that furnaces meet the limits by 2012, it is recommended that rule develop ment be completed by 2009.

• Operators have increased production capacity during t he most recent round of rebuilds, triggering Best Available Cont rol Technology (BACT) provisions. The BACT provisions have resulted in NOx emi ssions limits that are much less than 3 and 5 pounds per ton of glass pulled for c ontainer/fiberglass and fl at glass furnaces, respectively, so the current dra ft rule proposes similar limits.

• When fully implemented, Distr ict staff has estimated th at actual NOx emission reductions from rule amendments would be an additional 0.4 tons per day beginning in 2012.

Recommendation: A rule project for this control measure has already begun. Estimated adoption of amendments is third quarter 2008, with full implementation possible by 2012.

Projected Reductions: NOx data reflects the estimated reductions from the draft ru le amendments and the reductions from the current rule, which have not been added to the inventory. PM2.5 and SOx reductions will be calc ulated based on the informati on derived from current rule development project, but are not quantifiable at this time.

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 1.22 1.25 1. 18 1.60 1.67 1.58 PM2.5 TBD TBD TBD TBD TBD TBD SOx TBD TBD TBD TBD TBD TBD Tons per day – annual average NOx 1.22 1.25 1. 18 1.60 1.67 1.58 PM2.5 TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBDSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-33 

### Lime Kilns (S-COM-8) (Food & Ag Processing)

Source Category: This source category pertains to facilities operating lime kilns in a wide variety of manufacturing and processing operations , including food and agriculture.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx TBD TBD TBD TBD TBD TBD TBD PM2.5 TBD TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBD TBD Tons per day – annual average NOx TBD TBD TBD TBD TBD TBD TBD PM2.5 TBD TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBD TBD

• EIC Affected: Need to assign an EIC because lime kilns are not included in the ARB emissions inventory. There is only one device operating in the District and it currently complies with the rule associated with this device.

Current Control: District Rule 4313 limits NOx emissions from lime kilns to no more than 0.1 lb/MMBTU for gaseous fuel-fired; 0.12 lb/MMBTU for distill ate fuel oil-fired; 0.20 lb/MMBTU residual fuel oil-fired

Future Control Options:

• Future control option includes loweri ng the current NOx emission limits.

• Available retrofit combustion control technologies to achieve lower NOx limits include low NOx burner and ul tra low NOx burners fir ed on natural gas. Add-on controls such as SCR or SCNR is technologi cally feasible but its cost effectiveness should be examined for this application.

Discussion:

• The District has legal authority to regulate these units which are located at stationary

sources.

• There is only one permitted lime kiln operati ng in the District. The kiln is operated only during ozone season to manufacture sugar.

• The current permit allows firing on distillate f uel oil (#6 fuel oil) as primary fuel and natural gas as back-up fuel.

• Current NOx limit of 0.1 lb/MMBtu is considered uncontrolled emission limit.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-34 Lime Kilns (Continued)

• Lower the NOx limits to at least 0.036 lb/M MBtu (30 ppmv) fired on natural gas fuel and 0.052 lb/MMBtu (40 ppmv) fir ed on liquid fuel (residual fuel oil or distillate oil), at 3% excess oxygen.

• Require firing on natural gas as primary f uel. Distillate oil firing as a back-up fuel could be allowed during natural gas curtailment period.

• A reduction of about 64% from current emissions level could be achieved by lowering the NOx limit to at leas t 30 ppmv for natural gas firing.

• A reduction of about 75% from current emissions level could be achieved by lowering the NOx limit to at leas t 40 ppmv for distillate oil firing.

Recommendation:

• Staff recommends this source category be controlled through regulatory method with implementation schedule not ear lier than 2012 to allow time to design, procure, and install retrofit control technology. Co mpliance schedule for the new emission limit should coincide during off-season when the kiln is not operating so retrofit could be completed without disrupting norma l manufacturing operations.

• Amend Rule 4313 to lower the NOx limits. A reduction of between 64% to 75% from current emissions level from this source category could be achieved by combustion control retrofit technologies discussed abov e depending on the type of fuel (natural gas or distillate) used to fire the unit.

• Consider inclusion of an alternative comp liance option to improve cost effectiveness of this control measure.

• Based on the current emissions inventory or lack thereof, control level, and existing technology, emission reductions are not quant ifiable for this source category. However, a future study to re-evaluate th is source category may be planned in the future.

Projected Reductions: Calculated emission reductions, a ssuming the recommended controls:

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 0 0 0 PM2.5 0 0 0 0 0 0 SOx 0 0 0 0 0 0 Tons per day – annual average NOx 0 0 0 0 0 0 PM2.5 0 0 0 0 0 0 SO 2 0 0 0 0 0 0San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-35 

### Residential Water Heaters (S-COM-9) (Residential Fuel Combustion)

Source Category: Units in this source category are water heat ers sold for use in private residences.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 1.37 1.28 1.29 1.30 1.31 1.32 1.33 PM2.5 0.17 0.17 0.18 0.18 0.18 0.18 0.18 SO 2 0.01 0.01 0.01 0. 01 0.01 0.01 0.01 Tons per day – annual average NOx 1.37 1.28 1.29 1.30 1.31 1.32 1.33 PM2.5 0.17 0.17 0.18 0.18 0.18 0.18 0.18 SO 2 0.01 0.01 0.01 0. 01 0.01 0.01 0.01

• EIC Affected: 610-608-0110

Current Control: District Rule 4902 currently requires any new or replacement natural-gas fired, new resi dential water heaters, which ar e rated at less than 75,000 BTU heat input, not to exceed 93 pounds of NOx emissions per billion Btu (lb of NOx/bBtu) of heat input.

Future Control Options:

• New water heaters are designed to be more energy efficient and emit less NOx, using low-NOx combustion technology.

• Electrification – replacement with electric water heaters – could also significantly lower NOx emissions.

• Encourage early replacement of exiting units using eith er a specific compliance schedule or incentive funding.

Discussion:

• Lower NOx limits are currently in plac e in SCAQMD Rule 1121 which are become effective in 2007 and 2008. Because of the tendency for manufacturers to supply SCAQMD-complying products for the entire state, many new wa ter heaters in the San Joaquin Valley may already meet the new limits.

• Nonresidential water heaters and mobile ho me heaters are exempt from current rule requirements, although these applications generally use similar water heating devices.

• The transition from older to newer, less NO x-emitting units currently occurs through attrition and assumes a 20-year lifetime for water heaters.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-36 Residential Water Heaters (Continued)

• The reductions from the new water heaters are mainly in the form of NOx since the VOC emissions are c onsidered negligible.

Recommendation:

• Amend Rule 4902 to lower the NOx emission limit, similar to SCAQMD Rule 1121 standard for post-2008 units and expand its applic ability to nonresidential and mobile home heaters, taking into account any technological limitations.

• Control PM2.5 and SO2 by requiring the uni ts be fired exclusively on PUC-quality natural gas, propane, or liquefie d petroleum gas (LPG). T he use of liquid fuel with a sulfur content of 15 ppm or less would be allowed onl y during PUC-quality natural gas curtailment periods.

• Currently this source category is not a candidate for incentive funding, but further analysis and study will be done during the rule project to determine if this source category may garner cost effect ive reductions in the future provided funding sources are available.

Projected Reductions: Calculated reductions assuming the re commended emission limits described below:

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0.20 0.25 0.32 0.40 PM2.5 TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBD Tons per day – annual average NOx 0 0 0.20 0.25 0.32 0.40 PM2.5 TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBD

• The reductions reflect controls that come by natural attrition of the units, which is projected to take 20 years resulting in a r eduction rate of 5% per year of the final emission reduction total.

• The reductions are based on 75% reduction of NOx (reducing from 93 to 23 lb of NOx/billion Btu) for th e additional applicable units.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-37 

### Natural Gas-Fired, Fan-Type Residential Central Furnaces (S-COM-10) (Residential Fuel Combustion)

Source Category: This source category covers natural gas-fir ed, residential central heating furnaces. These units are in the size range of rat ed heat input capacity of less than 175,000 British thermal units per hour and, for co mbination heating and cooling units, a rated cooling capacity of less than 65, 000 British thermal units per hour.

Emissions Inventory: Data reflects current controls and regulations, but does not reflect the reductions from the proposed control.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 4.21 4.09 4.06 4.03 4.00 3.97 3.93 PM2.5 0.34 0.33 0.33 0.33 0.32 0.32 0.32 SO 2 0.03 0.03 0.03 0. 03 0.03 0.02 0.02 Tons per day – annual average NOx 2.49 2.42 2.40 2.39 2.37 2.35 2.33 PM2.5 0.20 0.20 0.19 0.19 0.19 0.19 0.19 SO 2 0.02 0.02 0.01 0. 01 0.01 0.01 0.01

• EIC Affected: 610-606-0110-0000

Current Control:

• Rule 4905 was adopted on October 20, 2005 and limits NOx emissions from residential central furnaces.

• The rule requires any new or replacement natural gas-fired fan-type residential central furnace to have certified emissions of oxides of nitrogen less than or equal to 0.093 pounds of oxides of nitrogen per m illion BTU heat output or 55 ppm NOx at 3.00% O 2 stack gas by volume (dry).

Future Control Options:

• Low-NOx burner (LNB) technology wit h NOx emissions of approximately 0.046 lb/MMBtu has been developed, but it has not reached the commercially available stage. These burners could be requir ed when the technology matures.

• Incentivize the use of more efficient “condensing” heating units, which have Annual Fuel Utilization Efficiency (AFUE) upwards of 90%, in contrast to “noncondensing” units that have 78% AFUE. Higher effi ciencies lead to less fuel usage and lower total emission amounts.

• Require state-of-the-art c ontrol systems that minimize energy use and reduce fuel consumption.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-38 Natural Gas-Fired, Fan-Type Residential Central Furnaces (Continued)

Discussion:

• A 50% NOx emission reduction could be achieved by requiring LNB on units, once that technology is commercially viable.

• Currently, there are no known units that operate with both PM2.5 and SO2 control devices for these units. PM2.5 and SO2 emissions will be cont rolled by ensuring complete combustion of natural gas fuel. Natural gas contains only trace quantities of non-combustible material. Since natural gas fuel is inherently low in sulfur content, additional controls have not been r equired or developed that would reduce emissions further. Since these units are fi red on natural gas, no significant reduction in PM2.5 and SO2 is anticipated.

Recommendation:

• LNB are not currently commercially avai lable but do present the possibility of significant reductions from new or replac ement units. Therefore, staff recommends amending Rule 4905 to establish more stri ngent NOx limits for new and replacement units.

Projected Reductions: Emission reductions will be estimated during the plan rule development process.

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQ Tons per day – annual average NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-39 

### Dryers (S-COM-11) (Mineral Processes, Other – Industrial Processes)

Source Category: This source category includes any dryer, dehydrator, or oven . Some examples of units subject the this rule are onion dehydrators, dryers that conver t liquid milk to dried milk, and units used to dry aggreg ate at asphalt plants.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 2.46 2.63 2.67 2.73 2.78 2.83 2.90 PM2.5 0.94 1.00 1.01 1.02 1.03 1.05 1.06 SO 2 1.52 1.63 1.66 1. 69 1.73 1.75 1.79 Tons per day – annual average NOx 2.49 2.66 2.70 2.77 2.81 2.87 2.93 PM2.5 0.99 1.06 1.07 1.08 1.09 1.10 1.12 SO 2 1.64 1.76 1.79 1. 82 1.86 1.89 1.93

• EIC Affected: 430-422-7078, 430-424-7006, 430-995-7000, 499-995-0000, 499-995-5630

Current Control: District Rule 4309 requires dehydrators to be fired on PUC-quality nat ural gas; all others units have a NOx emission limit of 3.5 to 5.3 ppmv using an oxygen correction factor. Operators may meet NOx emission limit using a NOx emission control system.

Because this rule was recently adopted, no estimation has been made of the proportion of additional units that are at least 5 MMBtu/hr or larger that will be subject to this rule. At full implementation of t he current rule requirements, NOx emissions from units subject to the rule are estimated at 66% of uncontrolled emissions.

Future Control Options:

• No new technologies that are not current ly specified under cu rrent controls are known at this time.

Discussion:

• Low-NOx burners are already in use for sour ces subject to rule provisions. Some of the sources that are currently exempt from the rule are al ready using this technology as part of their Pe rmit to Operate.

• The bulk of the dryers, dehydrators, and ov ens operate at temperat ures that are too low for efficient operation of NOx em ission control system s, therefore add-on controls are not an option for this source category.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-40 Dryers (Continued)

• Some currently exempt units operate for a short limited season, for example, dryers and humidifiers at cotton gins, so the amount of NOx emission redu ctions from these units would be small since nearly all exem pted units run on PUC natural gas which is a clean burning technology.

• Another option for this rule is to change the rule applicability by reducing the total heat input cut-off for units subj ect to the rule below the cu rrent 5.0 MMBtu/hr. As the heat input cut-off decreases, t he sources that would be affected by the rule become more diverse. For example, commercial laundry dryers and ovens for pre-packaged tortillas are units that are in the range of 2 to 3 million Bt u/hr. Since the industries would be varied, more analysis would be needed throughout the rule development project to adequately assess the technology available for these lower heat input units. Nearly all of the exempted units are firing on PUC-quality natural gas already, which is a very clean-burning technology.

Recommendation:

• The recent adoption of this rule has maximized the possible emission reductions from this source category. Future equi pment advancements may produce additional reductions from exempt equipment. A feasib ility study to re-evaluate this source category is planned.

Projected Reductions: Calculated emission reductions, a ssuming the recommended controls:

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQ Tons per day – annual average NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-41 

### Wood Burning Fireplaces a nd Wood Burning Heaters (S-COM-14) (Residential Fuel Combustion)

Source Category: This source category includes fireplaces an d heaters that burn wood for space heating.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 2.12 1.77 1.73 1.66 1.59 1.52 1.46 PM2.5 20.44 17.67 17.37 16.75 16.22 15.72 15.22 SO 2 0.33 0.34 0.34 0. 34 0.34 0.34 0.35 Tons per day – annual average NOx 1.09 0.91 0.89 0.85 0.81 0.78 0.75 PM2.5 10.48 9.06 8.90 8.59 8.31 8.06 7.80 SO 2 0.17 0.17 0.17 0. 17 0.18 0.18 0.18

• EIC Affected: 610-600-0230-0000; 610-602-0230-0000

Current Control: Rule 4901 regulates the emissions of particulate matter and carbon monoxide from wood burning fireplaces and wood burning heaters (devices) are currently regulated in the S an Joaquin Valley under Rule 4901. The rule was adopted in 1993 and amended in 2003.

• Exempts gaseous-fueled devices and cook st oves described in the Code of Federal Regulations.

• From November through February, the epi sodic wood burning curtailment provisions prohibits using wood burning devices when the Air Quality Index (AQI) value is predicted to be 150 or higher for a specific geographic region (county).

• Wood burning devices located at least 3000 f eet in elevation, or where natural gas service is not available, or if they are t he sole source of heat in a residence are not subject to the episodic curt ailment provisions.

• New wood burning device must be either an EPA Phase II certified unit or a pelletfueled device.

• Real property cannot be sold or transfe rred if it includes a wood burning heater, unless each heater in the real property is EPA certified. Seller must provide the recipient and the District a signed statement that the device is EPA certified.

• A wood burning fireplace cannot be installe d in a new residential development with a density greater than two dw elling units per acre.

• No more than two EPA Phase II certifi ed wood burning heaters c an be installed per acre in any new residential development with more than three dwelling per acre.

• Certain materials, such as waste wood and coal, cannot be burned in the devices.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-42 Wood Burning Fireplaces and Wood Burning Heaters (Continued)

Future Control Options:

• The current AQI threshol d of 150 for declaring mandatory curtailment of wood burning activities needs to be lowered to an appropriate level to achieve additional emission reductions necessary in attain ing the new federal PM2.5 standard.

• Wood burning devices located at least 3,000 elevation, or where natural gas service is not available, or if they are the sole s ource of heat, are current ly not subject to the rule. The rule could include a provision to allow counties, cities, and municipalities to require residents their geographical ar eas to participate in mandatory burn curtailment program, even t hough they are otherwise exem pt from the curtailment.

• Rule applicability could be extended to include wood-burning chimineas, fire pits, and outdoor fireplaces.

Discussion:

• The District has the authority to regulate this source category.

• Rule 4901 is one of the most stringent rule s in the nation. Ot her air districts have used it as a model when developing their rules.

• The District’s “Check Before You Burn” Program has raised public awareness to a high level and the active participation of Valley residents resulted in significant emission reductions that enabled the District to attain th e federal PM10 standards.

Recommendation:

• Staff recommends amending Rule 4901 with implementation schedule in 2009.

Projected Reductions: Calculated reductions assuming the re commended emission limits described below:

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0.0 0.08 0. 15 0.14 0.14 0.14 PM2.5 0.0 0.76 1. 48 1.43 1.39 1.35 SO 2 0.0 0.01 0.03 0.03 0.03 0.03 Tons per day – annual average NOx 0.0 0.04 0. 08 0.07 0.07 0.07 PM2.5 0.0 0.39 0. 76 0.73 0.71 0.69 SO 2 0.0 0.01 0.02 0.02 0.02 0.02San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-43 

### Prescribed Burning and Ha zard Reduction Burning (S-GOV-6) (Managed Burning and Disposal)

Source Category: This source category includes activiti es related to prescribed burning and hazard reduction burning in wildla nd/urban interface areas.

Emissions Inventory: Data includes current controls and regulations but does not reflect the reductions from the proposed control.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0.37 0.36 0.36 0.36 0.35 0.35 0.35 PM2.5 1.17 1.14 1.14 1.13 1.12 1.12 1.11 SO 2 0.07 0.07 0.07 0. 07 0.07 0.07 0.07 Tons per day – annual average NOx 1.77 1.77 1.77 1.76 1.76 1.76 1.76 PM2.5 5.10 5.07 5.07 5.06 5.06 5.05 5.05 SO 2 0.52 0.52 0.52 0. 52 0.52 0.52 0.52

• EIC Affected: 670-666-0200, 670-667-020 0, 670-668-0200, 670-670-0200

Current Control:

• District Rule 4106 authorizes restrictions on material; burning allocations; prescribed burning requirement; permits for haza rd reduction burning; smoke management plans for prescribed burning; go/no go decisi ons for naturally ignited Wildland Fire Use fires

• Hazard reduction burning occurs generally from late October/early November through May 1st.

Future Control Options:

• Encourage and/or incentivize land managem ent practices that result in less uncontrolled and untimely fires

Discussion:

• The District has authority over emi ssions from this source category.

• District Rule 4106 is currently the most stri ngent regulatory strategy in California for this source category.

• While the hazard reduction burning is stri ngently regulated, other alternatives to burning exist. Particularly for homeowners, much green waste is generated in preparing their property to meet the guidelin es adopted by the California to minimize wildfire propagation. Since these properties are outside city limits, green waste collection is not usually offered as part of the county waste collection program.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-44 Prescribed Burning and Hazard Reduction Burning (Continued)

A few homeowners compost their own material s, but most do not. Woody materials could be chipped to make mulch, but the co st of a chipper that could process goodsized tree limbs is too costly for most resi dents. Therefore, t he most cost-effective solution for homeowners currently is burning the dried plant materials.

• This source category could be a candida te for an incentives program such as offering free or reduced cost hauling of t he green waste from pr ivate properties at the wildland/urban interface. Free or r educed cost for chipping/grinding of woodbased materials could also be considered.

• Hazard reduction burning is allow ed with a burn permit within the State Responsibility Area and the Federal Responsi bility Area of the District. These areas are generally the foothill and mountain areas of the District. Such burning is prohibited in the Local Responsibility Ar ea, which represents the valley floor.

• Fire Safe Councils and Resource Cons ervation Districts wit hin the urban/wildland interface often receive Federal grant monies for fuel break and hazard fuel reduction programs, of which much of the accumulated materials ar e chipped and not burned. Examples include the Hwy 168 Fire Safe Council, the Eastern Madera Fire Safe Council, the Central Sierra Watershed Commi ttee, the Yosemite/Sequoia Resource Conservation and Development Area, and the Coarsegold Resource Conservation District.

Recommendation:

• This source category is recommended for an incentives program or policy changes to achieve additional emission reduct ions from this source category.

• The magnitude of the current emissions inventory for this source category warrants a close look at possible methods of reducin g emissions. A feasibility study to closely examine alternatives to prescribed burning is planned.

Projected Reductions: Emissions reductions will be qua ntified during the rule dev elopment process when the appropriate AQI threshold for mandatory curtailment of wood burning activities is established.

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQ Tons per day – annual average NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-45 

### Cotton Gins (S-IND-8) (Food and Agriculture)

Source Category: This source category includes all cott on ginning facilities within the District.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 0 0 0 0 PM2.5 0.91 0.77 0.75 0.76 0.77 0.78 0.79 SO 2 0 0 0 0 0 0 0 Tons per day – annual average NOx 0 0 0 0 0 0 0 PM2.5 0.66 0.56 0.54 0.55 0.56 0.57 0.58 SO 2 0 0 0 0 0 0 0

• EIC Affected: 420-418-6028, 420-420-6028

Current Control: To reduce PM10, District Rule 4204 requires the use of BACT-level 1D3D cyclones for existing cotton gins according to a compliance schedule. The rule also requires that new cyclones or replacement parts of existing cyclones have the dimensional characteristics of the Enhanc ed 1D3D cyclone or the 1D3D with expansion chamber. Rule 4204 also regulates the tras h conveyance systems on gins.

Future Control Options:

• Additional research is required to dete rmine if controls such as baghouses, stacked cyclones or other PM10 controls are applicab le to controlling PM2.5 emissions from cotton gins.

Discussion:

• The District has legal authority to regulate this source category.

• A variety of studies have been conducted whic h may indicate that the PM2.5 fraction of the PM emissions from this may not be as significant as the PM coarse fraction. A better quantification of t he PM2.5 fraction is required to develop a more accurate emissions inventory for the vari ous activities in this category and to indicate the level of significance of those PM2.5 emissions.

• Research at Texas A&M University cited the 1D3D and 2D2D cycl ones as the most efficient collectors of fine dust (PM10) with the 1D3D more efficient than the 2D2D. A number of jurisdictions have thus cla ssified the 1D3D as BACT for PM10.

• Two jurisdictions, Maricopa County (AZ) and the State of Nort h Carolina, require 1D3D and/or 2D2D cyclones in ginning op erations for control of PM10.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-46 Cotton Gins (Continued)

• If the inventory study shows this to be a si gnificant source of PM 2.5, research would be needed to identify and characterize control techniques. At this time, PM2.5 emission control factors are not well defined and it is not known if controls for PM10 are effective for producing PM2.5 emissions reductions for this category. Further review of available research is necessa ry to determine feasible, cost-effective control measures, should they be necessary.

• Rule 4204 (Cotton Gins) is currently the mo st stringent in the nation for this source category to control PM10.

Recommendation: While PM10 emissions and controls for this category are well esta blished, there is evidence that such data may not apply directly to PM2.5 emission and controls. District staff recommends that a Feasibility Study be conducted and completed by 2010. The Study would first examine the PM2.5 fracti on of the emissions from this category and would use that information to develop a repres entative emissions inventory. If that inventory appears to be significantly large and contribute to the non-attainment problem, staff would then exami ne control effectiveness for PM2.5 r eduction strategies that could be used to reduce the PM 2.5 inventory.

Projected Reductions: Emission reductions will be calculated bas ed on the information derived from the Feasibility Study, but are not quantifiable at this time.

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 0 0 0 PM2.5 TBD TBD TBD TBD TBD TBD SO 2 0 0 0 0 0 0 Tons per day – annual average NOx 0 0 0 0 0 0 PM2.5 TBD TBD TBD TBD TBD TBD SO 2 0 0 0 0 0 0San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-47 

### Commercial Charbroiling (S-IND-9) (Commercial Cooking)

Source Category: This source category includes charbroiling equipment located in restaurants, including hospitals, educational institutions, military, and governm ent facilities.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day - winter season NOx 0 0 0 0 0 0 0 PM2.5 2.68 2.84 2.89 2.93 2.97 3.02 3.06 SO2 0 0 0 0 0 0 0 Tons per day - annual average NOx 0 0 0 0 0 0 0
PM2.5 2.68 2.84 2.89 2.93 2.98 3.02 3.06 SO2 0 0 0 0 0 0 0

• EIC Affected: 690-680-6000

Current Control:

• Existing Rule 4692, adopted in April 2002, applies only to chain-driven charbroiling equipment to control VOC and PM10 emissions, but not to all under-fired charbroilers. Operators of chain-driven charbroilers must install and operate an approved catalytic oxidizer on their charbroiler exhaust stack.

Future Control Options:

• Expand the applicability of Rule 4692 to in clude control of emissions from underfired charbroilers.

• The BAAQMD draft Regulation 6 Rule 2 would require operat ors of under-fired charbroilers, at least 10 square feet, to exhaust their emissions to an approved PM10 control device. The BAAQMD does not consider VOC control from underfired charbroilers to be economically feas ible. If the PM10 c ontrols prove to be feasible, similar requirements could be added to Rule 4692.

• BAAQMD Draft Staff Report indicated that regulating under fired charbroilers. could reduce PM emissions from under-fired charbroilers about 90%.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-48 Commercial Charbroiling (Continued)

Discussion:

• The District has legal authority to regulat e air emissions units located at stationary

sources.

• The total number of affected sources operating under-fired charbroilers equipment would need to be determined, as well as the amount of meat being cooked. Information of number of cooking estab lishments may be obtained from the county or city Health Departments responsible for inspecting and regulating such food establishments.

• A baseline emissions for under-fired c harbroilers would need to be determined because the ARB inventory reported total emissions from both under-fired versus chain-driven charbroilers. BAAQMD Dra ft Staff Report for Regulation 6 Rule 2 stated that according to U.C. River side study conducted in 1997 under-fired charbroilers account for 82% of PM emissions generated by restaurants.

• This control measure will primarily tar get PM emissions reduction from under-fired charbroilers since the BAAQMD has determi ned that control of VOC emissions from under-fired charbroilers not economically feasible.

• Currently, there are no achieved-in-practic e or technologically feasible control technologies to reduce NOx or SO 2 emissions from charbroiling equipment.

Recommendation:

• Expand applicability of Rule 4692 to r egulate PM emissions from under-fired charbroilers with full implementation by 2011.

Projected Reduction: Calculated emission reductions, a ssuming the recommended controls:

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 0 0 0 PM2.5 0 0 2.16 2.21 2.25 2.28 SO 2 0 0 0 0 0 0 Tons per day – annual average NOx 0 0 0 0 0 0 PM2.5 0 0 2.17 2.21 2.25 2.28 SO 2 0 0 0 0 0 0San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-49 

### Fugitive PM10 Prohibitions (S-IND-10) (Construction, demolition, excavation, ex traction or other earthmoving activities; handling transport, and storage of bulk material s; landfill operations; unpaved roads, unpaved vehicle/equipment traffic areas ; disturbed open areas; and off-field agricultural sources.)

Source Category: Anthropogenic (human-caused) activities resu lt in the majority of fugitive dust emissions. Mechanical disturbance (for exam ple, vehicles traveling over an unpaved surface, or earthmoving operations associat ed with construction activities, or sand and gravel or other mining activities) is a signific ant source of fugitive dust emissions). Wind events, although infrequent in t he San Joaquin Valley, also contribute to fugitive dust emissions especially as wind travels over pr eviously disturbed, unstabilized surface.

Emissions Inventory: Refer to Emissions Inventory fo r each Regulation VIII rules below.

Current Control:

• Existing Regulation VIII (Fugitive PM10 Prohibi tions) is comprised of eight rules that regulate fugitive dust emissions. Regulat ion VIII applies to anthropogenic dust sources; it does not apply to PM10 precur sor sources or sources of smoke. Specifically, Regulation VIII applies to activi ties that have the pot ential to emit or result in primary PM10 fugitive dust emi ssions such as construction, demolition, excavation, extraction or other earthm oving activities; handling transport, and storage of bulk materials; landf ill operations; unpaved roads, unpaved vehicle/equipment traffic areas; dist urbed open areas; and off-field agricultural

sources.

• The eight rules under Regulation VIII are: Rule 8011 (General Requirements); Rule 8021 (Construction, Demolition, Excavati on, Extraction, and other Earthmoving Activities); Rule 8031 (Bulk Materials); (4) Rule 8041 (Carryout and Trackout); Rule 8051 (Open Areas); Rule 8061 (Paved and Unpaved Road); Rule 8071 (Unpaved Vehicle/Equipment Traffic Areas); and Rule 8081(Agricultural Sources). Current control requirements of each rule are discussed below.

Future Control Options:

• Change existing administrative requirement s and dust control plan s, applicability, thresholds (e.g. amount of ac tivity such as vehicular pa sses per day, size of an area where an activity occurs, or amount of material moved during an activity, and additional control options).

• Eliminate or reduce current exemptions.

• Evaluate techniques that prevent fugitive dust as opposed to techniques that require a reactive or mitigation response (e.g., prevent soil trackout instead of clean up of trackout).

• Enhance District enforcement presence in the field for increased compliance assistance and greater public outreach.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-50 Fugitive PM10 Prohibitions (Continued)

Discussion:

• A variety of studies have been conducted whic h may indicate that the PM2.5 fraction of the PM emissions from this may not be as significant as the PM coarse fraction. A better quantification of t he PM2.5 fraction is required to develop a more accurate emissions inventory for the vari ous activities in this category and to indicate the level of significance of t hose PM2.5 emissions.

• If the inventory study shows th is to be a signific ant source of PM2. 5, research would be needed to identify a nd characterize control techniq ues. At this time, PM2.5 emission control factors are not well defined and it is not known if controls for PM10 are effective for producing PM 2.5 emissions reductions for this category. Further review of available resear ch is necessary to determi ne feasible, cost-effective control measures, should they be necessary.

• Please refer to specific discussions for eac h of the rule in Regulation VIII, which follow below.

Recommendation: While PM10 emissions and controls for this category are well esta blished, there is evidence that such data may not apply directly to PM2.5 emission and controls. District staff recommends that a Feasibility Study be conducted and completed by 2010. The Study would first examine the PM2.5 fraction of the emissions from this category and would use that information to develop a repres entative emissions inventory. If that inventory was significantly la rge, staff would then exami ne control effectiveness for PM2.5 reduction strategies that could be used to reduce the PM2.5 inventory.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-51 1. Rule 8011 (General Requirements)

Source Category: The provisions of Rule 8011 ar e applicable to specified outdoor fugitive dust sources. Rule 8011 contains definitions, exemptions, requirements, administrative requirements, recordkeeping requirements, exemptions, and test methods which are applicable to all rules under Regulation VIII (i.e., Rules 8021, 8031, 8041, 8051, 8061, 8071, and 8081)

Emissions Inventory: There is no specific emissions in ventory associated with Rule 8011.

Current Control:

• Materials used for chemical/organic stabi lization of soils should not violate State Water Quality Control Board standards fo r use as a soil stabilizer. Materials accepted by ARB and EPA, which meet s State water quality standards are acceptable to the District.

• Materials prohibited for use as dust suppr essant by EPA, ARB, or other applicable laws, rules, or regulations are also prohibited for use under Regulation VIII.

• Prohibits the use of hygroscopic materi als as dust suppressant in areas lacking sufficient atmospheric moisture of soil for su ch material to effectively reduce fugitive dust emissions. Use of such materials ma y be allowed in conjunction with sufficient watering of the controlled area.

• Specifies test methods for determination of visible dust emission opacity, stabilized surface, soil moisture content, silt c ontent, threshold friction velocity for demonstration of compliance wit h the standards specified in Regulation VIII rules.

• Allows an alternative compliance option fo r certain specified requirements of Rule 8061 (Paved and Unpaved Road) and Rule 8071 (Unpaved Vehicle/Equipment Traffic Areas) provided the operator subm its a Fugitive PM10 Management Plan that is designed to achieve 50 percent control efficiency and has been approved by the District.

Future Control Options:

• Increase the current 50 percent contro l efficiency required by the alternate compliance option’s Fugitive PM10 Management Plan.

• Evaluate other more effectiv e feasible control techniques.

Discussion:

• Fugitive dust generating activities ar e located at stationary sources and area sources for which the District has legal authority to regulate air emissions.

• Stationary sources subject to Regulation VIII rules are required to obtain operating permits. However, most area sources such as construction, demolition, excavation, or other earthmoving activities are not r equired to obtain operatin g permits from the District. For sources that are not requi red to have operating permits, the District should periodically examine county/city building permits department records to determine the location and durat ion of fugitive dust generating activities so that District inspectors could ensure operator s are complying with the rules.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-52 Rule 8011 (Continued)

• Enhance the effectiveness of the rules thr ough several actions including, but not limited to, an increased presence of District Compliance Division staff in the field, increased use of Dust Control Plans, in creased compliance assistance, and greater public outreach.

Recommendation:

• See recommendations for Regulation VIII as a whole.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-53 2. Rule 8021 (Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities)

Source Category: Sources subject to Rule 8021 include, but ar e not limited to, building and construction industry, mining industry, sand and grav el industry, and oil and gas production.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 0 0 0 0 PM2.5 1 1.00 1.08 1.09 1. 01 1.01 1.02 1.03 SO 2 0 0 0 0 0 0 0 Tons per day – annual average NOx 0 0 0 0 0 0 0 PM2.5 1 1.09 1.18 1.19 1. 10 1.11 1.11 1.12 SO 2 0 0 0 0 0 0 0

1 PM2.5 reductions from existing controls have been assumed to be proportional to PM10 reductions.

• EIC Affected: 630-622-5400-0000; 630-624-5400- 0000; 630-626-5400-0000; 630-628-5400-0000; 630-634-5400-0000

Current Control:

• Rule 8021 applies to any construction, dem olition, excavation, extraction, and other earthmoving activities including, but not limited to, land clearing, grubbing, scraping, travel on site, and travel on access roads to and from the site. Applies to construction of new landfills or modifica tion of existing landfills prior to commencement of landfilling activities.

• Current rule exempts several activities such as blasting activities that have been permitted by the California Div ision of Industrial Safety; maintenance or remodeling of existing buildings and additi ons to existing buildings where the total building area is not increased by more than 50 percent or 10,000 square feet (whichever is less); additions to single family residential build ings; disking of weeds and dried vegetation related to fire prevention required by f ederal, state, or local agency on a site less than one-half (1⁄2) acre; and spreading of landfill daily cover necessary to cover garbage/rubbish in order to preserve pub lic health and safety and to comply with California Integrated Waste Management Board requirements during conditions which would generate fugitive dust.

• The rule requires submission of Dust Cont rol Plan with specific information on the location, total land area that would be di sturbed, including duration of activities, volume of earthmoving activities, type of dust suppressant to be applied, measures to be taken to control carryout/trackout. O perators/owners are required to submit Dust Control Plan for any construction activity on any site 10 or more acres of disturbed surface area for resi dential developments, or five acres or more for non-San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-54 Rule 8021 (Continued)

residential development, or will include moving, depositing, or relocating more than 2,500 cubic yards per day of bulk ma terials on at least three days.

• Basically, the rule requires application of water, chemical/organic stabilizers/dust suppressants in sufficient quantity and frequency so as to limit visible dust emission (VDE) to 20% or less during pre-activity, dur ing active operations and during periods of inactivity.

• Restrict speed limits to no more than 15 mph on uncontrolled unpaved access/haul roads on construction sites.

• Cease outdoor construction, excavation, extraction, and other ear thmoving activities that disturb the soil whenever VDE exceeds 20% opacity.

Future Control Options:

• Evaluate the feasibility of eliminating existing exempt ions or lowering current exemption thresholds.

• Lower existing speed limit on uncontrolled unpaved access/haul roads on construction sites.

• Strengthen the effectiveness of the rule by lowering the current threshold requirements for submission of Dust Control Plan.

• Control techniques that may deem feas ible would be evaluated during the rule development process.

Discussion:

• Fugitive dust generating activities ar e located at stationary sources and area sources for which the District has legal authority to regulate air emissions.

• Stationary sources subject to Regulation VIII rules are required to obtain operating permits. However, most area sources such as construction, demolition, excavation, or other earthmoving activities are not r equired to obtain operating permits from the District. For sources that are not requi red to have operating permits, the District should periodically examine county/city building permits department records to determine the location and durat ion of fugitive dust generating activities so that District inspectors could ensure operator s are complying with the rules.

• Enhance the effectiveness of the rules throug h several actions including, but are not limited to, an increased presence of District Compliance Division staff in the field, increased use of Dust Control Plans, in creased compliance assistance, and greater public outreach.

Recommendation:

• See recommendations for Regulation VIII as a whole.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-55 3. Rule 8031 (Bulk Materials)

Source Category: Sources subject to Rule 8031 include, but ar e not limited to, building and construction industry, mining industry, sand and gravel industry, food and agr icultural processing industry, mineral processing industry, gla ss and related products industry, chemical industry, landfills, and companies t hat transport bulk materials.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 0 0 0 0 PM2.5 0.03 0.03 0.03 0.03 0.03 0.04 0.04 SO 2 0 0 0 0 0 0 0 Tons per day – annual average NOx 0 0 0 0 0 0 0 PM2.5 0.04 0.05 0.05 0.05 0.05 0.05 0.06 SO 2 0 0 0 0 0 0 0

• EIC Affected: 430-436-7006-0000; 430-436- 7078-0000; 430-995-7064-0000

Current Control:

• Rule 8031 exempts several activities such as outdoor storage, hand ling, or transport of bulk materials which would be damaged by wetting or application of chemical/organic dust suppressants if none of t he controls listed in the rule could be implemented to limit VDE to 20% opacity or less or provide a stabilized surface; spreading of landfill daily cover; transport of bulk materials in an outdoor area for a distance of 12 feet or less with the use of a chute or conv eyor device; outdoor storage of bulk material at a single site w here no material is actively being added or removed at the end of the workday or over night and where the total material stored is less than 100 cubic yards; agricultural so urces subject to Rule 8081 (Agricultural sources) or exempt by Ru le 8011 (General Requirements).

• Rule 8031 requires control of fugitive dust emissions from any outdoor handling, storage, and transport of bulk materials in su ch a manner that limit the VDE to 20% opacity or less in addition to implementing s pecific control measures listed in the rule.

o For handling of bulk materials: A pply of water or chemical/organic stabilizers/suppressants that limits VDE to 20% opacity or less; and construct wind barriers or fences with less than 50% porosity and apply water or chemical/organic stabilizers/suppressants.

o For storage of bulk materials: bulk materi al surface needs to be stabilized; cover bulk material with tarp or other suit able material and anchored securely;San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-56 Rule 8031 (Continued)

Construct wind barriers or fences to limit VDE to 20% opacity and less than 50% porosity and apply water or chemical /organic stabilizers/suppressants; and use 3-sided structure wit h the height equal to the height of the stored bulk material and with less than 50% porosity.

o For on-site transporting of bulk materials: Limit vehicular speed on the work site sufficient to limit VDE to 20% opacity; or load haul trucks such that freeboard is not less 6 inches so that VDE is limit ed to 20% opacity; or apply water on top of the load to limit VDE to 20% opacity; or cover haul trucks with tarp or other suitable cover.

o For off-site transporting of bulk mate rials: clean interior of the cargo compartment or cover compar tment before the empty truck leaves the work site; prevent spillage or loss of bulk material from holes or openings in the cargo compartment’s floor, sides, and tailgates ; and load haul trucks such that the freeboard is not less than 6 inches and apply water to the top of the material sufficient to limit VDE to 20% opacity or cover haul trucks with tarp or other suitable cover.

o For outdoor transport of bulk materials: fully enclose the chute or conveyor; operate water spray equipment that suffici ently wets materials to limit VDE to 20% opacity; or wash separated or screened materials to remove conveyed materials having an aerodynamic diameter of 10 microns or less sufficient to limit VDE to 20% opacity.

Future Control Options:

• Spray material with water, as necessary, prior to stacking, loading, unloading, and/or while stacking, loading and unloading.

• Remove material from downwind side of the storage pile when safe to do so.

• Empty loader bucket slowly and keep loader bucket close to the truck to minimize drop height while dumping.

• Pre-water and maintain surface soils in a stabilized condition where support equipment and vehicles will operate.

• Apply water to maintain soil moisture at a minimum of 12%, or for areas that have optimum moisture content for compaction of less than 12%, maintain at least 70% moisture content.

• Change the haul truckload freeboard limit to more than 6 inches.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-57 Rule 8031 (Continued)

Discussion:

• Fugitive dust generating activities ar e located at stationary sources and area sources for which the District has legal authority to regulate air emissions.

• Stationary sources subject to Regulation VIII rules are required to obtain operating permits. However, most area sources such as construction, demolition, excavation, or other earthmoving activities are not r equired to obtain operatin g permits from the District. For sources that are not requi red to have operating permits, the District should periodically examine county/city building permits department records to determine the location and durat ion of fugitive dust generating activities so that District inspectors could ensure operator s are complying with the rules.

• Enhance the effectiveness of the rules throug h several actions including, but are not limited to, an increased presence of District Compliance Division staff in the field, increased use of Dust Control Plans, in creased compliance assistance, and greater public outreach.

Recommendation:

• See recommendations for Regulation VIII as a whole.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-58 4. Rule 8041 (Carryout and Trackout)

Source Category: Sources subject to Rule 8041 include, but ar e not limited to, building and construction industry, mining industry, sand and gravel industry, food and agr icultural processing industry, mineral processing industry, gla ss and related products industry, chemical industry, landfills, and companies t hat transport bulk materials.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 0 0 0 0 PM2.5 1 TBD TBD TBD TBD TBD TBD TBD SO 2 0 0 0 0 0 0 0 Tons per day – annual average NOx 0 0 0 0 0 0 0 PM2.5 1 TBD TBD TBD TBD TBD TBD TBD SO 2 0 0 0 0 0 0 0

1 Further study is needed to confirm whether PM2. 5 and PM10 reductions are proportional for this category.

• EIC Affected: EIC for carryout and trackout s ource categories would need to be established.

• The ARB Emissions Inventory database doe s not contain emissions data pertaining to carryout and trackout. Needs to estab lish the baseline emissions for carryout and trackout and update t he ARB database.

Current Control:

• Rule 8041 applies to all sites that ar e subject to Rules 8021, 8031, 8061, 8071 where carryout or trackout has occurred or may occur on paved public roads or paved shoulders of a paved public road.

• In addition to the exemptions provided in Rule 8011, carryout and trackout caused by agricultural sources are also ex empt from complying with Rule 8041.

• Rule 8041 requires operators/owners to su fficiently prevent or cleanup carryout and trackout.

• Prohibits the use of blower devices, or dr y rotary brushes or brooms, for removal of carryout or trackout.

• Requires removal of all visible carryout or trackout at the end of each workday.

• For any site with 150 or more vehicle trip s per day, or 20 or mo re vehicle trips per day by vehicles with 3 or more axles:

• Prevent carryout or trackout by insta lling and maintaining a trackout control device at all access points to paved public roads; orSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-59 Rule 8041 (Continued)

• Utilize a carryout or trackout devic e prevention procedure that has been demonstrated to the satisfaction of the APCO and EPA as achieving equivalent or greater level of cont rol than the device mentioned above.

• If the carryout and trackout device is insu fficient, remove carryout and trackout within 1⁄2 hour of the generation of su ch carryout and trackout.

• Within urban areas, prevent carryout and tr ackout, or immediat ely remove carryout and trackout when it extends 50 feet or mo re from the nearest unpaved surface exit point of the site.

• Within rural areas, construction projects 10 acres or more in size, prevent carryout and trackout, or immediately remove carryout and trackout when it extends 50 feet or more from the nearest unpaved su rface exit point of the site.

• Cleanup of trackout and carryout shoul d be done by manually sweeping and picking up, operating a rotary brush or broom a ccompanied or preceded by wetting to limit VDE to 20% opacity; operati ng a PM10-efficient street sweeper that has a pick-up efficiency of at least 80%, or flushing with water, if curb s or gutters are not present and where the use of water will not result as a s ource of trackout mate rial or result in adverse impacts on storm water drainage systems or violate any NPDES permit program.

• The rule specifies criteria for use of gri zzlies, gravel pads, and paving of surfaces to prevent carryout and trackout.

Future Control Options:

• Eliminate the vehicle trips per day thres hold for requiring installation of control device to prevent trackout and carryout.

• Clearly establish and enforce traffic pattern s to route traffic over selected trackout control devices.

• Limit accessibility to the site by inst alling barriers on unprotec ted routes without trackout control devices.

• Pave roadways as soon as possible in area s where construction activities will occur.

• Decrease the 50 feet of carryout/track out accumulation distance threshold for requiring cleanup of carryout and trackout.

Discussion:

• Fugitive dust generating activities ar e located at stationary sources and area sources for which the District has legal authority to regulate air emissions.

• Stationary sources subject to Regulation VIII rules are required to obtain operating permits. However, most area sources such as construction, demolition, excavation, or other earthmoving activities are not r equired to obtain operating permits from the District. For sources that are not requi red to have operating permits, the District should periodically examine county/city building permits department records to determine the location and durat ion of fugitive dust generating activities so that District inspectors could ensure operat ors are complying with the rules.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-60 Rule 8041 (Continued)

• Enhance the effectiveness of the rules throug h several actions including, but are not limited to, an increased presence of District Compliance Division staff in the field, increased use of Dust Control Plans, in creased compliance assistance, and greater public outreach.

Recommendation:

• See recommendations for Regulation VIII as a whole.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-61 5. Rule 8051 (Open Areas)

Source Category: Sources subject to Rule 8051 include, but ar e not limited to, building and construction industry, mining industry, oil and gas produc tion, sand and gravel industry, food and agricultural processing industry, mineral pr ocessing industry, glass and related products industry, chemical industry, landfills, and gov ernment agencies, industrial manufacturing companies, and transportation companies that have open areas located within their jurisdiction.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 0 0 0 0 PM2.5 4.51 4.42 4.40 4.39 4.37 4.37 4.35 SO 2 0 0 0 0 0 0 0 Tons per day – annual average NOx 0 0 0 0 0 0 0 PM2.5 7.18 7.03 7.00 6.99 6.97 6.94 6.92 SO 2 0 0 0 0 0 0 0

• EIC Affected: 650-650-5400-0000; 650-651-5400- 0000; 650-652-5400-0000.

• The ARB Emissions Inventory database in dicates emissions from windblown dust from non-pasture agricultural lands, pasturelands, and from unpaved roads and associated areas. It appears that the database does not account the emissions from disturbed open areas. Improvement in emissions inventory for open areas is needed.

Current Control:

• Rule 8051 applies to any open area having 0. 5 acres or more within urban areas, or three acres or more within rural areas, and contains at least 1,000 square feet of disturbed surface area.

• Requires operators to impl ement specific control meas ures whenever open areas are disturbed or vehicles are used in open areas to comply with conditions for stabilized surface at all times and to limit VDE to 20% opacity.

• Control measures to limit VDE to 20% opacity include the applic ation of water or dust suppressants to all non-vegetated areas , establishment of vegetation on all previously disturbed areas, or paving, appl ication and maintenance of gravel, or application and maintenance of chemical/organic stabilizers/suppressants.

• If there is evidence of trespass, prevent unauthorized vehicle access by posting No Trespassing signs or installing barriers such as fences, gates, posts, or other appropriate barriers to e ffectively prevent access.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-62 Rule 8051 (Continued)

Future Control Options:

• Fugitive dust generating activities ar e located at stationary sources and area sources for which the District has legal authority to regulate air emissions.

• Change the applicability of the rule so it applies to any open area 0.10 acre or larger and have a cumulative of 500 s quare feet of disturbed area.

• Implement similar control requirements and reporting prov isions for open areas as specified in Maricopa County APCD Regulati on III Rule 310.01 (Fugitive Dust from Open Areas, Vacant Lots, Unpaved Park ing Lots, and Unpaved Roadways).

• Stationary sources subject to Regulation VIII rules are required to obtain operating permits. However, most area sources such as construction, demolition, excavation, or other earthmoving activities are not r equired to obtain operatin g permits from the District. For sources that are not requi red to have operating permits, the District should periodically examine county/city building permits department records to determine the location and durat ion of fugitive dust generating activities so that District inspectors could ensure operat ors are complying with the rules.

• Develop an outreach progr am requiring property ow ners/operators to report information on the size of their open areas to the District along with the submission of a Dust Control Plan listing the control m easures that would be implemented if their property is subject to Rule 8051.

• Enhance the effectiveness of the rules throug h several actions including, but are not limited to, an increased presence of District Compliance Division staff in the field, increased use of Dust Control Plans, in creased compliance assistance, and greater public outreach.

Recommendation:

• See recommendations for Regulation VIII as a whole.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-63 6. Rule 8061 (Paved and Unpaved Roads)

Source Category: Sources subject to Rule 8061 include, but are not limited to, city, county, and state agencies, mining industry, oil and gas producti on, sand and gravel industry, agriculture industry, mineral processing industry, landf ills, and manufacturing companies that have paved and unpaved roads located within their jurisdiction.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls. Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 0 0 0 0 PM2.5 1 8.18 8.25 8.46 8. 63 8.80 8.98 9.15 SO 2 0 0 0 0 0 0 0 Tons per day – annual average NOx 0 0 0 0 0 0 0 PM2.5 1 9.65 9.70 9.93 10.11 10.30 10.48 10.67 SO 2 0 0 0 0 0 0 0

1 PM2.5 reductions from existing controls have been assumed to be proportional to PM10 reductions.

• EIC Affected: 640-635-5400-0000; 640-637-5400- 0000; 640-639-5400-000; 640-641-5400-0000; 640-643-540 0-0000; 645-638-5400-0000; 645-640-5400-0000; 645-644-5400-0000; 645-646-5400-0000

Current Control:

• Applicability: Rule 8061 applies to any new or existing public or private paved or unpaved roads, road construction projects , or road modification projects.

• Exemption: In addition to the exempt ions provided in Rule 8011, Rule 8061 exempts the following:

o Unpaved road segment with less than 26 annual average daily vehicle trips (AADT).

o Maintenance and resurfaci ng of existing paved road.

o Agricultural sources subject to Rule 8081.

o Emergency activities performed to ensure public health and safety.

o Equipment used to remove debris beyond t he capabilities of PM10-efficient street sweepers.

• Paved Roads: The rule includes the following requirements:

o New or modified paved roads must be constructed in accordance with the standards established by the Americ an Association of State Highway and Transportation guidelines for width of s houlders and for medians shoulders. The minimum paved or stabilized shoul der widths based on annual average daily vehicle trips are specified in the rule.

o Curbing adjacent to and contiguous with the travel lanes or paved shoulder of roads mat be constructed in lieu of the required shoulder width standards.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-64 Rule 8061 (Continued)

• Mud/dirt Cleanup Requirements:

o Use of PM10-efficient street sweeper s and conducting routine street sweeping operations of paved roads not less than once per month.

o Remove any accumulated mud/dirt of at least one-inch thickness over an area of at least 50 square feet on road surf ace travel lanes resulting from wind/storm/water erosion and runoff withi n 24 hours of discovery of such

o condition.

o Allows an extension to cleanup period if unsafe travel conditions exist, but requires notification to the District and approval by APCO.

o Dust minimization practices must be followed during removal of mud/dirt.

• Unpaved Roads:

o Limit VDE to 20% opacity on any unpaved road segment with 26 or more AADT and comply with the requirements of a stabilized unpaved road by applying chemical/organic dust stabilizers/suppre ssants, watering, paving, installing roadmix or uniform layer of washed gr avel, or other equivalent methods approved by the APCO.

o Construction of new unpaved road in ur ban areas except for temporary unpaved roads that meets the conditi ons specified in Rule 8011.

o Each city, county, or state agency with primary responsibility for any existing unpaved roads within rural and urban areas must pave an average of 20% annually of all unpaved roads within their jurisdiction by 1/1/2010 (priority must be given to unpaved roads with the highest AADT. Annual reports (April 1 of each year) must be to the District on the total number and percent of unpaved road miles that have been paved during the previous calendar year.

• Existing Paved Public Roads with Unpav ed Shoulders in Urban and Rural Areas:

o Each city, county, or state agency must: - Provide a list to the District of a ll existing paved public roads with unpaved shoulders. - In urban areas, pave or stabilize 4-foot shoulders on 50% of existing paved public roads with the hi ghest AADT by 1/1/10. - In rural areas, pave or stabilize 4-f oot shoulders on 25% of existing paved public roads with the hi ghest AADT by 1/1/10. - If the requirements above could not be met due to budgetary constraints, submit statement of financ ial hardship to the District for approval of the APCO and EPA. - Establishment and Posting of speed Limits on Unpaved Roads: - Establish a maximum speed limit of 25 mph on each unpav ed road with 26 AADT and post speed limit signs one in eac h direction, per mile of unpaved road segment in urban areas, and per tw o miles of unpaved road segment in rural areas.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-65 Rule 8061 (Continued)

Future Control Options: Evaluate the feasibility and cost effectiveness of requiring all unpaved shoulders on paved roads to be paved. Incentivize the paving of unpaved shoulders to assist city and county agencies that are financially constrained.

Discussion:

• District has legal authority to regulate ai r emissions from sources subject to Rule 8061.

• District staff should evaluate the compliance status of each city, county, and state agencies to determine the effectiveness of existing rule requirements.

• Based on overall compliance status, Distric t staff needs to reevaluate the emissions data for this source category and update the emissions inventory database, preferably on an annual basis.

• Currently, the rule only requires submission of required reports by city, county, and state agencies, but does not mention federal agencies (e.g., U.S. Forest and Parks, Bureau of Land Management, etc.), which also have unpaved roads within their jurisdiction. Information on total num ber and miles of unpaved roads and associated AADT from responsible federal agencies res ponsible within the San Joaquin Valley are necessary to establish more accurate emissions inventory.

• Enhance the effectiveness of the rule through several actions including, but are not limited to, an increased presence of District Compliance Division staff in the field, increased use of Dust Control Plans, in creased compliance assistance, and greater public outreach.

Recommendation: See recommendations for Regulation VIII as a whole.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-66 7. Rule 8071 (Unpaved Vehicle and Equipment Traffic Areas)

Source Category: Sources subject to Rule 8071 include, but ar e not limited to, building and construction industry, city, county, and state agencies, mi ning industry, oil and gas production, sand and gravel industry, food and agriculture processing industry, mineral processing industry, landfills, and industrial and m anufacturing companies that have unpaved vehicle and equipment traffic areas.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 0 0 0 0 PM2.5 0.58 0.57 0.57 0.57 0.57 0.57 0.57 SO 2 0 0 0 0 0 0 0 Tons per day – annual average NOx 0 0 0 0 0 0 0 PM2.5 0.57 0.56 0.56 0.56 0.56 0.56 0.56 SO 2 0 0 0 0 0 0 0

• EIC Affected: 645-645-5400-0000; 645-647-5400-0000

• The ARB Emissions Inventory database does not contain emissions data on unpaved vehicle and equipment traffic areas. Needs to establish the baseline emissions for this source and update the ARB database.

Current Control:

• Applicability: Rule 8071 applies to any unpaved vehicle and equipment traffic area.

• Exemption: In addition to the exempt ions provided in Rule 8011, Rule 8061 exempts the following:

o Unpaved vehicle and equipment traffic areas with less than 50 annual average daily vehicle trips (AADT).

o Agricultural sources subject to Rule 8081.

• Requirements:

o Limit VDE to 20% opacity and stabilize unpaved road by the application of at least one of the following control measures: - Watering - Uniform layer of washed gravel - Chemical/organic dust stabilizers/suppressants - Vegetative materials - Paving or roadmix - Other APCO-approved methods that effect ively limits VDE to 20% opacity.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-67 Rule 8071 (Continued)

o In lieu of complying with the above requirements, implement an APCO-approved Fugitive PM10 Management Plan as specified in rule 8011.

o Areas with 150 vehicle daily trips (V DT), or 150 VDT that are utilized intermittently for 30 days or less during a calendar year, implement the control measures indicated above when the unpaved areas are utilized.

o Each day that 25 or more VDT with 3 or more axles will occur on unpaved area, limit VDE to 20% opacity, comply with t he requirement for stabilized surface and implement the above control measures.

o Each day when special event will result in 1,000 or more vehicles will travel/park on unpaved area, notify the District at l east 48 hours in advance of the special event and during the duration of the event limit VDE to 20% opacity, comply with the requirements for stabilized surf ace, and apply/reapply water or chemical/organic dust suppressants.

o On each day 50 or more VDT, or 25 or more VDT with 3 or more axles, originates from within and remain s exclusively within an unpaved areas apply/reapply water to limit VDE to 20% opacity.

Future Control Options:

• Establish a database of the total number of unpaved vehicle and equipment traffic areas and calculate the emissions asso ciated with this source category.

• Evaluate the feasibility of paving vehi cle and equipment traffi c areas that are frequently and regularly used on a daily basis.

Discussion:

• District has legal authority to regulat e air emissions from these sources.

• District staff should evaluate the complianc e status of source owners/operators to determine the effectiveness of existing rule requirements.

• Based on overall compliance status, Distric t staff needs to reevaluate the emissions data for this source category and update the emissions inventory database, preferably on an annual basis.

• Enhance the effectiveness of the rule through several actions including, but are not limited to, an increased presence of District Compliance Division staff in the field, increased use of Dust Control Plans, in creased compliance assistance, and greater public outreach.

Recommendation:

• See recommendations for Regulation VIII as a whole.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-68 8. Rule 8081 (Agricultural Sources)

Source Category: Sources subject to Rule 8081 are agric ulture industry (farming and livestock husbandry).

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0 0 0 0 0 0 0 PM2.5 13.22 13.60 13.69 13.82 13.95 14.08 14.21 SO 2 0 0 0 0 0 0 0 Tons per day – annual average NOx 0 0 0 0 0 0 0 PM2.5 14.79 15.15 15.23 15.36 15.48 15.60 15.73 SO 2 0 0 0 0 0 0 0

• EIC Affected: 620-614-5400-0000; 620-615-5400- 0000; 620-618-0262-0101; 620-618-0262-0102; 620- 618-0262-0103; 620-618- 0262-0104; 620-618-0262-0105; 620-618-0262-0106; 620-618-026 2-0107; 620-618-0262-0108; 620-618-0262-0109; 620-618-0262-0110

Current Control:

• Applicability: Rule 8071 applies to off-field agricultural sources.

• Exemption: In addition to the exempt ions provided in Rule 8011, Rule 8061 exempts the following:

o On-field agricultural sources

o Off-field agricultural sources necessary to minimize or respond to adverse effects on agricultural crops during freezing temperatures.

o Outdoor storage, handling, or transport of bulk materials which would be damaged by wetting with water or chemic al/organic dust suppressants if the operator could demonstrate t hat none of the other contro l measures specified in the rule could be implemented to limit VDE to 20% opacity and provided it is approved by the EPA and APCO.

o Any unpaved road segment with less than 75 VDT. This threshold does not apply to unpaved road segments subj ect to Rule 4550 (Conservation Management Practices). Equipment with loading forks employed in loading and unloading harvested commodities in the har vest location and traveling at 3 miles per hour or less is not in cluded in the VDT counts.

o The felling or removal of trees from fore st lands. However, Regulation VIII rules apply to other timber harvest activities su ch as site preparation of log storage and staging areas.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-69 Rule 8081 (Continued)

o Outdoor storage of bulk materials at a si ngle site where no material is actively added or removed and where the total ma terial stored is less than 100 cubic yards.

o Any unpaved vehicle and equipment parking and traffic area less than 1.0 acre and more than one mile from an urban area, or with less than 50 AADT, or less than 150 VDT that are utilized intermittently for a period of 30 days or less in a calendar year.

o Transport of bulk material in an outdoor ar ea for a distance of 12 feet or less.

• Requirements:

o The requirements of Rule 8061 regarding the construction standards for shoulder width and medians apply when construc ting new or modifying existing paved roads.

o Except as specifically exempted by Rule 8081, owner s/operators must comply with similar requirements for storage, handling and transport of bulk materials specified in Rule 8031.

o For unpaved road segments, on each day that 75 or more VDT, or 25 or more VDT with 3 or more axles will occur, lim it VDE to 20% opacity and comply with the requirements for stabilized surface by application of at least one of the following: - Watering - Uniform layer of washed gravel - Chemical/organic dust suppressants - Vegetative materials - Paving or roadmix - Other methods that effectively limit s VDE to 20% opacity and is approved by the APCO.

o Unpaved vehicle/equipment parking and traffic areas: - For 50 or more AADT that will occu r on unpaved vehicle/equipment traffic area, limit VDE to 20 % opacity and comply with the requirements of a stabilized unpaved road by the applicati on of the control measures mentioned above. - For 150 or more VDT, or 150 or more VDT that are utilized intermittently for a period of 30 days or less during the calendar year, implement control measures mentioned above. - On each day that 25 or more VDT with 3 or more axles will occur, limit VDE to 20% opacity and comply with the require ments for stabilized surface by the application of the control measures mentioned above.

o For carryout and trackout, comply with t he requirements of the California Vehicle Code Section 23112-23113 which requires mate rial, including dirt deposited on any public highway or street to be cleaned up.

o As an alternative compliance option, ow ners/operators may impl ement a Fugitive PM10 Management Plan (FPM P) that achieves 50% efficiency andSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-70 Rule 8081 (Continued)

approved by the Fresno Regional Office of the U.S. Department of Agriculture Natural Resource Conservation Service based on criteria established by the APCO. The rule includes provisions outlining the subm ission and approval process for FPMP, including the information that must be included in the FPMP.

Future Control Options:

• Evaluate the appropriateness of continuing the exempti on for bulk material storage of less than 100 cubic yards at a single loca tion where no material is actively added or removed. Bulk material storage pile is susceptible to windblo wn emissions if left exposed (without cover such as tarp) especially during high wind conditions.

• Reevaluate existing exemption of on-fiel d agricultural sources in conjunction with current requirements of Rule 455 0 (Conservation Management Plan).

• Consider establishing sim ilar appropriate control r equirements for carryout and trackout as specified in Rule 8081 in stead current requirem ents to comply the requirements under the California V ehicle Code sections 23112-23113.

Discussion:

• District has legal authority to regulate ai r emissions from sources subject to Rule 8081.

• District staff should evaluate the complianc e status of source owners/operators to determine the effectiveness of existing rule requirements.

• Based on overall compliance status, Distric t staff needs to reevaluate the emissions data for this source category and update the emissions inventory database, preferably on an annual basis.

• Enhance the effectiveness of the rule through several actions including, but are not limited to, an increased presence of District Compliance Division staff in the field, increased use of Dust Control Plans, in creased compliance assistance, and greater public outreach.

Recommendation:

• See recommendations for Regulation VIII as a whole.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-71 

### Flares (S-IND-21) (Oil & Gas Production – Combustion, Sewage Treatment, Landfills, Incinerators, Oil & Gas Production, Petroleum Refining)

Source Category: This source category includes any oper ation involving the use of flares.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 0.33 0.33 0.33 0.33 0.34 0.34 0.34 PM2.5 0.01 0.01 0.01 0.01 0.01 0.01 0.01 SO 2 0.60 0.63 0.63 0. 63 0.64 0.64 0.64 Tons per day – annual average NOx 0.33 0.33 0.33 0.33 0.34 0.34 0.34 PM2.5 0.01 0.01 0.01 0.01 0.01 0.01 0.01 SO 2 0.60 0.63 0.63 0. 63 0.64 0.64 0.64

• EIC Affected: 110-132-0130; 120-132-0136; 130-132-0110; 130-132-0136; 310-320-0110; 310-320-0120; 310- 320-0130; 320-320-0010; 320-320-0130

• The current emissions inventory will be validated to ensure it accounts for the emissions generated during em ergency flaring events. Current NOx emissions appear to be low and may have only account ed for the emissions generated by the gas fuel used by the flare pilot flame.

• Usage records will be used to determine the tota l amount of gases sent to the flare during normal operation and process equipm ent upset or breakdown periods. Thereafter, the emissions will be calc ulated and the emissi ons inventory will be updated.

Current Control:

• District Rule 4311 addresses operations invo lving the use of a flare. Specific requirements include: pilot flame devices, automatic ignition systems, heat-sensing devices, use of purge gases, applicable pr ovisions of 40CFR60.18, and emission standards for ground-level enclosed flares.

Future Control Options:

• Operators could be required to prepare and submit a Flare Minimization Plan (FMP) to reduce emissions from flaring includ ing installing vapor recovery systems; increasing the vapor recovery system capac ity; increasing the fuel gas treating capacity; more rigorous monitoring and reporting requirement s; and improving operational and maintenance procedures to prevent upset conditions.

• Control devices for NOx, PM2.5 and SO x emissions from flares should be considered.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-72 Flares (Continued)

Discussion:

• The BAAQMD and SCAQMD have require d operators to prepare FMP which resulted in data being gathered on strategies that can be used in reducing flaring events.

• The South Coast rule has provisions explic itly prohibiting flaring in some instances and a reporting requirement for flare emissions that spread over 100,000 cubic feet.

• During the last amendment of Rule 4311, an FMP not required since the districts that incorporated this requirement were unable to explicitly state the expected emission reduction potential and control m easure options of this strategy.

Recommendation:

• Evaluate the effect of FMP and relat ed information that other districts have implemented. Amend District Rule 4311 to in corporate requirements that will result in reduced flaring events.

• Consider control devices for NOx, PM2.5 and SOx emissions from flares.

Projected Reductions: Emission reductions will be calcul ated during the rule project, but are not quantifiable at this time.

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx TBD TBD TBD TBD TBD TBD PM2.5 TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBD Tons per day – annual average NOx TBD TBD TBD TBD TBD TBD PM2.5 TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBDSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-73 

### Indirect Source Review (ISR) Enhancement (M-OTH-8) (Light and medium duty vehicles, heavy-dut y vehicles, and off-road equipment)

Source Category: In terms of NOx reductions, ISR impacts thr ee main source categories: (1) Vehicles used for commuting to and from a development project after its completion; (2) Heavyduty vehicles such as trash haulers; and (3) Off-road equipment, including street sweepers; small off-road engines such as lawn equipment using IC engines-mowers, edgers, and leaf blowers; and hea vy-construction machinery.

Emissions Inventory: The baseline inventory for ISR is in the three source category groups mentioned above and is included in the ARB m obile source inventories.

Current Control: The Indirect Source Rule, Rule 9510, is designed to mitigate emissions associated with development projects that exce ed two tons per year of NO x and PM10. Specifically, for the construction phase of a development project, Rule 9510 requires a 20% NOx reduction from the statewide av erage resulting from the use of construction equipment that is greater than 50 horsepower. For the operational emissions, defined as the combination of the area and mobile emissions associated with the project, Rule 9510 requires 33% NOx reduction fr om the operational baseline, as computed using an APCO-approved model, e.g. URBEMIS. Both s ources of NOx reductions can be met by implementing on-site emission re duction measures or by paym ent of off-site mitigation fees to the District.

VOC reductions are not part of the mitigation requirement s of Rule 9510, since the effects of VOC emissions have been deemed as in significant in the formation of PM2.5. However, ozone formation involves both VO C and NOx. Therefore, VOC emissions associated with development pr ojects and its reduction through mitigation measures are now an integral part when considering Rule 9510 as a current ozone control mechanism.

Future Control Options: A feasibility study will eval uate the potential of suggestions received during the development of the 2007 Ozone Plan :

• Increase the required reduction from the us e of construction equipment greater than 50 horsepower from 20% to 50% NOx r eduction from the statewide average.

• Increase the required reduction from the operational baseline from 33% to 50% NOx reduction.

• Add VOC (an ozone precursor) reducti on as a mitigation requirement.

Discussion:

• The 20% reduction from the statewide average for construction emissions was based on the assumption that it was sufficient from the point of controlling emissions in order for the District to meet its one-hour ozone plan requirements.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-74 Indirect Source Review (ISR) Enhancement (Continued)

• The 33% operational baseline emission reduction for NOx was based on the assumption that mobile source emissions will come down by 50% over 10 years due to improved tailpipe emissions. Instead of mitigating 100% of the remaining emissions, after deducting the emission redu ction attributable to ARB’s tailpipe control, Rule 9510 required only 33% mitigati on. This method was used in order to assure that development projects do not over-mitigate its emissions.

• The potential NOx emission reduction from increasing the mitigation requirements from 33% to 50% reduction of the operationa l baseline emissions is approximately 2 tons per day.

• A future reevaluation of Rule 9510 shoul d include analysis of VO C emissions and its reduction through mitigat ion requirements.

Recommendation:

• At this point, the District is exploring a ll possibilities of gaining emission reductions from sources under its jurisdiction. Legal limitations in state law are also being examined.

• The District invites comments and suggesti ons to further improve control options, within legal limitations set by state law.

• A future feasibility study to re-evaluate this source category is planned. See the 2007 Ozone Plan, Chapter 8, Innovat ive Strategies and Program s, for any additional information on this source category.

Projected Reductions: Emission reductions will be calculated bas ed on the information derived from the Feasibility Study, but are not quantifiable at this time.

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQ Tons per day – annual average NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-75 

### Healthy Air Living (M-OTH-1) (Lawn-care equipment, architectural coat ings and solvents, asphalt paving and roofing operations, barbecue cooking, off-road construction machinery, recreational vehicles and watercrafts , household aerosols, single occupancy vehicle travel and othe r stationary sources)

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx NQ NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQ NQ Tons per day – annual average NOx NQ NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQ NQ

Current Control: Public service announcements which encour age residents and employees to curtail activities that cause air pollution; par tnerships with 700 public and private entities enable workers to participate in Spare-The-Air (STA) day activities, including receiving rewards and recognition; various outreach pr ograms, including: cl ean yard machines trade-ins, air quality school curriculums, and public forums.

Future Control Options:

• Recruit more public agencies, private companies and members of the public as clean air partners; add additional program s, including assisting businesses and public agencies in establishing alternativ e transportation programs, telecommuting programs, voluntary episodic operation curtailments, emi ssions reduction potential analysis, and emissions footprints.

• Additionally emphasize trip reduction progr ams, idling curtailments, low emissions yard care equipment throughout the thr ee month Ozone season with an intense focus on behavior change over heightened promotional awareness week.

• Voluntary no-sell policy of VOC-emitting products, such as paints and solvents.

• Curtailment of recreational activities, such as off-road motorcycling and motorized watercraft use throughout the Ozone season.

• Postpone the use of heavy construction machinery, such as bulldozers, levelers, and pavers, to days that are le ss conducive to ozone formation.

• Postpone nonessential activities in stationar y sources, such as structural repairs, maintenance, or painting, which result in emissions of NOx and VOC to days that are less conducive to ozone formation.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-76 Healthy Air Living (Continued) Discussion:

• The District’s in-house approach to encourag ing employees to curtail activities during past Spare the Air days is a good model for other public and private entities to follow. District employees take part in activi ties, such as: (1) Staying in for lunch, (2) Carpooling for lunch, (3) Carpooling and trip linking with fe llow employees for lunchtime errands, and (4) Stepped-up efforts to use alternative transportation to and from work. The District’s public education unit, which awards prizes to outstanding participants, coor dinates these efforts.

• The District’s alternative transportation program gets 40% parti cipation, wherein employees taking part use alternative transpor tation for three days out of a five-day workweek (60%) and get rewarded $50 for a two-week pay period. This 40% participation is approximately 16% higher t han the general working population’s use of alternative transportation (US Census 2000).

• Free transit rides, as done in the Bay Area during their Spare the Air days, have increased ridership in buses and trains. Ho wever, these free rides have relatively very high costs in reducing vehicle miles traveled (VMT), compared to other programs that reduce VMT.

• Curtailment of activities that contri bute to ozone formation will be on a voluntary basis, since the District does not have t he authority to impose an outright ban on these activities. Local government entit ies are empowered by state law to limit certain activities, as has been done by ci ties in limiting usage of lawn equipment, such as leaf blowers.

Recommendation:

• Expand the District’s current Spare the Air programs with the following improvements:

o Assist public and private agencies to assess, organize, implement and evaluate alternative transportation programs and emissions reduction protocols and projects.

o Promote voluntary curtailment of activities that produce NOx and VOC.

o Write model ordinances that prevent NOx and VOC emissions by restricting certain activities, such as use of recr eational vehicles and watercraft, lawnmaintenance equipment, drive-thorough, et c. Promote the adoption of these ordinances by cities and counties, with the District providing technical and scientific assistance in subjec ts pertaining to air quality.

o Explore ways to incentivize the voluntar y participation of st ationary sources in curtailing activities that contribute to ozone formation.

o As a form of voluntary and emergi ng measures for which EPA has provided guidelines for SIP credits, design Heal thy Air Living projects so that EPA criteria for SIP accr editation are fulfilled.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-77 Healthy Air Living (Continued)

Projected Reductions: Emission reductions will be calculated bas ed on the information derived from the Feasibility Study, but are not quantifiable at this time.

Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQ Tons per day – annual average NOx NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-78 

### Fireworks and Pyrotechnic Displays (M-OTH-10) (Fireworks, pyrotechnic displays, and use of consumer fireworks)

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx TBD TBD TBD TBD TBD TBD TBD PM2.5 TBD TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBD TBD Tons per day – annual average NOx TBD TBD TBD TBD TBD TBD TBD PM2.5 TBD TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBD TBD

• EIC Affected: There is no known inventory fo r emissions caused by the use of fireworks and pyrotechnic displays in the Valley. The inventory will be revised as part of the further study.

Current Control:

• Some counties and municipal ities limit the time and pl ace of use, as well as regulating the type of fireworks t hat may be sold to the public.

• Where allowed by local ordinances, fire works emissions are gener ally uncontrolled.

• The U.S. Consumer Product Safety Co mmission (CPSC) regulates consumer fireworks as part of its mission to protect the public from unreasona ble risk of serious injury or death from cons umer products. Its regulat ions contain construction, performance, amount and composition of pyro technic (powder) material present in the fireworks devices, and labeling requirem ents for consumer fi reworks. OSHA regulates the working conditions relating to the manufacture of explosives and including pyrotechnics (commonly called fireworks). However, CPSC and OSHA regulations do not address emissions of air pollutants.

• Some facilities, such as California t heme parks, may use pneumatic launchers to decrease emissions from propellant charges.

Future Control Options:

• Cities and municipalities coul d pass ordinances that limit or prohibit the use of fireworks during periods of unhealthy air quality.

• The District could adopt regulations that re quire facilities to use pneumatic launchers and other abatement measures to reduce emissions from fireworks and pyrotechnic displays.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-79 Fireworks and Pyrotechnic Displays (Continued)

Discussion:

• Large fireworks displays, in combinati on with other sources, can in some circumstances be potentially significant source s of air pollutant emissions. For this reason, reasonable precautions are taken to minimize exposures to emissions from fireworks displays. Such precautions incl ude alerting the public to the potential for short-term air quality impacts that may result from the discharge of fireworks at large displays.

• The District considers the use of firewor ks displays to be integral to significant, traditional July 4 events. Air quality data as sociated with July 4 events is flagged to be excluded, similar to exc eptional events under section 319 of the Clean Air Act.

Recommendation:

• The District will explore all possibilities of gaining emission reductions from sources under its jurisdiction. Legal limitations in state law are also being examined.

• The District invites comments and suggesti ons to further improve control options, within legal limitations set by state law.

• A feasibility study to evaluate th is source category is planned.

Projected Reductions: Emission reductions will be calculated bas ed on the information derived from the Feasibility Study, but are not quantifiable at this time.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx NQ NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQ NQ Tons per day – annual average NOx NQ NQ NQ NQ NQ NQ NQ PM2.5 NQ NQ NQ NQ NQ NQ NQ SO 2 NQ NQ NQ NQ NQ NQ NQSan Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-80 

### Employer-based Trip Reduction Programs (M-TRAN-1) Light-Duty Passenger (LDA), Light Duty Trucks-1 (LDT1), Light Duty Trucks-2 (LDT2), Medium-Duty Trucks (MDV), and Motorcycles.

Source Category: Van Pools, Carpools, Public Transit Use, Employer-based Alternative Transportation Programs, and Other Commute Options to Reduce Vehicle Miles Traveled.

Emissions Inventory: Data reflects current controls and regulations, but does not include any reductions from proposed controls.

Pollutant 2005 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx 3.78 2.74 2.57 2.36 2.17 1.99 1.83 PM2.5 0.11 0.12 0.13 0.13 0.13 0.14 0.14

SO2 0.02 0.020 0.02 0.02 0.02 0.02 0.02 Tons per day – annual average NOx 3.50 2.54 2.60 2.19 2.01 1.84 1.69 PM2.5 0.11 0.12 0.13 0.13 0.14 0.14 0.14

SO2 0.02 0.02 0.02 0.02 0.02 0.02 0.02

• EIC Affected: 710-XXX-XXXX (LDA); 722- XXX-XXXX (LDT1); 723-XXX-XXXX (LDT2); 724-XXX-XXXX (MD V); 750-XXX-XXXX (MCY) The above baseline emission inventory reflec ts the emissions for vehicles involved in commuting to work at employers of over 100 employees.

Current Control: The Metropolitan Planning Organ izations in the San Joaquin Valley have been very proactive in encouraging ride sharing. A nd while some municipalities have had incredible success, the efforts still remain vol untary in nature and limited in scope. Trip reduction programs have the potent ial to achieve significant reductions in vehicle miles traveled (VMT).

Future Control Options:

• Organize and use incentives to achieve mo re participation, both private and public, in trip reduction programs.

• Emphasize trip reduction programs using t he previous Spare The Air Program (STA) and the new Healthy Air Living initiative by increasing public awareness campaigns. The District currently has more than 700 pr ivate and public Spare the Air Employer Partners from Stockton to Ar vin, who demonstrate their commitment to improving air quality by their implementation of VMT reduction activities.

• Adopt a rule requiring employe r-based trip reduction programs.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-81 Employer-based Trip Reduction Programs (Continued) Discussion:

• Single-occupancy vehicle trips to work si tes contribute significantly to traffic congestion, emissions of direct PM2.5 and its associated precursors.

• The number of vehicle miles traveled in the SJV is growing at a rate 21⁄2 times greater than the rate of population growth.

• District Rule 9001 (Commuter-based Trip Reduction) was adopted on January 20, 1994. It was repealed on February 15, 1996 with the passage of state Senate Bill 437, which prohibited mandat ory employer-based trip reduction programs.

• On February 21, 2003, in response to Senate Bill 709 (Flores), an act was added to Chapter 5.7 (commencing with Section 40600) to Part 3 of Div ision 26 of the Health and Safety Code, to add Section 9205. 16 to the Vehicle Code, and to repeal Section 5 of Chapter 915 of the Statues of 1994, relating to air quality. Section 40601(d) allows the District Governing Board to adopt by the earliest feasible date rules and regulations that require all busi nesses employing at least 100 people, as described further by Section 40601(d)(1 & 2), to establish rideshare programs.

• With the anticipated doubling of the Va lley’s population in the next 40 years, reducing commute trips will be essential.

Recommendation:

• Adopt a rule requiring employers (with over 100 employees) to establish employee trip reduction programs.

Projected Reductions: With recommended controls Pollutant 2009 2010 2011 2012 2013 2014 Tons per day – winter season NOx TBD TBD TBD TBD TBD TBD PM2.5 TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBD Tons per day – annual average NOx TBD TBD TBD TBD TBD TBD PM2.5 TBD TBD TBD TBD TBD TBD SO 2 TBD TBD TBD TBD TBD TBD

The District is committed to developing this rule and emissions reduction calculations are undergoing review. The District is ensuring that emissions reductions estimates are consistent with vehicle activity data and current EMFAC2007 model runs. The reductions will be finalized during the rule development process.San Joaquin Valley Unified Air Polluti on Control District April 30, 2008

Appendix I: Candidate Control Measures 2008 PM2.5 Plan Appendix I-82 This page intentionally blank.