San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

Chapter 5: Best Available Control Measures and Most Stringent Measures 2015 Plan for the 1997 PM2.5 Standard 

# Chapter 5

Best	Available	Control	Measures	and	Most	Stringent Measures

2015 Plan for the 1997 PM2.5 Standard SJVUAPCDSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

Chapter 5: Best Available Control Measures and Most Stringent Measures 2015 Plan for the 1997 PM2.5 Standard This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

5-1 Chapter 5: Best Available Control Measures and Most Stringent Measures 2015 Plan for the 1997 PM2.5 Standard 

### Chapter 5: Best Available Contro l Measures and Most Stringent Measures

The best available control meas ures (BACM) and most stringent m easures (MSM) analyses conducted for this 2015 Plan for the 1997 PM2.5 Standard ( 2015 PM2.5 Plan ) are the first such analyses per formed for PM2.5 and its precurs ors in the nation. Maricopa County in Arizona is t he only other area that has cond ucted BACM and MSM demonstrations to comply with feder al Clean Air Act (CAA) Title 1, Part D Subpart 4 (Subpart 4) requirements as a Ser ious PM10 nonattainment area.

PM2.5 and its precursors are alr eady being extensively controll ed in the San Joaquin Valley (Valley); every feasible opportunity identified to reduc e these emissions is already being implemented as soon as practicable. While the Di strict already implements the most stringent cont rol program in the nation thr ough its existing planning and regulator y efforts, this plan leaves no stone untu rned in evaluating additional emissions reductions op portunities that might qualif y as BACM and MSM.

BACM DEFINED 5.1

As discussed in Chapter 1 of this 2015 Plan for the 1997 PM2.5 Standard ( 2015 PM2.5 Plan) , one of the requirements for a Serious nonattainment area atta inment plan under CAA Subpart 4 is to demonstrate, “ Provisions to assure that the best available control measures (BACM), including best available control technology (BACT) for stationary sources, for the control of direct PM2. 5 and PM2.5 precursors shall be implemented no later than four years after the area is reclassified .” 1 As such, this 2015 PM2.5 Plan demonstrates that the District’s r egulatory control measures sa tisfy the U.S. Environmental Protection Agen cy (EPA) BACM requirements.

EPA defines a BACM-level of control as:

 The maximum degree of emissions r eductions achievable from a s ource or source category, which is determi ned on a case-by-case basis co nsidering energy, economic and environmental impacts. 2

 More stringent than reasonably ava ilable control measure (RACM ) standards, but less stringent than the lowest ach ievable emission rate (LAER), which doesn’t take into consideration the cost effectiveness of implementing a particular control

measure. 3

 Additive to RACM, as BACM will generally consist of a more ext ensive implementation of RACM measures (i.e. paving more unpaved roads

, strengthening components of a s moke management system (SMS) pro gram, etc.) 4

1 Clean Air Act Subpart 4 Section 189(b)(1)(B).
2 Environmental Protect ion Agency (EPA). 19 94 Addendum to the Ge neral Preamble, p. 42010.
3 EPA. 1994 Addendum to the General Preamble, p. 42010.
4 EPA. 1994 Addendum to the General Preamble, p. 42013.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

5-2 Chapter 5: Best Available Control Measures and Most Stringent Measures 2015 Plan for the 1997 PM2.5 Standard  Inclusive of BACT. EPA defines B ACT similarly to BACM as an e mission limitation based on the, "maxi mum degree of reduction of each p ollutant emitted from or which results from any m ajor emitting facility, which t he permitting authority, on a case-by-case basis, taking into account energy, environmental, and economic impacts and other cos ts, determines is achievable for such facility through application of production processes and available metho ds, systems, and techniques.” BACT is also at least as stringent as new sou rce performance standards (NSPS) and national e missions standards for hazardous air pollutants (NESHAPs). 5

BACM must be implemented within 4 years after an area is reclas sified as Serious nonattainment, with the exception of source categories that EPA has determined do not contribute significantly to exc eedances of the federal PM2.5 st andards. 6

MSM DEFINED 5.2

As a Serious nonattainment ar ea, the Valley would have until De cember 31, 2015 to attain the 1997 PM2.5 air qualit y standards. As demonstrated i n Chapter 4 and Appendix A of this 2015 PM2.5 Plan , the Valley will not a ttain the standard by December 31, 2015; as such, the District is requesting an exten sion of the attainment date with this 2015 PM2.5 Plan . Pursuant to CAA Subpart 4, EPA may grant one extension of the attainment date of up to five years for a Seri ous nonattainment area, provided certain criteria are m et. One of those criteria requi res the District to, “Demonstrate to the satisfaction of the Admi nistrator that the plan for the area includes the most stringent measures (MSM) that are included in the implem entation plan of any State, or are achieved in practice in any State, and can feasibly be implemented in the area.” 7 EPA further clarifies that, simi larly to BACM, the definition of a MSM is the maximum degree of emission reduct ion that has been required or achieved from a source or source category in ot her SIPs or in practice in other states and can be feasibly implemented in the area. 8 Unlike BACM, the CAA does not specify an implementation deadline for MSM ; EPA states that all MSM should be implemented as expeditiously as practicable. 9

BACM/MSM EVALU ATION PROCESS 5.3

As previously discussed, the Mari copa County PM10 Serious nonat tainment area is the only other area in the nation t hat has conducted a BACM and MSM analysis to comply with Subpart 4 requirements. Wi thin EPA’s Technical Support Do cument (TSD) for

5 EPA. 1994 Addendum to the General Preamble, p. 42009.
6 EPA. Proposed Approval and P romulgation of Im plementation Plan s; Arizona—Maricopa County PM-10 Nonattainment Area; Serious Ar ea Plan for Attainment of the 24- Hour PM-10 Standard and Contingency Measures. 66 FR 50255.
7 Clean Air Act Subpart 4 Section 189(b)(1)(B).
8 EPA TSD for Maricopa County PM 10 Nonattainment Area. 2001, p. 31.
9 EPA TSD for Maricopa County PM 10 Nonattainment Area. 2001, p. 237.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

5-3 Chapter 5: Best Available Control Measures and Most Stringent Measures 2015 Plan for the 1997 PM2.5 Standard evaluation of the Maricopa County Serious Area Nonattainment Pl an, 10 EPA defined the processes for evaluating whether an attainment plan satisfies B ACM and/or MSM requirements. Recognizing the similarity between the BACM and MSM requirements, EPA defines the MSM evaluation pr ocess as the same as the BACM evaluation process, but with one additional step, to compare the potential MSM against the measures already adopted in the area to determine if the existi ng measures are most stringent. The process is as follows: 11

1. Develop a detailed emissions inventory of PM2.5 sources and source categories (Appendix B).

2. Model to evaluate the impact o f various source categories on PM2.5 concentrations over the air qua lity standard to determine which sources are significant and which sources ar e de minimis (less than signifi cant) for the purposes of adopting BACM and MSM.

More source categories should be subject to the MSM analysis th an those subject to a BACM analysis by low ering the threshold for what i s considered a de minimis source category. 12 What constitutes a de mini mis source category for BACM is dependent upon the specif ic facts of the nonattainment problem under consideration. According to EPA, one means of determining an a ppropriate de minimis level is to determine if applying MSM to the proposed d e minimis source categories would meaningfully e xpedite attainment. If it does, then the established de minimis level is too high, and if it does not, t hen the de minimis level is appropriate.

Section 5.4 presents the calcul ations for determining the de mi nimis thresholds for sources of PM2.5, NOx, and SOx emissions.

3. Identify potential BA CM and MSM in other implementation plan s or used in practice in other states for eac h significant source category, and for each measure evaluate the technologica l and economic feasibility for the area, as necessary (Appendix C).

a. Technological feasibility 13 – This analysis determines if the new control can be integrated with the existing controls without reducing o r delaying the emission reductions from t he existing control. If it canno t, then it would not be considered to be te chnologically feasible for the area unless the emission benefit of the new meas ure is substantially greate r than the existing measure.

10 EPA. Technical Support Document (Notice of Proposed Rulemaking on the Serious A rea PM-10 State Implementation Plan for the Mari copa County PM-10 Nonattainment Area Provisions for Attaining the 24-Hour Standard and Cont ingency Measures). ( 2001, September 14).
11 EPA Technical Support Document fo r Maricopa County PM10 Nonatt ainment Area. 20 01, pp. 237-238
12 EPA. Technical Support Document (Notice of Proposed Rulemaking on the Serious A rea PM-10 State Implementation Plan for the Mari copa County PM-10 Nonattainment Area Provisions for Attaining the 24-Hour Standard and Cont ingency Measures). ( 2001, September 14).
13 EPA. Technical Support Documen t for Maricopa County PM10 Nonat tainment Area. 2001, p. 34.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

5-4 Chapter 5: Best Available Control Measures and Most Stringent Measures 2015 Plan for the 1997 PM2.5 Standard b. Economic feasibility 14 – If the potential contro l is determined to be technologically feasible, it is then evaluated for economic fea sibility.

The District has evaluated the economic feasibility of various control measures by conducting cost effectiveness analyses within Appen dix C of this 2015 PM2.5 Plan . A cost effectiveness analysis examines the added cost, in dollars per year, of t he control technology or techniq ue, divided by the emissions reductions achieved , in tons per year. Within th e Maricopa County TSD, EPA cautions that t hey have not established a gener al guide for evaluating when a measure is economically infeasible, but w ill instead address the issue on a case-by-case basis as needed.

4. Compare potential BA CM/MSM for each significant source categ ory against the control measures, if any, already adopted for that source categ ory (Appendix C).

5. Provide for the adoption of any BACM/MSM that is more string ent than existing similar local measures and provid e for implementation as expedi tiously as practicable or, in lieu of adopt ion, provide a reasoned justifi cation for rejecting the potential MSM, i.e., why such measures cannot be feasibly imple mented in the area (Appendix C).

Using the EPA defined BACM/MSM process above, emission control requirements for stationary and area source categor ies were evaluated in Appendi x C to determine if they satisfy both BACM and MSM r equirements or if there are any technologically and economically feasible technologies or practices that could furt her reduce PM2.5 and precursor emissions for sources in the Valley.

DE MINIMIS THRESHOLD FOR DE TERMINING SIGNIFICANT SOURCE 5.4 CATEGORIES

As described in the previous sec tion, BACM and MSM are required for all categories of sources in Serious nonattainme nt areas unless the State adequat ely demonstrates that a particular source category does not contribute significantly to nonattainment of the PM2.5 NAAQS. Using m odeling data from this 2015 PM2.5 Plan , the calculations below were used to quantify the impact of various source catego ries on PM2.5 concentrations over the federal air quality standards to determ ine which sources are significant and which sources ar e de minimis for the purposes o f adopting BACM and MSM. The sections below outli ne the significance determination approach used and summarize which source categories are considered significant ba sed on the de minimis thresholds.

14 EPA. Technical Support Documen t for Maricopa County PM10 Nonat tainment Area. 2001, p. 34.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

5-5 Chapter 5: Best Available Control Measures and Most Stringent Measures 2015 Plan for the 1997 PM2.5 Standard 5.4.1 Significance Determination Approach

5.4.1.1 U.S. EPA Guidance For PM2.5 implementation, EPA has directed states to follow gui dance that was used to implement the PM10 standard. For the PM10 standard, guidance s pecifies that sources are considered signifi cant and are required to have BACM and MS M controls if they contribute 1 μg/m 3 PM10 out of an annual PM 10 standard of 50 μg/m 3 . Applying this guidance to PM2.5, the PM10 signi ficance ratio is applied to th e annual PM2.5 standard to estimate the level consider ed significant requiring BACM and MSM controls.

1 μg/m 3 / 50 μg/m 3 = X μg/m 3 / 15 μg/m 3

X = 0.3 μg/m 3

PM2.5 is very complex with many species and associated emission s contributing to its formation. A first step is to det ermine whether an individual species is significant. If a species is determined to be si gnificant, then a de minimis thre shold needs to be established for the pollutant.

5.4.1.2 Significant Species Available speciation data co llected from 2011 through 2013 was used to determine which PM2.5 species are signifi cant. In the Valley, four speci ation sites are operated, one each in Bakersfield, Visalia , Fresno and Modesto. The comp osition for each site was applied to the highest design value in the area related to that speciation site. The highest concentration from all t he sites was used to establish the significance level. As shown in Table 5-1, all species are considered significant in r elationship to the 0.3 μg/m3 threshold established above.

Table 5-1 PM2.5 Signi ficance Thresholds (μg/m 3 )

Bakersfield Visalia Clovis Modesto Significant level

2013 DV 17.3 16.6 16.4 13.3 n/a Ammonium Nitrate 7.1 7.6 6.4 5.0 7.6 Ammonium Sulfate 2.4 2.1 1.9 1.6 2.4 Organic Carbon 4.1 4.7 5.5 4.5 5.5 Elemental Carbon 1.0 0.7 1.1 0.8 1.1 Dust 2.4 1.1 1.1 0.8 2.4 Elements 0.4 0.4 0.4 0.6 0.6San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

5-6 Chapter 5: Best Available Control Measures and Most Stringent Measures 2015 Plan for the 1997 PM2.5 Standard The next step is to establish a significant emission level for each pollutant associated with the species using the 2012 bas eline emission inventory. A ny source that exceeds the significance emission level is assumed to contribute 0.3 μg /m 3 of PM2.5 and would need to be evaluated for BACM and MSM controls. The equation t o establish the significant emission level is as follows:

Significant emissions level = (0.3 μg/m 3 / significant level in μg/m 3 ) x Basin-wide 2012 emissions

The above PM2.5 species will be correlated to the following emi ssion inventory categories:

 5% of organic carbon (OC) will be considered secondary organic aerosolsvolatile organic carb on (VOC) emissions

 Am Sulfate-SOx and ammonia emissions

 Am Nitrate-NOx and ammonia emissions

 Dust-directly emitted PM2.5 from dust sources

 Elemental Carbon (EC) + OC & ele ments-directly emitted PM2.5 c ombustion emissions

Sulfur Oxide (SOx) Emissions SOx emissions contribute to the formation of ammonium sulfate. Per the equation below, the amount of emissions t hat cause at least a 0.3 μg/m 3 impact on air quality for SOx is 1.0 tpd.

Significant SOx emissions level = (0.3 μg/m 3 / 2.4 μg/m 3 ) x 8.1 tpd SOx = 1.0 tpd SOx

Nitrogen Oxide (NOx) Emissions NOx emissions contribute to the formation of ammonium nitrate. Per the equation below, the amount of emissions t hat cause at least a 0.3 μg/m 3 impact on air quality for NOx is 13.1 tpd.

Significant NOx emissions level = (0.3 μg/m 3 / 7.6 μg/m 3 ) x 332 tpd NOx = 13.1 tpd NOx

PM2.5 Emissions PM2.5 emissions contribute to th e remaining species, dust, OC, EC, and element species. It is appropriate to separ ate the dust and combustion emissions. Per the equation below, the amount of emi ssions that cause at least a 0 .3 μg/m 3 impact on air quality for PM2.5 dust is 4.0 t pd PM2.5 dust emissions. Also, per the equation below, the amount of emissions that c ause at least a 0.3 μg/m 3 impact on air quality for PM2.5 combustion is 1.4 tpd PM 2.5 combustion emissions.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

5-7 Chapter 5: Best Available Control Measures and Most Stringent Measures 2015 Plan for the 1997 PM2.5 Standard Significant PM2.5 dust level = (0.3 μg/m 3 / 2.4 μg/m 3 ) x 32.3 tpd PM2.5 dust = 4.0 tpd PM2.5 dust emissions

Significant PM2.5 combustion level = (0.3 μg/m 3 / 7.2 μg/m 3 ) x 33.7 tpd PM2.5 combustion emissions = 1.4 tpd PM2.5 combustion emissions

5.4.2 De Minimis Thresholds

Table 5-2 below demonstrates wh ich source categories in the Val ley are above and which source categories in the Va lley are below de minimis base d on the de minimis thresholds calculated above and t he emissions inventories prese nted in Appendix B. There are only six so urce categories that exceed the de minimis thresholds for PM2.5, NOx, or SOx emissions in the Valley. The CAA does not require a control measure evaluation for the remaining de minimis source categories for t he purpose of satisfying BACM/MSM requirements. Howev er, within Appendix C of this 2015 PM2.5 Plan, the District has still conducted full control measure evaluations f or all of the rules and source categories lis ted in Table 5-2.

Table 5-2 Valley Source Categor y De Minimis Determinations (us ing 2012 data)

Source Category Rule Number (if any) Emissions of Qualifying Pollutant(s) (tpd) Above de minimis? PM2.5 NOx SOx Open Burning 4103 2.27 1.61 0.05 Yes Reduction of Animal Matter 4104 0.03 0.00 0.00 No Prescribed Burning and Hazard Reduction Burning 4106 0.76 0.07 0.03 No

Particulate Matter Emissions from the Incineration of Combustible Refuse 4203 0.00 0.00 0.00 No

Cotton Gins 4204 0.22 0.00 0.00 No Fuel Burning Equipment 4301 N/A N/A N/A N/A Boilers, Steam Generators, and Process Heaters Greater than 5.0 MMBtu/hr 4306/432 0 1.27 1.93 0.60 No
Boilers, Steam Generators, and Process Heaters—2.0 to 5.0 MMBtu/hr 4307 0.32 0.49 0.15 No
Boilers, Steam Generators, and Process Heaters—0.075 to less than 2.0 MMBtu/hr 4308 0.61 0.92 0.28 No

Dryers, Dehydrators, and Ovens 4309 0.85 0.20 0.47 No Flares 4311 0.16 0.56 0.33 No Lime Kilns 4313 0.00 0.00 0.00 No Solid Fuel Fired Boilers, Steam Generators, and Process Heaters 4352 0.62 2.69 0.56 No
Glass Melting Furnaces 4354 0.33 6.04 1.96 Yes Conservation Management Practices 4550 YesSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

5-8 Chapter 5: Best Available Control Measures and Most Stringent Measures 2015 Plan for the 1997 PM2.5 Standard Source Category Rule Number (if any) Emissions of Qualifying Pollutant(s) (tpd) Above de minimis? PM2.5 NOx SOx

 Tilling Dust

 Harvest Operations Dust

 Dust from Ag Lands (non-pasture)

 Dust from Pasture Lands 5.17 0.00 0.00 7.28 0.00 0.00 6.15 0.00 0.00 1.09 0.00 0.00 No Commercial Charbroiling 4692 2.84 0.00 0.00 Yes Internal Combustion Engines 4702 0.49 13.06 0.12 No Stationary Gas Turbines 4703 1.22 3.09 0.22 No Sulfuric Acid Mist 4802 0.00 0.00 0.75 No Wood Burning Fireplaces and Wood Burning Heaters 4901 4.48 0.50 0.08 Yes

Residential Water Heaters 4902 0.21 2.21 0.06 No Natural Gas-Fired, Fan-Type Central Furnaces 4905 0.20 2.46 0.06 No
General Requirements 8011 N/A N/A N/A N/A Construction, Demolition, Excavation, Extraction, and Other Earthmoving Activities 8021 1.46 0.00 0.00 No

Bulk Materials 8031 0.04 0.00 0.00 No Carryout and Trackout 15 8041 N/A N/A N/A N/A Open Areas 8051 0.34 0.00 0.00 No Paved and Unpaved Roads 8061 7.59 0.00 0.00 Yes Unpaved Vehicle/Equipment Traffic Areas 8071 0.59 0.00 0.00 No
Agricultural Sources 8081 1.21 0.00 0.00 No Lawn and Garden Equipment SC 001 0.04 0.58 0.00 No Energy Efficiency SC 002 N/A N/A N/A N/A Fireworks SC 003 N/A N/A N/A N/A Sand and Gravel Operations SC 004 0.09 0.00 0.00 No Asphalt/Concrete Operations (Mineral Processes) SC 005 0.82 0.20 0.36 No
Almond Hulling/Shelling Operations SC 006 0.38 0.00 0.00 No Pistachio Hulling/Shelling Operations 16 SC 007 N/A N/A N/A N/A Agricultural Material Screening/Shaking Operations 17 SC 008 N/A N/A N/A N/A
Tub Grinding 18 SC 009 N/A N/A N/A N/A Abrasive Blasting SC 010 0.33 0.00 0.00 No

15 Emissions from Rule 8041 are in cluded in Rule 8061 (Paved and Unpaved Roads).
16 The emissions inventory for SC 007 (Pistachio Hulling/Shelling Operations) is included as part of the emissions inventory for SC 006 (Almond H ulling/Shelling Operations).
17 The emissions inventory for SC 008 (Agricultural Material Scre ening/Shaking Operations) is accounted for in other control measure source categories.
18 The emissions generated by the en gines of the tub grinders are accounted for in the the emissions inventory for Rule 4702 (Internal Combustion En gines). The fugitive particula te emissions from these units are accounted for as a part of the stationary a nd area inventory.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

5-9 Chapter 5: Best Available Control Measures and Most Stringent Measures 2015 Plan for the 1997 PM2.5 Standard DISTRICT BACM AND MSM 5.5

Based on the analyses conducted in Appendix C, the District cur rently has in place the Best Available Control Measures and Most Stringent Measures fea sible and did not identify any additional technologi cally feasible and cost effec tive control measures. Therefore, the Distri ct meets or exceeds both BACM and MSM requ irements for all stationary and area s ource categories.

ARB BACM AND MSM 5.6

Based on the analysis conducted in Appendix D, ARB did not iden tify any additional technologically feasible and cost effective control measures th at would qualify as BACM or MSM. The ARB currently has i n place the most stringent meas ures feasible to implement in the Valley and ther efore meets or exceeds both BAC M and MSM requirements for mobile source categories.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

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