2008 PM2.5 Plan 

Appendix I 

 

Candidate Control Measures 
2008 PM2.5 Plan 

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San Joaquin Valley Unified Air Pollution 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 emissions 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 reducing emissions of primary PM2.5 and PM2.5 

precursors. This Appendix presents the product of this process: a master list of all 

candidate control measure ideas identified and evaluated for this plan. After 

assembling Appendix I, the District then screened the candidate measures into several 

categories: high priority measures to be implemented in the years immediately following 

plan adoption; measures that might be implemented in future years to allow for 

expected technology development; and those measures that require further study to 

identify when they could be implemented 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 applicable 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 commitments, as well as expected emissions 

reductions. Chapter 6 also includes the District’s list of feasibility study measures. 

Study measures that point toward possible emission reduction opportunities will be 

included in future plan updates as control measure commitments. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-2 

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San Joaquin Valley Unified Air Pollution 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 Heaters >5 MM Btu/hr S-COM-1 I-10 

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

Boilers, Steam Generators & Process Heaters > 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 (Regulation VIII) S-IND-10 I-49 

Flares S-IND-21 I-71 

Indirect Source Review (ISR) 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-80 
San Joaquin Valley Unified Air Pollution 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 

SO2 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 

SO2 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 material that can be burned 

and restricts when such burning can occur. The rule provides exemptions for fires that 

serve a ceremonial purpose, and when the District determines there would be an 

imminent and substantial economic loss if burning 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 economically 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 agricultural industry stakeholders to identify 

feasible alternative methods to burning agricultural waste. 

• District staff will conduct a feasibility study on biomass incentives for fourth quarter 

of 2008. 

• Staff will address the burn prohibition requirements of California State Senate Bill 

705 (SB 705) according to the schedule detailed below. 
San Joaquin Valley Unified Air Pollution 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 regulate 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 Safety 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 agricultural 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 Weed Abatement (June 1, 2006) 

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

o Phase IV: Other Materials, 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, 2005,and 2007, respectively. The next 

rulemaking project in 2010 will focus on Phase IV - the prohibition on the burning of 

Other Materials, Vineyard Removals, and Prunings from Surface-Harvested Crops. 

In addition, the postponement until 2010 for certain 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 prohibition commencement dates set forth in the 

CH&SC but cannot provide a permanent allowance 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 facilities in the San Joaquin Valley or the 

development of alternatives to burning. 

o The District determines that the continued issuance of permits for that specific 

category or crop will not cause, or substantially contribute to a violation of an 

applicable federal ambient air quality standard. 

o The California Air Resources Board concurs with the District’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 provided funding sources are available. 
San Joaquin Valley Unified Air Pollution 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 economic limitations of the alternatives 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 

SO2 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 

SO2 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 indicated reductions include those resulting from both the completed June 

2007 Phase III rule making and the proposed June 2010 Phase IV rule making. 
San Joaquin Valley Unified Air Pollution 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 

SO2 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 

SO2 0 0 0 0 0 0 0 

• EIC Affected: The source category shares EIC inventory with Rule 8081, which 

covers off-field farming operations. The emission inventory for the operations in this 

control measure will be evaluated during 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 method of Conservation Management Practice 

(CMP) for each of the applicable CMP categories 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 Preparation/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 Vehicle/Equipment Traffic Areas 

o Dairy Operations – Corral/Manure Handling 

o Dairy Operations – Overall Management/Feeding 

Conservation Management Practices 
San Joaquin Valley Unified Air Pollution 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 Vehicle/Equipment Traffic Areas 

o Feedlot Operations – Pens/Manure Handling 

o Feedlot Operations – Overall Management/Feeding 

o Feedlot Operations – Unpaved Roads 

o Feedlot Operations – Unpaved Vehicle/Equipment Traffic Areas 

The list of CMP (published in a handbook) is quite 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 the 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 pesticide use and emissions from stationary 

agricultural internal combustion engines; and 

o Alternative practices to agricultural waste burning. 

• Growers and producers that are subject to the unpaved road and unpaved 

equipment traffic area provisions of Rule 8081 (Agricultural 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 chickens (except layers), and 55,000 

turkeys 

o Animal feeding operations, other than for 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 3,000 feet or more above mean sea level. 

o Agricultural operation parcel used for propagating young trees, shrubs or other 

crops for transplanting and exhibiting plants inside a building, providing grazing 

rangeland or pasture, and forestry. 

Control Options: 

• Lower the current exemption thresholds for agricultural operation sites, number of 

cows, cattle, chickens, and turkeys. Evaluate feasibility of applying similar 

thresholds specified in Rule 4570 (Confined Animal Feeding Operation) 

• Remove the existing exemption category for certain Animal Feeding Operations. 

• Increase the number of required CMP for each applicable CMP categories. 
San Joaquin Valley Unified Air Pollution 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 stationary sources for which the District has 

legal authority to regulate air emissions. 

• A variety of studies have been conducted which 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 the PM2.5 fraction is required to develop a more accurate 

emissions inventory for the various 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 significant source of PM2.5, 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 necessary to determine feasible, cost-effective 

control measures, should they be necessary. 

Recommendation: 

While PM10 emissions and controls for this category are well established, 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 representative emissions inventory. If that 

inventory appears to be significantly large and contribute to the non-attainment problem, 

staff would then examine control effectiveness for PM2.5 reduction strategies that could 

be used to reduce the PM2.5 inventory. 

Projected Reductions: 

Emission reductions will be calculated based 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 

SO2 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 

SO2 0 0 0 0 0 0 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-10 

Boilers, Steam Generators, and Process Heaters >5 MMBtu/hr (S-COM-1) 

(Electrical Utilities, Cogeneration, Oil & Gas Production – Combustion, Petroleum 

Refining – Combustion, Manufacturing & Industrial, Food & Ag Processing, Service 

& Commercial) 

Source Category: 

This source category includes a wide range of industries including 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 

SO2 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 

SO2 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 measure 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 Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-11 

Boilers, Steam Generators, and Process Heaters, >5 MMBtu/hr 

(Continued) 

Future Control Options: 

• Lower NOx limits are achievable by using selective catalytic reduction (SCR) or 

selective non-catalytic reduction (SNCR). Both technologies reduce NOx by 

injecting ammonia to the exhaust gas to convert NOx to elemental nitrogen and 

oxygen. 

• Ultra Low NOx burner technology at this time is technologically capable of achieving 

9 ppmv NOx, with some burners achieving 6 ppmv or lower. 

• Low temperature oxidation may be technologically 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 operated by various types of 

industry in the District. Emissions reduction could be achieved by lowering the 

current emission limits based on burner replacement of exhaust control system 

retrofits. 

• Lowering the current NOx limit of 9 ppmv to 5 ppmv for units greater than 20 

MMBtu/hr would result to about 44% reduction from current baseline emissions for 

units in this size category. The 5 ppmv limit is achievable by retrofitting existing 

units with selective catalytic reduction technology (SCR). In fact, about 12 units in 

the District have been operating SCR and source testing results show that the 5 

ppmv limit can be met. Data also shows that some units operating Ultra Low NOx 

Burner with flue gas recirculation could 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 useful life expectancy, may not be economical 

able to retrofit with SCR and it may be more cost 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 combustion equipment. A few 

steam generators operating in crude oil production facilities in the District fire on 

mixture of natural gas, field gas, and vapor recovery gas with SO2 scrubbers or 

desulfurization equipment. However, most permitted units are firing on natural gas 

or back-up distillate oil fuel without PM2.5 or SO2 control devices.
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-12 

Boilers, Steam Generators, and Process Heaters >5 MMBtu/hr 

(Continued)

• PM control devices such as baghouse, electrostatic precipitators, and scrubbers are 

available, but they have not yet been demonstrated 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 SO2. 

AP-42 indicates that the uncontrolled total PM (condensable and filterable) is 0.007 

pound per million Btu and uncontrolled SO2 is 0.0006 pound per million Btu for 

natural gas-fired boilers. The PM and SO2 emissions are less than 4% and 0.3%, 

respectively, of the AP-42 uncontrolled 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 amendments would be to lower the existing NOx 

limits and establish PM and SO2 standards. 

• Physical space where the units are located is often limited and could impede 

installation of NOx, PM and SO2 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 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 considered 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 SO2 could be achieved by requiring units to be fired exclusively 

on PUC-quality natural gas, propane, or liquefied petroleum gas (LPG), except firing 

on liquid fuel would be allowed only during PUC-quality natural gas curtailment 

periods, provided the sulfur content of liquid fuel does not exceed 15 ppm. 

Gaseous fuel other than specified above could be used provided the exhaust gas is 

controlled by a SO2 and PM10 emission control system. Staff estimates about 38% of 

existing permitted units are currently 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 exclusively with PUC-quality 

natural gas. 

• Staff will consider inclusion of an Advanced Emission Control Options to mitigate the 

potentially high cost effectiveness of this control measure for certain units. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-13 

Boilers, Steam Generators, and Process Heaters >5 MMBtu/hr 

(Continued) 

Projected Reductions: 

Calculated reductions assuming the recommended 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 

SO2 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 

SO2 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 permitted units are currently 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 exclusively with PUC-quality natural gas. 
San Joaquin Valley Unified Air Pollution 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 & Industrial, Food & Agricultural Products 

Processing, Service & Commercial, Other – Fuel Combustion) 

Source Category: 

This source category includes a wide range of industries including but not limited to 

medical facilities, educational institutions, office 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 

SO2 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 

SO2 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; 050-995-1500-0000; 052-070-0110-0000; 060-010-0110-0000; 

060-995-0110-0000; 060-995-0120-0000; 060-995-1500-0000; 099-995-0000-0000; 

310-356-0110-0000; 310-995-1600-0000; 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 Rule 4307 requires registration of small 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 inventory for this source category. 

 

Current Control: 

• District Rule 4307 sets NOx limits at 30 ppmv effective in 2009. This is 

approximately 70% NOx control from uncontrolled levels. 

• Natural draft units operating in oil fields or refineries, glycol 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 required 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 Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-15 

Boilers, Steam Generators, 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 operate no more than 5 billion Btu per year. 

(currently undergoing rule amendment development process). 

• Replacing with electric heaters is also an option since almost all facilities are in 

areas connected to existing commercial 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 electricity 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 regulate air emissions units located at stationary 

sources. 

• Except for the school boilers exemption, current Rule 4307 is as stringent as other 

air district rules. 

• Emission control devices such as baghouse, electrostatic precipitators, and 

scrubbers (wet or dry) are commercially available to reduce PM and SO2 emissions. 

Units firing on natural gas, propane, liquefied petroleum gas, or low sulfur diesel 

tend to emit very low levels of PM2.5 and SO2. AP-42 indicates that the 

uncontrolled total PM (condensable and filterable) is 0.007 pound per million Btu and 

uncontrolled SO2 is 0.0006 pound per million Btu for natural gas-fired boilers. The 

PM and SO2 emissions are less than 4% and 0.3%, respectively, of the AP-42 

uncontrolled NOx emission factor of 0.186 pound per million Btu from natural gasfired boilers. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-16 

Boilers, Steam Generators, and Process Heaters, 2 - 5 MMBtu/hr 

(Continued) 

• Physical space where the units are located could be limited and impede installation 

of NOx, PM and SO2 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 undergoing rule development process to implement the control 

measure in the Ozone Plan. The draft 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 adoption of rule amendments by third quarter of 

2008. 

• Due to limited state funding, school districts may need financial assistance to retrofit or 

replace aging equipment. Staff recommends initially 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 SO2 can be achieved by specifying that be units be fired 

exclusively on PUC-quality natural 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 proposed changes to the 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 replacement 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 recommended 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 

SO2 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 

SO2 0 0 0 0 0 0 
San Joaquin Valley Unified Air Pollution 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 & Industrial, 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, manufacturing 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 

SO2 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 

SO2 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; 050-995-1500-0000; 052-070-0110-0000; 060-010-0110-0000; 

060-995-0110-0000; 060-995-0120-0000; 060-995-1500-0000; 099-995-0000-0000; 

310-356-0110-0000; 310-995-1600-0000; 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 rated 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 lower emission level but may not be available 

for smaller unit. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-18 

Boilers, Steam Generators, and Process Heaters, 0.075 MMBtu/hr 

(Continued) 

• Replacement of older existing units with new ones that already integrate low NOx 

technology is possibly the more cost effective control options to that of retrofitting 

existing units. 

• Replacing with electric heaters may also be an option since most facilities are in 

areas connected to existing commercial electric grid system. 

Discussion: 

• The District has legal authority to regulate 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 limit, it does not specify the turnover of 

boilers in service prior to that date. Mandating a specific date that all boilers in this 

size range must meet the current emission limit would generate faster turnover of 

the existing, boilers than natural attrition. 

• At full implementation, NOx emission reductions were estimated to be 2.0 tons NOx 

per day, or about 60% of the baseline 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 control devices. Control devices such as baghouse, 

electrostatic precipitators, and scrubbers are available, but they have not yet been 

demonstrated or achieved-in-practice for these units. Units firing on natural gas, 

propane, liquefied petroleum gas, or low sulfur diesel tend to emit very low levels of 

PM2.5 and SO2. AP-42 indicates that the uncontrolled total PM (condensable and 

filterable) is 0.007 pound per million Btu and uncontrolled SO2 is 0.0006 pound per 

million Btu for boilers firing on natural gas. The PM and SO2 emissions are less than 

4% and 0.3%, respectively, of the AP-42 uncontrolled NOx emission factor of 0.186 

pound per million Btu from natural gas-fired boilers. 

• Control of PM2.5 and SO2 can be achieved by requiring the units be fired exclusively 

on PUC quality natural gas, propane or Liquefied Petroleum Gas (LPG). Firing on 

other fuel types may only be allowed during natural gas curtailment periods.

• Physical space where the units are located is often limited and could impede 

installation of PM and SO2 control device, 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. Availability of trained installation and source testing 

personnel will also be considered 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 Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-19 

Boilers, Steam Generators, 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 NOx emission rate limits by a rule-based requirement 

(e.g. no units operating within the District that are 10 years or older, unless a certain 

emission rate can be demonstrated) or by the use of incentives or a combination of 

both strategies. An additional reduction of 5% from baseline emissions could be 

achieved by amending the current rule to accelerate replacement 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 units be fired exclusively on PUC-quality 

natural gas, propane, or liquefied petroleum gas (LPG). Allow 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, assuming 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 

SO2 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 

SO2 TBD TBD TBD TBD TBD TBD 
San Joaquin Valley Unified Air Pollution 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, Cogeneration, Service and Commercial) 

Source Category: 

This source category includes facilities 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 (electricity and heat) by burning solid fuels including 

petroleum coke, coal, municipal solid wastes, 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 

SO2 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 

SO2 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 refined to ensure that it captures the NOx 

reductions from existing boiler permit NOx limits 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% CO2. For all other units, the NOx limits is 115 ppmv @ 

3% O2. 

Future Control Options: 

• Current BACT is selective non-catalytic reduction (SNCR) or ammonia injection for 

municipal waste-fired or biomass-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 the NOx emission limits from Sacramento 

AQMD (70 ppmv) or (40 ppmv) are achievable. 

• There is some increased use of selective catalytic reduction (SCR) with ammonia 

injection in new coal-fired boilers in eastern states in the nation. European Best 

Available Technology (BAT) listed SCR for coal and lignite firing boilers. 

• There are no biomass-fired or municipal waste-fired boilers that are currently using 

SCR in the nation or in Europe. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-21 

Solid Fuel Boilers, Steam Generators, and Process Heaters 

(Continued) 

• Coal-fired units are not comparable to the District’s biomass fired or municipal solid 

waste fired boilers, which are non-homogenous 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 combustion retrofits that 

would require boiler rebuilds. 

Discussion: 

• The District has legal authority to regulate air emissions from units operated at 

stationary sources. 

• Rule 4352 was recently amended to implement BARCT and All Feasible Control 

Measure as a commitment in the District’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 facilities is important to reduce emissions from 

open burning. 

Recommendation: 

• This source category is recommended for feasibility study to investigate the 

feasibility of retrofitting the units with SCR or other combustion modifications to 

achieve additional NOx emissions reduction and controls for PM2.5 and SO2. 

Projected Reductions: 

Emission reductions will be calculated based 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 

SO2 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 

SO2 NQ NQ NQ NQ NQ NQ 
San Joaquin Valley Unified Air Pollution 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 & Industrial, Service & Commercial, Other – 

Fuel Combustion) 

Source Category: 

This source category includes any operations that use stationary 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 

SO2 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 

SO2 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 reflect the reductions from the recent 

September 2007 amendments to Rule 4703. 

Current Control: 

• Due to the recent September 2007 amendments, District Rule 4703 is considered to 

be the most stringent rule in California for this category. 

• Rule 4703 applies to stationary gas turbines with rated 0.3 megawatt (MW) and/or a 

maximum heat input greater than 3 MMBtu/hr. 

• Recent amendments in September 2007, established the following NOx emission 

limits corrected to 15% O2 for gas fired turbines which will be effective in 2012 or 

within 90 days following the next major overhaul 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 operating no greater than 200 hours/year: 

25 ppmv 

o Greater than 10 MW, simple cycle, operating no greater than 200 hours/year: 25 

ppmv 
San Joaquin Valley Unified Air Pollution 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, operating greater than 200 hours/year, but 

less than 877 hours/year: 5 ppmv 

o Greater than 10 MW, Combined cycle: 3 ppmv (enhanced compliance option) and 

5 ppmv (standard compliance option). 

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

• The previous exemption for low-use turbines’ operating hours limitation has been 

lowered from 877 hours/year to 200 hours/year. 

• Exemption includes laboratory 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 September 2007which requires units to meet 

the most stringent NOx limits in the nation. 

• Currently, there are no turbines firing on gaseous fuel in the nation or elsewhere that 

operate with PM2.5 and SO2 control devices for units. Control devices such as 

baghouse, electrostatic precipitators, and scrubbers are available, but they have not 

yet been demonstrated or achieved-in-practice for turbines. 

• PM2.5 and SO2 controls could include requiring firing the units on PUC quality 

natural gas, propane or liquefied petroleum gas. Combustion of these types of 

gases emits very low amount PM2.5 and SO2. If the units are not firing on PUC 

quality natural gas, propane or liquefied petroleum gas, consider requiring operation 

of PM2.5 and SO2 control devices. 

Discussion: 

• The District has legal authority to regulate air emissions from units operated at 

stationary sources. 

• Controlling PM and SO2 may be technologically feasible, but the cost effectiveness 

of controlling these pollutants from units firing on natural gas with the above 

mentioned emission factors is expected to be prohibitive. 

• The economic feasibility of controlling PM and SO2 would need to be evaluated in 

light of the recent September 2007 amendments requiring most units to retrofit by 

2012 to meet the most stringent NOx limits. 

• Physical space where the units are located could impede or present challenges to 

the effective installation of PM and SO2 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 turbine without water injection or combinedcycle turbines using dry low NOx could not use the SCONOx system. (Source “Final 
San Joaquin Valley Unified Air Pollution 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 Application 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 investigate the PM2.5 

and SO2 controls for this source category. 

Projected Reductions: 

Calculated NOx emissions reflect the reductions from September 2007 Rule 4703 

amendments which have not been previously reflected in the emissions inventory. The 

potential for emission reductions for PM2.5 and SOx will be calculated based 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 2.20 2.20 2.20 

PM2.5 NQ NQ NQ NQ NQ NQ 

SO2 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 

SO2 NQ NQ NQ NQ NQ NQ 
San Joaquin Valley Unified Air Pollution 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 reciprocating internal combustion engines. District 

Rule 4702 currently applies to engines greater 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 

SO2 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 

SO2 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 spark-ignited engines 

and stationary compression ignited (diesel) engines greater than 50 horsepower. 

• NOx limits for spark-ignited engines used exclusively in agricultural operations (AO) 

are: Rich burn – 90 ppmv or 80 percent reduction; lean-burn – 150 ppmv or 70 

percent 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: 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 Pollution 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 comply 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 emission limits to the same level as the 

non-AO units. 

• Consider the 2007 proposed South Coast Air Quality 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 proposing amendments to Rule 1110.2 (Emissions from 

Gaseous- and Liquid-Fueled Engines). Rule 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 currently electrifying 2,000 agricultural diesel engines under 

an incentive program the utility company and the District. 

• Technical and economic conditions may limit the application of electric motors in some 

locations and possible impacts to the power grid should be examined. 

• Current Rule 4702 goes beyond the ARB Suggested Control Measure for this source 

category. 

• Currently, no PM and SO2 control technologies have been demonstrated or achieved 

in practice for gaseous fired units. The AP-42 uncontrolled emissions factors for 

natural gas-fired 4-stroke lean burn engines are 0.000077 lb/MMBtu for filterable 

PM2.5 and 0.000588 lb/MMBtu SO2. The PM2.5 and SO2 emissions are about 0.01% 

and 0.07%, respectively, of the AP-42 uncontrolled NOx emission 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 Control Measure, which was implemented in 

2005. 
San Joaquin Valley Unified Air Pollution 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 SO2 emissions. The feasibility of controlling SO2 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 specified PM limit by the ARB deadline. 

• District staff recommends this source category as a control measure for rule 

amendments to consider SCAQMD’s Rule 1110.2 proposed NOx limits, and to 

include PM2.5 and SO2 controls. The emissions inventory may need to be adjusted 

to account for SO2 emissions reductions from the use of state-mandated 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 

SO2 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 

SO2 NQ NQ NQ NQ NQ NQ 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-28 

Small Spark-Ignited Engines and Agricultural 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 combustion engines rated at less 

50 brake-horsepower-hour (bhp-hr) or less 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 

SO2 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 

SO2 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 include the emissions from stationary 

internal combustion engines rated at 50 bhp-hr or less are not included in the 

emissions inventory. A survey of businesses and industries is needed to accurately 

determine the total number of small engines and to calculate their emissions. 

• A survey of agricultural operation (AO) sources is needed to accurately determine 

the total number of AO spark-ignited engines and update the emissions inventory. 

Based on extrapolation from preliminary data provided by a stakeholder, there are at 

least 1,000 AO spark-ignited engines operating within the District. 

Current Control: 

• Rule 4702 applies to stationary internal combustion engines greater than 50 bhp-hr. 

Small stationary spark-ignited engines rated at 50 bhp-hr or less are exempt from 

Rule 4702. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-29 

Small Spark-Ignited Engines and Agricultural Spark-Ignited Engines 

(Continued) 

• Rule 4702 NOx limits for spark-ignited 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 percent 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 with electric motors – where possible. 

• Evaluate potential controls for small spark-ignited engines. 

• Consider lowering the current 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-ignited 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 regulate engines greater than 25 bhp-hr. 

• SCAQMD is currently proposing amendments to Rule 1110.2 (Emissions from 

Gaseous- and Liquid-Fueled Engines). Rule 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. 

• Additional NOx reductions could be achieved by lowering the current emission limits 

for agricultural spark-ignited engines and by expanding the applicability of existing 

Rule 4702 so that engines rated at greater than 25 bhp-hr to 50 bhp-hr would be 

subject to the rule. 

Recommendation: 

• Explore opportunities for incentive funding and regulatory action to achieve earlier 

and additional emission reductions from this source category. 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-30 

Small Spark-Ignited Engines and Agricultural Spark-Ignited Engines 

(Continued) 

• Conduct an emissions inventory survey to determine the total number of small 

spark-ignited engines and agricultural operations spark-ignited engines operating in 

the District. 

• Evaluate potential controls for small spark-ignited engines. 

• Evaluate if SCAQMD’s proposed 11 ppmv NOx limit is feasible for agricultural sparkignited engines. 

• District staff recommends this source category as a control measure for Feasibility 

Study. 

Projected Reductions: 

Emission reductions will be calculated based 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 

SO2 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 

SO2 NQ NQ NQ NQ NQ NQ 
San Joaquin Valley Unified Air Pollution 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-melting 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 

SO2 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 

SO2 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. NOx emission limits range 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 limits 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 applies to all industrial glass-melting furnaces 

in the District. The NOx emissions are controlled 67% to 76% compared to uncontrolled 

glass-melting furnaces. 

Future Control Options: 

• NOx controls: 100% Oxygen 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 selection, and scrubbers (wet or dry). 
San Joaquin Valley Unified Air Pollution 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, glass formulations, and controls. 

• SCR is an add-on control that may help operators meet lower NOx limits. SCR has 

been used by other source categories to reduce NOx emissions. Glass melting 

furnaces in Europe and Asia have successfully used SCR to control NOx emissions, 

but to date; no facility in the US has implemented this control technology. 

• Emission reductions from the last furnaces to meet the 2002 rule amendments will 

begin starting in 2008. There are four furnaces with NOx limits greater than these 

limits that are expected to be rebuilt by 2012: three container glass furnaces and 

one flat glass furnace. The most cost-effective time to change NOx controls is 

during furnace rebuild. To ensure that furnaces meet the limits by 2012, it is 

recommended that rule development be completed by 2009. 

• Operators have increased production capacity during the most recent round of 

rebuilds, triggering Best Available Control Technology (BACT) provisions. The 

BACT provisions have resulted in NOx emissions limits that are much less than 3 

and 5 pounds per ton of glass pulled for container/fiberglass and flat glass furnaces, 

respectively, so the current draft rule proposes similar limits. 

• When fully implemented, District staff has estimated that 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 rule amendments and the 

reductions from the current rule, which have not been added to the inventory. PM2.5 

and SOx reductions will be calculated based on the information 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 

SO2 TBD TBD TBD TBD TBD TBD 
San Joaquin Valley Unified Air Pollution 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 

SO2 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 

SO2 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 distillate fuel oil-fired; 0.20 lb/MMBTU residual 

fuel oil-fired 

Future Control Options: 

• Future control option includes lowering the current NOx emission limits. 

• Available retrofit combustion control technologies to achieve lower NOx limits 

include low NOx burner and ultra low NOx burners fired on natural gas. Add-on 

controls such as SCR or SCNR is technologically 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 operating in the District. The kiln is operated 

only during ozone season to manufacture sugar. 

• The current permit allows firing on distillate fuel 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 Pollution 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/MMBtu (30 ppmv) fired on natural gas fuel 

and 0.052 lb/MMBtu (40 ppmv) fired on liquid fuel (residual fuel oil or distillate oil), at 

3% excess oxygen. 

• Require firing on natural gas as primary fuel. 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 least 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 least 40 ppmv for distillate oil firing. 

Recommendation: 

• Staff recommends this source category be controlled through regulatory method with 

implementation schedule not earlier than 2012 to allow time to design, procure, and 

install retrofit control technology. Compliance schedule for the new emission limit 

should coincide during off-season when the kiln is not operating so retrofit could be 

completed without disrupting normal 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 above depending on the type of fuel (natural 

gas or distillate) used to fire the unit. 

• Consider inclusion of an alternative compliance 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 quantifiable for this source category. 

However, a future study to re-evaluate this source category may be planned in the 

future. 

Projected Reductions: 

Calculated emission reductions, assuming 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 

SO2 0 0 0 0 0 0 
San Joaquin Valley Unified Air Pollution 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 heaters 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 

SO2 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 

SO2 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 residential water heaters, which are 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 either a specific compliance 

schedule or incentive funding. 

Discussion: 

• Lower NOx limits are currently in place 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 water heaters in the 

San Joaquin Valley may already meet the new limits. 

• Nonresidential water heaters and mobile home heaters are exempt from current rule 

requirements, although these applications generally use similar water heating 

devices. 

• The transition from older to newer, less NOx-emitting units currently occurs through 

attrition and assumes a 20-year lifetime for water heaters. 
San Joaquin Valley Unified Air Pollution 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 considered negligible.

Recommendation: 

• Amend Rule 4902 to lower the NOx emission limit, similar to SCAQMD Rule 1121 

standard for post-2008 units and expand its applicability to nonresidential and mobile 

home heaters, taking into account any technological limitations. 

• Control PM2.5 and SO2 by requiring the units be fired exclusively on PUC-quality 

natural 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 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 effective reductions in the future provided funding sources 

are available. 

Projected Reductions: 

Calculated reductions assuming the recommended 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 

SO2 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 

SO2 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 reduction 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 the additional applicable units. 
San Joaquin Valley Unified Air Pollution 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-fired, residential central heating furnaces. 

These units are in the size range of rated heat input capacity of less than 175,000 

British thermal units per hour and, for combination 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 

SO2 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 

SO2 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 million BTU heat output or 55 ppm NOx at 

3.00% O2 stack gas by volume (dry). 

Future Control Options: 

• Low-NOx burner (LNB) technology with NOx emissions of approximately 0.046 

lb/MMBtu has been developed, but it has not reached the commercially available 

stage. These burners could be required 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 efficiencies lead to less fuel usage and lower 

total emission amounts. 

• Require state-of-the-art control systems that minimize energy use and reduce fuel 

consumption. 
San Joaquin Valley Unified Air Pollution 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 controlled 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 required or developed that would reduce 

emissions further. Since these units are fired on natural gas, no significant reduction 

in PM2.5 and SO2 is anticipated. 

Recommendation: 

• LNB are not currently commercially available but do present the possibility of 

significant reductions from new or replacement units. Therefore, staff recommends 

amending Rule 4905 to establish more stringent 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 

SO2 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 

SO2 NQ NQ NQ NQ NQ NQ 
San Joaquin Valley Unified Air Pollution 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 convert liquid milk to dried milk, and 

units used to dry aggregate 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 

SO2 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 

SO2 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 natural 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 the 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 currently specified under current controls are 

known at this time. 

Discussion: 

• Low-NOx burners are already in use for sources subject to rule provisions. Some of 

the sources that are currently exempt from the rule are already using this technology 

as part of their Permit to Operate. 

• The bulk of the dryers, dehydrators, and ovens operate at temperatures that are too 

low for efficient operation of NOx emission control systems, therefore add-on 

controls are not an option for this source category. 
San Joaquin Valley Unified Air Pollution 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 reductions from these 

units would be small since nearly all exempted 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 subject to the rule below the current 5.0 MMBtu/hr. As the 

heat input cut-off decreases, the 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 Btu/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 equipment advancements may produce additional 

reductions from exempt equipment. A feasibility study to re-evaluate this source 

category is planned. 

Projected Reductions: 

Calculated emission reductions, assuming 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 

SO2 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 

SO2 NQ NQ NQ NQ NQ NQ 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-41 

Wood Burning Fireplaces and Wood Burning Heaters (S-COM-14)

(Residential Fuel Combustion) 

Source Category: 

This source category includes fireplaces and 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 

SO2 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 

SO2 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 San Joaquin Valley under Rule 4901. The rule was adopted 

in 1993 and amended in 2003. 

• Exempts gaseous-fueled devices and cook stoves described in the Code of Federal 

Regulations. 

• From November through February, the episodic 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 feet in elevation, or where natural gas 

service is not available, or if they are the sole source of heat in a residence are not 

subject to the episodic curtailment provisions. 

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

• Real property cannot be sold or transferred 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 installed in a new residential development with a 

density greater than two dwelling units per acre. 

• No more than two EPA Phase II certified wood burning heaters can 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 Pollution 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 threshold 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 attaining 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 source of heat, are currently not subject to the 

rule. The rule could include a provision to allow counties, cities, and municipalities 

to require residents their geographical areas to participate in mandatory burn 

curtailment program, even though they are otherwise exempt 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 rules in the nation. Other 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 the federal PM10 standards. 

Recommendation: 

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

Projected Reductions: 

Calculated reductions assuming the recommended 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 

SO2 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 

SO2 0.0 0.01 0.02 0.02 0.02 0.02 
San Joaquin Valley Unified Air Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-43 

Prescribed Burning and Hazard Reduction Burning (S-GOV-6)

(Managed Burning and Disposal) 

Source Category: 

This source category includes activities related to prescribed burning and hazard 

reduction burning in wildland/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 

SO2 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 

SO2 0.52 0.52 0.52 0.52 0.52 0.52 0.52 

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

Current Control: 

• District Rule 4106 authorizes restrictions on material; burning allocations; prescribed 

burning requirement; permits for hazard reduction burning; smoke management 

plans for prescribed burning; go/no go decisions 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 management practices that result in less 

uncontrolled and untimely fires 

Discussion: 

• The District has authority over emissions from this source category. 

• District Rule 4106 is currently the most stringent regulatory strategy in California for 

this source category. 

• While the hazard reduction burning is stringently regulated, other alternatives to 

burning exist. Particularly for homeowners, much green waste is generated in 

preparing their property to meet the guidelines 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 Pollution 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 materials, but most do not. Woody materials 

could be chipped to make mulch, but the cost of a chipper that could process goodsized tree limbs is too costly for most residents. Therefore, the most cost-effective 

solution for homeowners currently is burning the dried plant materials. 

• This source category could be a candidate for an incentives program such as 

offering free or reduced cost hauling of the green waste from private properties at 

the wildland/urban interface. Free or reduced cost for chipping/grinding of woodbased materials could also be considered. 

• Hazard reduction burning is allowed with a burn permit within the State 

Responsibility Area and the Federal Responsibility Area of the District. These areas 

are generally the foothill and mountain areas of the District. Such burning is 

prohibited in the Local Responsibility Area, which represents the valley floor. 

• Fire Safe Councils and Resource Conservation Districts within the urban/wildland 

interface often receive Federal grant monies for fuel break and hazard fuel reduction 

programs, of which much of the accumulated materials are chipped and not burned. 

Examples include the Hwy 168 Fire Safe Council, the Eastern Madera Fire Safe 

Council, the Central Sierra Watershed Committee, 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 reductions from this source category. 

• The magnitude of the current emissions inventory for this source category warrants 

a close look at possible methods of reducing emissions. A feasibility study to closely 

examine alternatives to prescribed burning is planned. 

Projected Reductions: 

Emissions reductions will be quantified during the rule development 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 

SO2 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 

SO2 NQ NQ NQ NQ NQ NQ 
San Joaquin Valley Unified Air Pollution 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 cotton 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 

SO2 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 

SO2 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 Enhanced 1D3D cyclone or the 1D3D with expansion chamber. 

Rule 4204 also regulates the trash conveyance systems on gins. 

Future Control Options: 

• Additional research is required to determine if controls such as baghouses, stacked 

cyclones or other PM10 controls are applicable 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 which 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 the PM2.5 fraction is required to develop a more accurate 

emissions inventory for the various 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 cyclones as the most 

efficient collectors of fine dust (PM10) with the 1D3D more efficient than the 2D2D. A 

number of jurisdictions have thus classified the 1D3D as BACT for PM10. 

• Two jurisdictions, Maricopa County (AZ) and the State of North Carolina, require 

1D3D and/or 2D2D cyclones in ginning operations for control of PM10. 
San Joaquin Valley Unified Air Pollution 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 significant source of PM2.5, 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 necessary to determine feasible, cost-effective 

control measures, should they be necessary. 

• Rule 4204 (Cotton Gins) is currently the most stringent in the nation for this source 

category to control PM10. 

Recommendation:

While PM10 emissions and controls for this category are well established, 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 representative emissions inventory. If that 

inventory appears to be significantly large and contribute to the non-attainment problem, 

staff would then examine control effectiveness for PM2.5 reduction strategies that could 

be used to reduce the PM2.5 inventory. 

Projected Reductions: 

Emission reductions will be calculated based 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 

SO2 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 

SO2 0 0 0 0 0 0 
San Joaquin Valley Unified Air Pollution 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 government 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 include control of emissions from underfired charbroilers. 

• The BAAQMD draft Regulation 6 Rule 2 would require operators 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 feasible. If the PM10 controls 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 Pollution 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 regulate 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 establishments may be obtained from the county 

or city Health Departments responsible for inspecting and regulating such food 

establishments. 

• A baseline emissions for under-fired charbroilers would need to be determined 

because the ARB inventory reported total emissions from both under-fired versus 

chain-driven charbroilers. BAAQMD Draft Staff Report for Regulation 6 Rule 2 

stated that according to U.C. Riverside study conducted in 1997 under-fired 

charbroilers account for 82% of PM emissions generated by restaurants. 

• This control measure will primarily target PM emissions reduction from under-fired 

charbroilers since the BAAQMD has determined that control of VOC emissions from 

under-fired charbroilers not economically feasible. 

• Currently, there are no achieved-in-practice or technologically feasible control 

technologies to reduce NOx or SO2 emissions from charbroiling equipment. 

Recommendation:

• Expand applicability of Rule 4692 to regulate PM emissions from under-fired 

charbroilers with full implementation by 2011. 

Projected Reduction: 

Calculated emission reductions, assuming 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 

SO2 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 

SO2 0 0 0 0 0 0 
San Joaquin Valley Unified Air Pollution 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, extraction or other earthmoving activities; 

handling transport, and storage of bulk materials; landfill operations; unpaved roads, 

unpaved vehicle/equipment traffic areas; disturbed open areas; and off-field 

agricultural sources.) 

Source Category: 

Anthropogenic (human-caused) activities result in the majority of fugitive dust 

emissions. Mechanical disturbance (for example, vehicles traveling over an unpaved 

surface, or earthmoving operations associated with construction activities, or sand and 

gravel or other mining activities) is a significant source of fugitive dust emissions). Wind 

events, although infrequent in the San Joaquin Valley, also contribute to fugitive dust 

emissions especially as wind travels over previously disturbed, unstabilized surface. 

Emissions Inventory: 

Refer to Emissions Inventory for each Regulation VIII rules below. 

Current Control: 

• Existing Regulation VIII (Fugitive PM10 Prohibitions) is comprised of eight rules that 

regulate fugitive dust emissions. Regulation VIII applies to anthropogenic dust 

sources; it does not apply to PM10 precursor sources or sources of smoke. 

Specifically, Regulation VIII applies to activities that have the potential to emit or 

result in primary PM10 fugitive dust emissions such as construction, demolition, 

excavation, extraction or other earthmoving activities; handling transport, and 

storage of bulk materials; landfill operations; unpaved roads, unpaved 

vehicle/equipment traffic areas; disturbed open areas; and off-field agricultural 

sources. 

• The eight rules under Regulation VIII are: Rule 8011 (General Requirements); Rule 

8021 (Construction, Demolition, Excavation, 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 requirements and dust control plans, applicability, 

thresholds (e.g. amount of activity such as vehicular passes 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 Pollution 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 which 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 the PM2.5 fraction is required to develop a more accurate 

emissions inventory for the various 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 significant source of PM2.5, 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 necessary to determine feasible, cost-effective 

control measures, should they be necessary. 

• Please refer to specific discussions for each of the rule in Regulation VIII, which 

follow below. 

Recommendation: 

While PM10 emissions and controls for this category are well established, 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 representative emissions inventory. If that 

inventory was significantly large, staff would then examine control effectiveness for 

PM2.5 reduction strategies that could be used to reduce the PM2.5 inventory. 

 
San Joaquin Valley Unified Air Pollution 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 are 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 inventory associated with Rule 8011. 

Current Control: 

• Materials used for chemical/organic stabilization of soils should not violate State 

Water Quality Control Board standards for use as a soil stabilizer. Materials 

accepted by ARB and EPA, which meets State water quality standards are 

acceptable to the District. 

• Materials prohibited for use as dust suppressant by EPA, ARB, or other applicable 

laws, rules, or regulations are also prohibited for use under Regulation VIII. 

• Prohibits the use of hygroscopic materials as dust suppressant in areas lacking 

sufficient atmospheric moisture of soil for such material to effectively reduce fugitive 

dust emissions. Use of such materials may 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 content, threshold friction velocity for 

demonstration of compliance with the standards specified in Regulation VIII rules. 

• Allows an alternative compliance option for certain specified requirements of Rule 

8061 (Paved and Unpaved Road) and Rule 8071 (Unpaved Vehicle/Equipment 

Traffic Areas) provided the operator submits 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 control efficiency required by the alternate 

compliance option’s Fugitive PM10 Management Plan. 

• Evaluate other more effective feasible control techniques. 

Discussion: 

• Fugitive dust generating activities are 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 required to obtain operating permits from the 

District. For sources that are not required to have operating permits, the District 

should periodically examine county/city building permits department records to 

determine the location and duration of fugitive dust generating activities so that 

District inspectors could ensure operators are complying with the rules. 
San Joaquin Valley Unified Air Pollution 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 through several actions including, but not 

limited to, an increased presence of District Compliance Division staff in the field, 

increased use of Dust Control Plans, increased compliance assistance, and greater 

public outreach. 

Recommendation: 

• See recommendations for Regulation VIII as a whole.
San Joaquin Valley Unified Air Pollution 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 are not limited to, building and construction 

industry, mining industry, sand and gravel 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 

PM2.51 1.00 1.08 1.09 1.01 1.01 1.02 1.03 

SO2 0 0 0 0 0 0 0 

Tons per day – annual average 

NOx 0 0 0 0 0 0 0 

PM2.51 1.09 1.18 1.19 1.10 1.11 1.11 1.12 

SO2 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, demolition, 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 modification 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 Division of Industrial Safety; maintenance or remodeling 

of existing buildings and additions 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 buildings; disking of weeds and dried vegetation 

related to fire prevention required by federal, 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 public 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 Control Plan with specific information on the 

location, total land area that would be disturbed, including duration of activities, 

volume of earthmoving activities, type of dust suppressant to be applied, measures 

to be taken to control carryout/trackout. Operators/owners are required to submit 

Dust Control Plan for any construction activity on any site 10 or more acres of 

disturbed surface area for residential developments, or five acres or more for non- 
San Joaquin Valley Unified Air Pollution 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 materials 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, during 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 earthmoving activities 

that disturb the soil whenever VDE exceeds 20% opacity. 

Future Control Options: 

• Evaluate the feasibility of eliminating existing exemptions 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 feasible would be evaluated during the rule 

development process. 

Discussion: 

• Fugitive dust generating activities are 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 required to obtain operating permits from the 

District. For sources that are not required to have operating permits, the District 

should periodically examine county/city building permits department records to 

determine the location and duration of fugitive dust generating activities so that 

District inspectors could ensure operators are complying with the rules. 

• Enhance the effectiveness of the rules 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, increased compliance assistance, and greater 

public outreach. 

Recommendation: 

• See recommendations for Regulation VIII as a whole.
San Joaquin Valley Unified Air Pollution 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 are not limited to, building and construction 

industry, mining industry, sand and gravel industry, food and agricultural processing 

industry, mineral processing industry, glass and related products industry, chemical 

industry, landfills, and companies that 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 

SO2 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 

SO2 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, handling, or transport 

of bulk materials which would be damaged by wetting or application of 

chemical/organic dust suppressants if none of the 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 conveyor device; outdoor 

storage of bulk material at a single site where no material is actively being added or 

removed at the end of the workday or overnight and where the total material stored 

is less than 100 cubic yards; agricultural sources subject to Rule 8081 (Agricultural 

sources) or exempt by Rule 8011 (General Requirements). 

• Rule 8031 requires control of fugitive dust emissions from any outdoor handling, 

storage, and transport of bulk materials in such a manner that limit the VDE to 20% 

opacity or less in addition to implementing specific control measures listed in the 

rule. 

o For handling of bulk materials: Apply 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 material surface needs to be stabilized; cover 

bulk material with tarp or other suitable material and anchored securely; 
San Joaquin Valley Unified Air Pollution 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 with 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 limited 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 materials: clean interior of the cargo 

compartment or cover compartment 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 sufficiently 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 Pollution 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 are 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 required to obtain operating permits from the 

District. For sources that are not required to have operating permits, the District 

should periodically examine county/city building permits department records to 

determine the location and duration of fugitive dust generating activities so that 

District inspectors could ensure operators are complying with the rules. 

• Enhance the effectiveness of the rules 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, increased compliance assistance, and greater 

public outreach. 

Recommendation: 

• See recommendations for Regulation VIII as a whole.
San Joaquin Valley Unified Air Pollution 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 are not limited to, building and construction 

industry, mining industry, sand and gravel industry, food and agricultural processing 

industry, mineral processing industry, glass and related products industry, chemical 

industry, landfills, and companies that 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 

PM2.51 TBD TBD TBD TBD TBD TBD TBD 

SO2 0 0 0 0 0 0 0 

Tons per day – annual average 

NOx 0 0 0 0 0 0 0 

PM2.51 TBD TBD TBD TBD TBD TBD TBD 

SO2 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 source categories would need to be 

established. 

• The ARB Emissions Inventory database does not contain emissions data pertaining 

to carryout and trackout. Needs to establish the baseline emissions for carryout and 

trackout and update the ARB database. 

Current Control: 

• Rule 8041 applies to all sites that are 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 exempt from complying with Rule 8041. 

• Rule 8041 requires operators/owners to sufficiently prevent or cleanup carryout and 

trackout. 

• Prohibits the use of blower devices, or dry 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 trips per day, or 20 or more vehicle trips per 

day by vehicles with 3 or more axles: 

• Prevent carryout or trackout by installing and maintaining a trackout control 

device at all access points to paved public roads; or 
San Joaquin Valley Unified Air Pollution 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 device prevention procedure that has been 

demonstrated to the satisfaction of the APCO and EPA as achieving 

equivalent or greater level of control than the device mentioned above. 

• If the carryout and trackout device is insufficient, remove carryout and trackout within 

1⁄2 hour of the generation of such carryout and trackout. 

• Within urban areas, prevent carryout and trackout, or immediately remove carryout 

and trackout when it extends 50 feet or more 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 surface exit point of the site. 

• Cleanup of trackout and carryout should be done by manually sweeping and picking 

up, operating a rotary brush or broom accompanied or preceded by wetting to limit 

VDE to 20% opacity; operating a PM10-efficient street sweeper that has a pick-up 

efficiency of at least 80%, or flushing with water, if curbs or gutters are not present 

and where the use of water will not result as a source of trackout material or result in 

adverse impacts on storm water drainage systems or violate any NPDES permit 

program. 

• The rule specifies criteria for use of grizzlies, gravel pads, and paving of surfaces to 

prevent carryout and trackout. 

Future Control Options: 

• Eliminate the vehicle trips per day threshold for requiring installation of control 

device to prevent trackout and carryout.

• Clearly establish and enforce traffic patterns to route traffic over selected trackout 

control devices. 

• Limit accessibility to the site by installing barriers on unprotected routes without 

trackout control devices. 

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

• Decrease the 50 feet of carryout/trackout accumulation distance threshold for 

requiring cleanup of carryout and trackout. 

Discussion: 

• Fugitive dust generating activities are 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 required to obtain operating permits from the 

District. For sources that are not required to have operating permits, the District 

should periodically examine county/city building permits department records to 

determine the location and duration of fugitive dust generating activities so that 

District inspectors could ensure operators are complying with the rules. 
San Joaquin Valley Unified Air Pollution 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 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, increased compliance assistance, and greater 

public outreach. 

Recommendation: 

• See recommendations for Regulation VIII as a whole.
San Joaquin Valley Unified Air Pollution 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 are not limited to, building and construction 

industry, mining industry, oil and gas production, sand and gravel industry, food and 

agricultural processing industry, mineral processing industry, glass and related products 

industry, chemical industry, landfills, and government 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 

SO2 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 

SO2 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 indicates 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 implement specific control measures 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 application of water or 

dust suppressants to all non-vegetated areas, establishment of vegetation on all 

previously disturbed areas, or paving, application 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 effectively prevent access.
San Joaquin Valley Unified Air Pollution 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 are 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 square feet of disturbed area. 

• Implement similar control requirements and reporting provisions for open areas as 

specified in Maricopa County APCD Regulation III Rule 310.01 (Fugitive Dust from 

Open Areas, Vacant Lots, Unpaved Parking 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 required to obtain operating permits from the 

District. For sources that are not required to have operating permits, the District 

should periodically examine county/city building permits department records to 

determine the location and duration of fugitive dust generating activities so that 

District inspectors could ensure operators are complying with the rules. 

• Develop an outreach program requiring property owners/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 measures that would be implemented if their 

property is subject to Rule 8051. 

• Enhance the effectiveness of the rules 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, increased compliance assistance, and greater 

public outreach. 

Recommendation: 

• See recommendations for Regulation VIII as a whole.
San Joaquin Valley Unified Air Pollution 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 production, sand and gravel industry, agriculture 

industry, mineral processing industry, landfills, 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 

PM2.51 8.18 8.25 8.46 8.63 8.80 8.98 9.15 

SO2 0 0 0 0 0 0 0 

Tons per day – annual average 

NOx 0 0 0 0 0 0 0 

PM2.51 9.65 9.70 9.93 10.11 10.30 10.48 10.67 

SO2 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; 640-643-5400-0000; 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 exemptions 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 resurfacing 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 the 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 American Association of State Highway and 

Transportation guidelines for width of shoulders and for medians shoulders. The 

minimum paved or stabilized shoulder 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 Pollution 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 sweepers 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 surface travel lanes resulting from 

wind/storm/water erosion and runoff within 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/suppressants, watering, paving, installing 

roadmix or uniform layer of washed gravel, or other equivalent methods 

approved by the APCO. 

o Construction of new unpaved road in urban areas except for temporary unpaved 

roads that meets the conditions 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 Unpaved Shoulders in Urban and Rural Areas: 

o Each city, county, or state agency must: 

- Provide a list to the District of all 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 highest AADT by 1/1/10. 

- In rural areas, pave or stabilize 4-foot shoulders on 25% of existing paved 

public roads with the highest AADT by 1/1/10. 

- If the requirements above could not be met due to budgetary constraints, 

submit statement of financial 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 unpaved road with 26 

AADT and post speed limit signs one in each direction, per mile of unpaved 

road segment in urban areas, and per two miles of unpaved road segment in 

rural areas.
San Joaquin Valley Unified Air Pollution 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 air 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, District 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 number and miles of unpaved roads and associated 

AADT from responsible federal agencies responsible 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, increased compliance assistance, and greater 

public outreach. 

Recommendation: 

See recommendations for Regulation VIII as a whole. 
San Joaquin Valley Unified Air Pollution 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 are not limited to, building and construction 

industry, city, county, and state agencies, mining industry, oil and gas production, sand 

and gravel industry, food and agriculture processing industry, mineral processing 

industry, landfills, and industrial and manufacturing 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 

SO2 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 

SO2 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 exemptions 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 effectively limits VDE to 20% opacity. 
San Joaquin Valley Unified Air Pollution 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 (VDT), 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 the 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 least 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 surface, 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 remains 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 associated with this source category. 

• Evaluate the feasibility of paving vehicle and equipment traffic areas that are 

frequently and regularly used on a daily basis. 

 

Discussion: 

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

• District staff should evaluate the compliance status of source owners/operators to 

determine the effectiveness of existing rule requirements. 

• Based on overall compliance status, District 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, increased compliance assistance, and greater 

public outreach. 

Recommendation: 

• See recommendations for Regulation VIII as a whole.
San Joaquin Valley Unified Air Pollution 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 agriculture 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 

SO2 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 

SO2 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; 620-618-0262-0107; 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 exemptions 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 chemical/organic dust suppressants if the 

operator could demonstrate that none of the other control 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 subject to Rule 4550 (Conservation 

Management Practices). Equipment with loading forks employed in loading and 

unloading harvested commodities in the harvest location and traveling at 3 miles 

per hour or less is not included in the VDT counts. 

o The felling or removal of trees from forest lands. However, Regulation VIII rules 

apply to other timber harvest activities such as site preparation of log storage and 

staging areas.
San Joaquin Valley Unified Air Pollution 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 single site where no material is actively 

added or removed and where the total material 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 area 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 constructing new or modifying existing paved 

roads. 

o Except as specifically exempted by Rule 8081, owners/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, limit 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 limits 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 occur on unpaved vehicle/equipment traffic 

area, limit VDE to 20% opacity and comply with the requirements of a 

stabilized unpaved road by the application 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 requirements for stabilized surface by the 

application of the control measures mentioned above. 

o For carryout and trackout, comply with the requirements of the California Vehicle 

Code Section 23112-23113 which requires material, including dirt deposited on 

any public highway or street to be cleaned up. 

o As an alternative compliance option, owners/operators may implement a Fugitive 

PM10 Management Plan (FPMP) that achieves 50% efficiency and 
San Joaquin Valley Unified Air Pollution 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 submission and approval 

process for FPMP, including the information that must be included in the FPMP. 

Future Control Options: 

• Evaluate the appropriateness of continuing the exemption for bulk material storage 

of less than 100 cubic yards at a single location where no material is actively added 

or removed. Bulk material storage pile is susceptible to windblown emissions if left 

exposed (without cover such as tarp) especially during high wind conditions. 

• Reevaluate existing exemption of on-field agricultural sources in conjunction with 

current requirements of Rule 4550 (Conservation Management Plan). 

• Consider establishing similar appropriate control requirements for carryout and 

trackout as specified in Rule 8081 instead current requirements to comply the 

requirements under the California Vehicle Code sections 23112-23113. 

Discussion: 

• District has legal authority to regulate air emissions from sources subject to Rule 

8081. 

• District staff should evaluate the compliance status of source owners/operators to 

determine the effectiveness of existing rule requirements. 

• Based on overall compliance status, District 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, increased compliance assistance, and greater 

public outreach. 

Recommendation: 

• See recommendations for Regulation VIII as a whole.
San Joaquin Valley Unified Air Pollution 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 operation 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 

SO2 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 

SO2 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 emergency flaring events. Current NOx emissions 

appear to be low and may have only accounted for the emissions generated by the 

gas fuel used by the flare pilot flame. 

• Usage records will be used to determine the total amount of gases sent to the flare 

during normal operation and process equipment upset or breakdown periods. 

Thereafter, the emissions will be calculated and the emissions inventory will be 

updated. 

Current Control: 

• District Rule 4311 addresses operations involving the use of a flare. Specific 

requirements include: pilot flame devices, automatic ignition systems, heat-sensing 

devices, use of purge gases, applicable provisions 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 including installing vapor recovery systems; 

increasing the vapor recovery system capacity; increasing the fuel gas treating 

capacity; more rigorous monitoring and reporting requirements; and improving 

operational and maintenance procedures to prevent upset conditions. 

• Control devices for NOx, PM2.5 and SOx emissions from flares should be 

considered. 
San Joaquin Valley Unified Air Pollution 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 required 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 explicitly 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 measure options of this strategy. 

Recommendation: 

• Evaluate the effect of FMP and related information that other districts have 

implemented. Amend District Rule 4311 to incorporate 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 calculated 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 

SO2 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 

SO2 TBD TBD TBD TBD TBD TBD 
San Joaquin Valley Unified Air Pollution 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-duty vehicles, and off-road equipment) 

Source Category: 

In terms of NOx reductions, ISR impacts three 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 heavy-construction machinery. 

Emissions Inventory: 

The baseline inventory for ISR is in the three source category groups mentioned above 

and is included in the ARB mobile source inventories. 

Current Control: 

The Indirect Source Rule, Rule 9510, is designed to mitigate emissions associated with 

development projects that exceed two tons per year of NOx and PM10. Specifically, for 

the construction phase of a development project, Rule 9510 requires a 20% NOx 

reduction from the statewide average 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 from the operational baseline, as computed using an 

APCO-approved model, e.g. URBEMIS. Both sources of NOx reductions can be met by 

implementing on-site emission reduction measures or by payment of off-site mitigation 

fees to the District. 

VOC reductions are not part of the mitigation requirements of Rule 9510, since the 

effects of VOC emissions have been deemed as insignificant in the formation of PM2.5. 

However, ozone formation involves both VOC and NOx. Therefore, VOC emissions 

associated with development projects 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 evaluate the potential of suggestions received during the 

development of the 2007 Ozone Plan: 

• Increase the required reduction from the use of construction equipment greater than 

50 horsepower from 20% to 50% NOx reduction from the statewide average. 

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

reduction. 

• Add VOC (an ozone precursor) reduction 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 Pollution 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 reduction attributable to ARB’s tailpipe 

control, Rule 9510 required only 33% mitigation. 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 operational baseline emissions is approximately 2 

tons per day. 

• A future reevaluation of Rule 9510 should include analysis of VOC emissions and its 

reduction through mitigation requirements. 

Recommendation: 

• At this point, the District is exploring 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 suggestions 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, Innovative Strategies and Programs, for any additional 

information on this source category. 

Projected Reductions: 

Emission reductions will be calculated based 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 

SO2 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 

SO2 NQ NQ NQ NQ NQ NQ 
San Joaquin Valley Unified Air Pollution 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 coatings and solvents, asphalt paving and 

roofing operations, barbecue cooking, off-road construction machinery, 

recreational vehicles and watercrafts, household aerosols, single occupancy 

vehicle travel and other 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 

SO2 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 

SO2 NQ NQ NQ NQ NQ NQ NQ 

Current Control: 

Public service announcements which encourage residents and employees to curtail 

activities that cause air pollution; partnerships with 700 public and private entities 

enable workers to participate in Spare-The-Air (STA) day activities, including receiving 

rewards and recognition; various outreach programs, including: clean 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 programs, including assisting businesses and 

public agencies in establishing alternative transportation programs, telecommuting 

programs, voluntary episodic operation curtailments, emissions reduction potential 

analysis, and emissions footprints. 

• Additionally emphasize trip reduction programs, idling curtailments, low emissions 

yard care equipment throughout the three 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 less conducive to ozone formation. 

• Postpone nonessential activities in stationary 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 Pollution 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 encouraging 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 activities, such as: (1) Staying in for lunch, 

(2) Carpooling for lunch, (3) Carpooling and trip linking with fellow 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, coordinates these efforts. 

• The District’s alternative transportation program gets 40% participation, wherein 

employees taking part use alternative transportation 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 than 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. However, 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 contribute to ozone formation will be on a voluntary 

basis, since the District does not have the authority to impose an outright ban on 

these activities. Local government entities are empowered by state law to limit 

certain activities, as has been done by cities 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 recreational vehicles and watercraft, lawnmaintenance equipment, drive-thorough, etc. Promote the adoption of these 

ordinances by cities and counties, with the District providing technical and 

scientific assistance in subjects pertaining to air quality. 

o Explore ways to incentivize the voluntary participation of stationary sources in 

curtailing activities that contribute to ozone formation. 

o As a form of voluntary and emerging measures for which EPA has provided 

guidelines for SIP credits, design Healthy Air Living projects so that EPA 

criteria for SIP accreditation are fulfilled.
San Joaquin Valley Unified Air Pollution 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 based 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 

SO2 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 

SO2 NQ NQ NQ NQ NQ NQ 
San Joaquin Valley Unified Air Pollution 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 

SO2 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 

SO2 TBD TBD TBD TBD TBD TBD TBD 

• EIC Affected: There is no known inventory for 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 municipalities limit the time and place of use, as well as 

regulating the type of fireworks that may be sold to the public. 

• Where allowed by local ordinances, fireworks emissions are generally uncontrolled. 

• The U.S. Consumer Product Safety Commission (CPSC) regulates consumer 

fireworks as part of its mission to protect the public from unreasonable risk of serious 

injury or death from consumer products. Its regulations contain construction, 

performance, amount and composition of pyrotechnic (powder) material present in 

the fireworks devices, and labeling requirements for consumer fireworks. 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 theme parks, may use pneumatic launchers to 

decrease emissions from propellant charges. 

Future Control Options: 

• Cities and municipalities could pass ordinances that limit or prohibit the use of 

fireworks during periods of unhealthy air quality. 

• The District could adopt regulations that require facilities to use pneumatic launchers 

and other abatement measures to reduce emissions from fireworks and pyrotechnic 

displays. 
San Joaquin Valley Unified Air Pollution 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 combination with other sources, can in some 

circumstances be potentially significant sources of air pollutant emissions. For this 

reason, reasonable precautions are taken to minimize exposures to emissions from 

fireworks displays. Such precautions include 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 fireworks displays to be integral to significant, 

traditional July 4 events. Air quality data associated with July 4 events is flagged to 

be excluded, similar to exceptional 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 suggestions to further improve control options, 

within legal limitations set by state law. 

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

Projected Reductions: 

Emission reductions will be calculated based 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 

SO2 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 

SO2 NQ NQ NQ NQ NQ NQ NQ 
San Joaquin Valley Unified Air Pollution 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 (MDV); 750-XXX-XXXX (MCY) 

 The above baseline emission inventory reflects the emissions for vehicles involved in 

commuting to work at employers of over 100 employees. 

Current Control: 

The Metropolitan Planning Organizations in the San Joaquin Valley have been very 

proactive in encouraging ride sharing. And while some municipalities have had 

incredible success, the efforts still remain voluntary in nature and limited in scope. Trip 

reduction programs have the potential to achieve significant reductions in vehicle miles 

traveled (VMT). 

Future Control Options: 

• Organize and use incentives to achieve more participation, both private and public, 

in trip reduction programs.

• Emphasize trip reduction programs using the 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 private and public Spare the Air Employer 

Partners from Stockton to Arvin, who demonstrate their commitment to improving air 

quality by their implementation of VMT reduction activities. 

• Adopt a rule requiring employer-based trip reduction programs. 
San Joaquin Valley Unified Air Pollution 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 sites 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 mandatory 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 Division 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 businesses employing at least 100 people, as 

described further by Section 40601(d)(1 & 2), to establish rideshare programs. 

• With the anticipated doubling of the Valley’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 

SO2 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 

SO2 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 Pollution Control District April 30, 2008

 Appendix I: Candidate Control Measures 

2008 PM2.5 Plan 

Appendix I-82 

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