San Joaquin Valley Unified Air Pollution 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		

SJVUAPCD	

 

 
San Joaquin Valley Unified Air Pollution 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 Pollution 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 Control Measures and Most Stringent 

Measures 

The best available control measures (BACM) and most stringent measures (MSM) 

analyses conducted for this 2015 Plan for the 1997 PM2.5 Standard (2015 PM2.5 Plan) 

are the first such analyses performed for PM2.5 and its precursors in the nation. 

Maricopa County in Arizona is the only other area that has conducted BACM and MSM 

demonstrations to comply with federal Clean Air Act (CAA) Title 1, Part D Subpart 4 

(Subpart 4) requirements as a Serious PM10 nonattainment area. 

PM2.5 and its precursors are already being extensively controlled in the San Joaquin 

Valley (Valley); every feasible opportunity identified to reduce these emissions is 

already being implemented as soon as practicable. While the District already 

implements the most stringent control program in the nation through its existing 

planning and regulatory efforts, this plan leaves no stone unturned in evaluating 

additional emissions reductions opportunities that might qualify as BACM and MSM. 

5.1 BACM DEFINED 

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 attainment 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 regulatory control measures satisfy the U.S. 

Environmental Protection Agency (EPA) BACM requirements. 

EPA defines a BACM-level of control as: 

 The maximum degree of emissions reductions achievable from a source or 

source category, which is determined on a case-by-case basis considering 

energy, economic and environmental impacts.2

 

 More stringent than reasonably available control measure (RACM) standards, but 

less stringent than the lowest achievable 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 extensive 

implementation of RACM measures (i.e. paving more unpaved roads, 

strengthening components of a smoke management system (SMS) program, 

etc.)4

 

1

 Clean Air Act Subpart 4 Section 189(b)(1)(B). 

2

 Environmental Protection Agency (EPA). 1994 Addendum to the General 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 Pollution 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 BACT similarly to BACM as an emission 

limitation based on the, "maximum degree of reduction of each pollutant emitted 

from or which results from any major emitting facility, which the permitting 

authority, on a case-by-case basis, taking into account energy, environmental, 

and economic impacts and other costs, determines is achievable for such facility 

through application of production processes and available methods, systems, 

and techniques.” BACT is also at least as stringent as new source performance 

standards (NSPS) and national emissions standards for hazardous air pollutants 

(NESHAPs).5

BACM must be implemented within 4 years after an area is reclassified as Serious 

nonattainment, with the exception of source categories that EPA has determined do not 

contribute significantly to exceedances of the federal PM2.5 standards. 6

5.2 MSM DEFINED 

As a Serious nonattainment area, the Valley would have until December 31, 2015 to 

attain the 1997 PM2.5 air quality standards. As demonstrated in Chapter 4 and 

Appendix A of this 2015 PM2.5 Plan, the Valley will not attain the standard by 

December 31, 2015; as such, the District is requesting an extension 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 Serious nonattainment area, 

provided certain criteria are met. One of those criteria requires the District to, 

“Demonstrate to the satisfaction of the Administrator that the plan for the area includes 

the most stringent measures (MSM) that are included in the implementation 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, similarly to BACM, the definition of a MSM is the 

maximum degree of emission reduction that has been required or achieved from a 

source or source category in other 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

5.3 BACM/MSM EVALUATION PROCESS 

As previously discussed, the Maricopa County PM10 Serious nonattainment area is the 

only other area in the nation that has conducted a BACM and MSM analysis to comply 

with Subpart 4 requirements. Within EPA’s Technical Support Document (TSD) for 

 

5

 EPA. 1994 Addendum to the General Preamble, p. 42009. 

6

 EPA. Proposed Approval and Promulgation of Implementation Plans; Arizona—Maricopa County PM-10 

Nonattainment Area; Serious Area 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 PM10 Nonattainment Area. 2001, p. 31. 9

 EPA TSD for Maricopa County PM10 Nonattainment Area. 2001, p. 237. 
San Joaquin Valley Unified Air Pollution 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 Plan,10 EPA defined the 

processes for evaluating whether an attainment plan satisfies BACM and/or MSM 

requirements. Recognizing the similarity between the BACM and MSM requirements, 

EPA defines the MSM evaluation process 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 existing 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 of various source categories on PM2.5 

concentrations over the air quality standard to determine which sources are 

significant and which sources are de minimis (less than significant) for the 

purposes of adopting BACM and MSM. 

More source categories should be subject to the MSM analysis than those 

subject to a BACM analysis by lowering the threshold for what is considered a de 

minimis source category.12 What constitutes a de minimis source category for 

BACM is dependent upon the specific facts of the nonattainment problem under 

consideration. According to EPA, one means of determining an appropriate de 

minimis level is to determine if applying MSM to the proposed de minimis source 

categories would meaningfully expedite attainment. If it does, then the 

established de minimis level is too high, and if it does not, then the de minimis 

level is appropriate. 

Section 5.4 presents the calculations for determining the de minimis thresholds 

for sources of PM2.5, NOx, and SOx emissions. 

3. Identify potential BACM and MSM in other implementation plans or used in 

practice in other states for each significant source category, and for each 

measure evaluate the technological and economic feasibility for the area, as 

necessary (Appendix C). 

a. Technological feasibility13 – This analysis determines if the new control 

can be integrated with the existing controls without reducing or delaying 

the emission reductions from the existing control. If it cannot, then it 

would not be considered to be technologically feasible for the area unless 

the emission benefit of the new measure is substantially greater than the 

existing measure. 

 

10 EPA. Technical Support Document (Notice of Proposed Rulemaking on the Serious Area PM-10 State 

Implementation Plan for the Maricopa County PM-10 Nonattainment Area Provisions for Attaining the 24-Hour 

Standard and Contingency Measures). (2001, September 14). 11 EPA Technical Support Document for Maricopa County PM10 Nonattainment Area. 2001, pp. 237-238 12 EPA. Technical Support Document (Notice of Proposed Rulemaking on the Serious Area PM-10 State 

Implementation Plan for the Maricopa County PM-10 Nonattainment Area Provisions for Attaining the 24-Hour 

Standard and Contingency Measures). (2001, September 14). 13 EPA. Technical Support Document for Maricopa County PM10 Nonattainment Area. 2001, p. 34. 
San Joaquin Valley Unified Air Pollution 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 feasibility14 – If the potential control is determined to be 

technologically feasible, it is then evaluated for economic feasibility. 

The District has evaluated the economic feasibility of various control 

measures by conducting cost effectiveness analyses within Appendix C of 

this 2015 PM2.5 Plan. A cost effectiveness analysis examines the added 

cost, in dollars per year, of the control technology or technique, divided by 

the emissions reductions achieved, in tons per year. Within the Maricopa 

County TSD, EPA cautions that they have not established a general guide 

for evaluating when a measure is economically infeasible, but will instead 

address the issue on a case-by-case basis as needed. 

4. Compare potential BACM/MSM for each significant source category against the 

control measures, if any, already adopted for that source category (Appendix C). 

5. Provide for the adoption of any BACM/MSM that is more stringent than existing 

similar local measures and provide for implementation as expeditiously as 

practicable or, in lieu of adoption, provide a reasoned justification for rejecting the 

potential MSM, i.e., why such measures cannot be feasibly implemented in the 

area (Appendix C). 

Using the EPA defined BACM/MSM process above, emission control requirements for 

stationary and area source categories were evaluated in Appendix C to determine if 

they satisfy both BACM and MSM requirements or if there are any technologically and 

economically feasible technologies or practices that could further reduce PM2.5 and 

precursor emissions for sources in the Valley. 

5.4 DE MINIMIS THRESHOLD FOR DETERMINING SIGNIFICANT SOURCE 

CATEGORIES 

As described in the previous section, BACM and MSM are required for all categories of 

sources in Serious nonattainment areas unless the State adequately demonstrates that 

a particular source category does not contribute significantly to nonattainment of the 

PM2.5 NAAQS. Using modeling data from this 2015 PM2.5 Plan, the calculations 

below were used to quantify the impact of various source categories on PM2.5 

concentrations over the federal air quality standards to determine which sources are 

significant and which sources are de minimis for the purposes of adopting BACM and 

MSM. The sections below outline the significance determination approach used and 

summarize which source categories are considered significant based on the de minimis 

thresholds. 

 

14 EPA. Technical Support Document for Maricopa County PM10 Nonattainment Area. 2001, p. 34. 
San Joaquin Valley Unified Air Pollution 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 guidance that was used to 

implement the PM10 standard. For the PM10 standard, guidance specifies that sources 

are considered significant and are required to have BACM and MSM controls if they 

contribute 1 μg/m3 PM10 out of an annual PM10 standard of 50 μg/m3. Applying this 

guidance to PM2.5, the PM10 significance ratio is applied to the annual PM2.5 standard 

to estimate the level considered significant requiring BACM and MSM controls. 

 1 μg/m3 / 50 μg/m3 = X μg/m3 / 15 μg/m3 

 X = 0.3 μg/m3

PM2.5 is very complex with many species and associated emissions contributing to its 

formation. A first step is to determine whether an individual species is significant. If a 

species is determined to be significant, then a de minimis threshold needs to be 

established for the pollutant. 

5.4.1.2 Significant Species 

Available speciation data collected from 2011 through 2013 was used to determine 

which PM2.5 species are significant. In the Valley, four speciation sites are operated, 

one each in Bakersfield, Visalia, Fresno and Modesto. The composition for each site 

was applied to the highest design value in the area related to that speciation site. The 

highest concentration from all the sites was used to establish the significance level. As 

shown in Table 5-1, all species are considered significant in relationship to the 

0.3 μg/m3 threshold established above. 

Table 5-1 PM2.5 Significance Thresholds (μg/m3) 

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 0.6 

 
San Joaquin Valley Unified Air Pollution 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 baseline emission inventory. Any source that exceeds 

the significance emission level is assumed to contribute 0.3 μg/m3

 of PM2.5 and would 

need to be evaluated for BACM and MSM controls. The equation to establish the 

significant emission level is as follows: 

Significant emissions level = (0.3 μg/m3 / significant level in μg/m3) x Basin-wide 2012 

emissions 

The above PM2.5 species will be correlated to the following emission inventory 

categories: 

 5% of organic carbon (OC) will be considered secondary organic aerosolsvolatile organic carbon (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 & elements-directly emitted PM2.5 combustion 

emissions 

Sulfur Oxide (SOx) Emissions 

SOx emissions contribute to the formation of ammonium sulfate. Per the equation 

below, the amount of emissions that cause at least a 0.3 μg/m3

 impact on air quality for 

SOx is 1.0 tpd. 

Significant SOx emissions level = (0.3 μg/m3 / 2.4 μg/m3

) 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 that cause at least a 0.3 μg/m3

 impact on air quality for 

NOx is 13.1 tpd. 

Significant NOx emissions level = (0.3 μg/m3 / 7.6 μg/m3

) x 332 tpd NOx 

= 13.1 tpd NOx 

PM2.5 Emissions 

PM2.5 emissions contribute to the remaining species, dust, OC, EC, and element 

species. It is appropriate to separate the dust and combustion emissions. Per the 

equation below, the amount of emissions that cause at least a 0.3 μg/m3 impact on air 

quality for PM2.5 dust is 4.0 tpd PM2.5 dust emissions. Also, per the equation below, 

the amount of emissions that cause at least a 0.3 μg/m3

 impact on air quality for PM2.5 

combustion is 1.4 tpd PM2.5 combustion emissions. 

 
San Joaquin Valley Unified Air Pollution 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/m3 / 2.4 μg/m3) x 32.3 tpd PM2.5 dust 

= 4.0 tpd PM2.5 dust emissions 

Significant PM2.5 combustion level = (0.3 μg/m3 / 7.2 μg/m3) 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 which source categories in the Valley are above and 

which source categories in the Valley are below de minimis based on the de minimis 

thresholds calculated above and the emissions inventories presented in Appendix B. 

There are only six source 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 the purpose of satisfying 

BACM/MSM requirements. However, within Appendix C of this 2015 PM2.5 Plan, the 

District has still conducted full control measure evaluations for all of the rules and 

source categories listed in Table 5-2. 

Table 5-2 Valley Source Category De Minimis Determinations (using 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 Yes 
San Joaquin Valley Unified Air Pollution 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 Trackout15 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 Operations16 SC 007 N/A N/A N/A N/A 

Agricultural Material Screening/Shaking 

Operations17 SC 008 N/A N/A N/A N/A 

Tub Grinding18 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 included 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 Hulling/Shelling Operations). 17 The emissions inventory for SC 008 (Agricultural Material Screening/Shaking Operations) is accounted for in other 

control measure source categories. 

18 The emissions generated by the engines of the tub grinders are accounted for in the the emissions inventory for 

Rule 4702 (Internal Combustion Engines). The fugitive particulate emissions from these units are accounted for as a 

part of the stationary and area inventory. 
San Joaquin Valley Unified Air Pollution 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 

5.5 DISTRICT BACM AND MSM 

Based on the analyses conducted in Appendix C, the District currently has in place the 

Best Available Control Measures and Most Stringent Measures feasible and did not 

identify any additional technologically feasible and cost effective control measures. 

Therefore, the District meets or exceeds both BACM and MSM requirements for all 

stationary and area source categories. 

5.6 ARB BACM AND MSM 

Based on the analysis conducted in Appendix D, ARB did not identify any additional 

technologically feasible and cost effective control measures that would qualify as BACM 

or MSM. The ARB currently has in place the most stringent measures feasible to 

implement in the Valley and therefore meets or exceeds both BACM and MSM 

requirements for mobile source categories. 

 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

5-10 Chapter 5: Best Available Control Measures and Most Stringent Measures 

2015 Plan for the 1997 PM2.5 Standard 

This page intentionally blank.