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

Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Appendix C

BACM	and	MSM	for	Stationary	and	Area	Sources	

2015 Plan for the 1997 PM2.5 Standard

SJVUAPCD	

 

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

Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

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C-1 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Appendix C: BACM and MSM for Stationary and Area Sources 

C.i Introduction 

The San Joaquin Valley (Valley) faces significant challenges in meeting National 

Ambient Air Quality Standards (NAAQS). The San Joaquin Valley Air Pollution Control 

District (District) has demonstrated leadership in developing and implementing 

groundbreaking regulatory strategies to reduce emissions. Tough and innovative rules, 

such as those for indirect source review, residential wood burning, glass manufacturing, 

and agricultural burning, have set benchmarks for California and the nation. 

Multiple regulatory control measures have been adopted under the District’s air quality 

attainment plans that reduce particulate matter (PM) that is 2.5 microns or less in 

diameter (PM2.5), including but not limited to commitments made in the 2007 Ozone 

Plan, 2008 PM2.5 Plan, 2012 PM2.5 Plan, and 2013 Plan for the Revoked 1-Hour 

Ozone Standard. All of these commitments serve as control measures that will reduce 

emissions under the 2015 Plan for the 1997 PM2.5 Standard (2015 PM2.5 Plan). 

Under the U.S. Environmental Protection Agency (EPA) policy, there is a preference for 

reliance on control measures that have already been adopted. The 2015 PM2.5 Plan 

regulatory control measures that have already been adopted include both stationary and 

area source control measures, as well as California Air Resources Board (ARB) rules 

for mobile sources. 

Table C-1 below identifies the control measures that the District has already adopted 

and that are contributing to attainment of the 1997 PM2.5 standard. These adopted 

District rules are achieving new emissions reductions after 2012, the base year for this 

plan. Even pre-2012 emissions reductions are contributing, and will continue to 

contribute, to the Valley’s progress toward clean air. 

Table C-1 District Regulations Contributing to Attainment of PM2.5 NAAQS 

Rule # Adopted District Rule Last Adoption/ 

Amendment Date 

4307 Boilers, Steam Generators, and Process Heaters—2.0 

MMBtu/hr to 5.0 MMBtu/hr 5/19/11 

4308 Boilers, Steam Generators, and Process Heaters—0.075 

MMBtu/hr to less than 2.0 MMBtu/hr 11/14/13 

4311 Flares 6/18/09 

4320 Advanced Emission Reduction Options for Boilers, Steam 

Generators, and Process Heaters Greater than 5.0 

MMBtu/hr 

10/16/08 

4354 Glass Melting Furnaces 5/19/11 

4702 Internal Combustion Engines 8/18/11 

4703 Stationary Gas Turbines 9/20/07 

4901 Wood Burning Fireplaces and Wood Burning Heaters 9/18/14 

4902 Residential Water Heaters 3/19/09 

4905 Natural Gas-Fired, Fan-Type Central Furnaces 1/22/15 

9310 School Bus Fleets 9/21/06 

9410 Employer-based Trip Reduction 12/17/09 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-2 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

One of the requirements for a Serious nonattainment area plan under Subpart 4 is to 

demonstrate that the plan includes the best available control measures (BACM) that can 

be feasibly and cost effectively implemented. EPA defines BACM as being more 

stringent than reasonably available control measures (RACM), but less stringent than 

the lowest achievable emission rate (LAER), which does not take into consideration the 

cost effectiveness of implementing a particular control measure.

1

 

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

attain the 1997 PM2.5 standard. As demonstrated in Chapter 2 and Appendix A, the 

Valley will not attain the 1997 PM2.5 standard by the attainment date and is therefore 

requesting an extension of the attainment date. Under Subpart 4, EPA may grant one 

extension of the attainment date of up to five years for a Serious nonattainment area 

provided the attainment plan for that area satisfies several federal requirements, 

including 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. EPA defines MSM as 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.”2

 This 

appendix demonstrates that the control measures in this 2015 PM2.5 Plan satisfy both 

BACM and MSM requirements. 

The analysis in this appendix consists of a literature review and evaluation of emission 

reduction opportunities for a variety of stationary and area source categories. District 

staff in multiple departments with expertise in these various sectors contributed to this 

effort. The evaluations in this appendix capture relevant background information, 

examine potential emission reduction opportunities for technological and economic 

feasibility, and make recommendations for appropriate District actions moving forward. 

This appendix reflects the comprehensive evaluation performed by the District to 

examine the Valley’s various emissions sources and identify any potential BACM or 

MSM for inclusion in this plan. 

C.ii BACM/MSM Evaluation Process 

As discussed in detail in Chapter 5, the District must demonstrate that its rules meet 

both BACM and MSM requirements. 

The Maricopa County PM10 nonattainment area is the only other area in the nation that 

has conducted a BACM and MSM analysis. Within the technical support document 

(TSD) for the Maricopa County Serious Area Nonattainment Plan,3

 EPA defined the 

process for determining BACM and MSM. EPA noted that MSM follows the same 

process for determining BACM, but with one additional step to compare the potential 

MSM against the measures already adopted in the area to determine if the existing 

 

1

 EPA. 1994 Addendum to the General Preamble, p. 10. 2

 EPA. Technical Support Document for Maricopa County PM10 Nonattainment Area. 2001, p. 237. 3

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

C-3 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

measures are most stringent. Because this is the only EPA guidance available for a 

Serious Nonattainment area under Subpart 4 (to evaluate BACM and MSM) at the time 

of the development of this 2015 PM2.5 Plan, the District will follow this process as 

summarized below: 

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 NAAQS to determine which sources are significant and 

which sources are de minimis (less than significant) for the purposes of adopting 

BACM and MSM4 (Chapter 5). 

a. ARB relative response factor (RRF) results demonstrate that the 

significance levels for PM2.5, oxides of nitrogen (NOx), and oxides of 

sulfur (SOx) are as follows (see Chapter 5 for the full calculations): 

i. PM2.5: 1.4 tons per day (tpd) for combustion, 4.0 tpd for dust 

ii. NOx: 13.1 tpd 

iii. SOx: 1.0 tpd 

b. To determine if a particular source category is significant for the purposes 

of adopting BACM and MSM, the 2012 baseline emissions inventory for 

each source category was compared to the significance thresholds above. 

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). 

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 BACM/MSM process summarized above, emission control requirements for 

stationary and area source categories are evaluated to determine if they satisfy both 

BACM and MSM requirements or if there are any potential technologies or practices 

 

4

 EPA stated in the Maricopa County TSD that 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. 

What constitutes a de minimis source category for BACM is dependent upon the specific facts of the nonattainment 

problem under consideration. EPA states that 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 did, then the established de minimis level is too high, and if it did not, then the de minimis level is appropriate. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-4 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

that could further reduce PM2.5 and precursor emissions and prove to be 

technologically and economically feasible for sources in the Valley. 

C.iii Appendix C Organization and Evaluation 

Each control measure evaluation includes a discussion of the rule applicability and rule 

adoption/amendment history; an overview of the source category and affected sources; 

an emissions inventory table for the source category; a regulatory evaluation; a 

technological feasibility and cost effectiveness analysis of any other potential 

BACM/MSM; and a summary of the evaluation findings. The sections below elaborate 

in more detail with respect to the information included within each individual rule 

evaluation. 

Discussion 

This section provides an overview of rule applicability, identifies what types of emissions 

the rule controls, provides the rule adoption/amendment history, and discusses 

additional pertinent details, as necessary. This section is not included for the source 

categories where there is no current District prohibitory rule.

Source Category 

This section discusses what types of units, industries, or operations are included in the 

respective source category.

Emissions Inventory 

Each emissions inventory table lists the annual average and wintertime average 

(November through April) PM2.5, NOx, and SOx emissions for the respective source 

category for the years 2012 through 2020. The data provided in this section is a 

compilation of the data sources identified in the emission inventory appendix. See 

Appendix B (Emission Inventory) for additional information. 

This section also includes a significance discussion, which compares the emissions 

from the respective source category to the applicable significance/de minimis thresholds 

developed by ARB, as shown in Chapter 5 of the plan. 

Regulatory Evaluation 

As part of the regulatory evaluation, District rules and source categories are compared 

to federal and state air quality regulations and standards, and the regulations and 

standards in other air districts. The following regulations and guidelines are referenced 

in the comparisons: 

 Federal Regulations – Federal regulations include the following regulations and 

guidance documents: 

o Control Techniques Guidelines (CTG)5

o Alternative Control Techniques (ACT)6

 

 

5

 EPA. Control Techniques Guidelines. Retrieved from http://www.epa.gov/groundlevelozone/SIPToolkit/ctgs.html 6

 EPA. Alternative Control Techniques. Retrieved from http://www.epa.gov/groundlevelozone/SIPToolkit/ctgs.html 
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C-5 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

o New Source Performance Standards (NSPS)7

o National Emission Standards for Hazardous Air Pollutants (NESHAP)8

o Maximum Achievable Control Technology (MACT)9

 

 State Regulations – Generally, state regulations are specific to mobile sources 

and consumer products. However, there are some California Health and Safety 

Code (CH&SC) requirements and ARB Airborne Toxic Control Measures 

(ATCM)10 that apply to stationary and area sources. While most of the rules 

evaluated in this 2015 PM2.5 Plan do not have a state regulation associated with 

their source category, any relevant state guidelines are evaluated within this 

section.

 Other Air Districts’ Rules – As agreed to by EPA for the 2009 RACT SIP, the 

rules were also compared to analogous regulations adopted by California’s most 

progressive air districts. Control strategies and measures in other air districts 

and agencies include, but are not limited to the following air districts: 

o South Coast Air Quality Management District (SCAQMD)11

o Bay Area Air Quality Management District (BAAQMD)12

o Sacramento Metropolitan Air Quality Management District (SMAQMD)13

o Ventura County Air Pollution Control District (VCAPCD)14

All potential BACM/MSM identified through this regulatory evaluation were then 

thoroughly evaluated using the following key factors, defined by EPA in the Maricopa 

County TSD, to determine if potential opportunities qualify as BACM/MSM for the 

Valley: 

 Technological feasibility15 – 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 

 

7

 EPA. 40 CFR 60 – Standards of Performance for New Stationary Sources (NSPS). Retrieved from 

http://www.tceq.state.tx.us/permitting/air/rules/federal/60/60hmpg.html 8

 EPA. 40 CFR 61 – National Emission Standards for Hazardous Air Pollutants (NESHAPs). Retrieved from 

http://www.tceq.state.tx.us/permitting/air/rules/federal/61/61hmpg.html 9

 EPA. 40 CFR 63 – Maximum Achievable Control Technology (MACT). Retrieved from 

http://www.tceq.state.tx.us/permitting/air/rules/federal/63/63hmpg.html 10 California Air Resources Board (ARB). Airborne Toxic Control Measures (ATCMs). Retrieved from 

http://www.arb.ca.gov/toxics/atcm/atcm.htm 11 South Coast Air Quality Management District (SCAQMD). Rules and Regulations. Retrieved from 

http://www.aqmd.gov/home/regulations/rules/scaqmd-rule-book/table-of-contents 12 Bay Area Air Quality Management District (BAAQMD). Rules and Regulations. Retrieved from 

http://www.baaqmd.gov/Divisions/Planning-and-Research/Rules-and-Regulations.aspx 13 Sacramento Metropolitan Air Quality Management District (SMAQMD). Rules and Regulations. Retrieved from 

http://www.airquality.org/rules/ 14 Ventura County Air Pollution Control District (VCAPCD). Rules and Regulation. Retrieved from 

http://www.vcapcd.org/Rulebook/RuleIndex.htm 15 EPA. (2001, June 22). Technical Support Document for Maricopa County PM10 Nonattainment Area, p. 34. 

Retrieved from http://www.epa.gov/region9/air/phoenixpm/pdf/tsd.pdf. 
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C-6 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

to be technologically feasible for the area unless the emission benefit of the new 

measure is substantially greater than the existing measure. 

 Economic feasibility16 – 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 this appendix. 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. EPA 

cautions that the threshold for economic feasibility should be addressed on a 

case-by-case basis. 

Additional Emission Reduction Opportunities 

The District reviewed the following areas to identify any additional potential 

BACM/MSM, exclusive of potential BACM/MSM evaluated in the Regulatory Evaluation 

section: 

 Any emission reduction opportunities identified/considered in previously adopted 

District plans that were determined to be beyond reasonably available control 

technology (RACT) at that time. 

 New emission reduction opportunities adopted in California SIPs, SIPs in other 

states, or achieved in practice in other areas. 

All potential BACM/MSM identified were then thoroughly evaluated for technological and 

economic feasibility, as previously defined. The District reviewed staff reports and 

studies from other air districts, EPA technical guidance documents, and applicable 

study data from the scientific community to assist in evaluating the technological and 

economic feasibility of potential BACM/MSM. 

Evaluation Findings 

This section provides a summary of the District’s findings based on the control measure 

evaluation. 

 

 

16 EPA. (2001, June 22). Technical Support Document for Maricopa County PM10 Nonattainment Area, p. 34. 

Retrieved from http://www.epa.gov/region9/air/phoenixpm/pdf/tsd.pdf. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-7 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.iv Ammonia Regulations 

Under Subpart 4 of the federal Clean Air Act (CAA), regions are required to address 

ammonia as a precursor in BACM/MSM analyses unless EPA determines that ammonia 

sources do not contribute significantly to PM concentrations. As demonstrated in 

Appendix A, ammonia emissions controls are not effective in significantly reducing 

ambient PM2.5 concentrations and do not contribute to the Valley’s PM2.5 attainment. 

As such, the District is not required to evaluate its ammonia regulations as part of the 

BACM/MSM analysis for this 2015 PM2.5 Plan. 

Nevertheless, the District has implemented the most stringent controls feasible for local 

sources of ammonia and the Valley’s ammonia emissions have been significantly 

reduced through stringent District regulations which include the following: 

 Rule 4570 (Confined Animal Facilities) 

 Rule 4566 (Organic Material Composting) 

 Rule 4565 (Biosolids, Animal Manure, and Poultry Litter Operations) 

Even though the District is not required to evaluate ammonia as part of this plan, 

Section C.41 (Ammonia Controls) includes a full analysis for the above sources and 

demonstrates that existing requirements meet or exceed BACM and MSM levels of 

control. Therefore, even if ammonia was a significant precursor to PM2.5 

concentrations in the Valley (which they are not), there are no current opportunities for 

additional ammonia emission reductions. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-8 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.1 RULE 4103 OPEN BURNING 

Discussion

The provisions of Rule 4103 apply to open burning conducted in the Valley, with the 

exception of prescribed burning and hazard reduction burning, as defined in Rule 4106 

(Prescribed Burning and Hazard Reduction Burning). The purpose of Rule 4103 is to 

permit, regulate, and coordinate the use of open burning while minimizing smoke 

impacts on the public. 

Rule 4103 was originally adopted on June 18, 1992 and it has been amended several 

times to incorporate state law requirements. In 2003, California Senate Bill (SB) 705 

(CH&SC Section (§) 41855.5 and 41855.6) established a schedule for specific types of 

agricultural material to no longer be openly burned in the field, but provided for a 

postponement of the phase-out where justified by technical and economic impediments. 

The air quality impacts from open burning in the Valley are of significant concern for the 

District and Valley growers; as such, Valley growers have reduced open burning 

through the use of sustainable agricultural practices. Those practices have contributed 

to a significant reduction in PM emissions since 1992. 

The historical cultural practice for disposing of agricultural materials, such as prunings 

and orchard removals, is to burn the materials. Burning agricultural materials provided 

an economically feasible method for the timely disposal of these materials, helped 

prevent the spread of plant diseases, and controlled weeds and pests. As part of 

implementing SB 705 and enhancing the effectiveness of the District’s burn reduction 

efforts, in 2004 the District established the Smoke Management System (SMS), a more 

refined method of authorizing or prohibiting individual burns, based on modeled smoke 

impacts. Rule 4103 and the District’s SMS have reduced the total acreage of 

agricultural materials burned in the Valley to date by more than 80% since 2002. 

Smoke Management System 

The District uses the SMS to manage the Valley’s remaining open burning of 

agricultural crops and materials. The District’s air quality forecasters incorporate 

projected meteorological information and air quality statistical modeling to determine the 

amount and location of agricultural burning that can be allowed without resulting in 

ambient air pollutant concentrations that exceed federal health-based standards. 

Through the results of this daily analysis, the SMS allows the District to manage 103 

burn zones in the Valley through allocating daily burning allowances in each zone based 

on local meteorology, the air quality conditions, the atmospheric holding capacity, the 

amount of burning already approved in a given area, and the potential impacts on 

downwind populations (see Figure C-1). This approach allows the District to better 

distribute air pollutant emissions from open burning temporally and spatially, providing 

flexibility of burn days for growers while minimizing the impact on the public. 

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

C-9 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Figure C-1 Agricultural Burn Zones Defined in the District SMS

Properly managed burning allocations under the existing District SMS ensures that air 

quality and health impacts of open burning of agricultural materials, prescribed burning, 

and hazard reduction burning are minimized to the fullest extent feasible. Under the 

SMS, emissions within a zone are limited to levels below the exceedance threshold of 

any applicable federal ambient air quality standard and burns are not allowed in zones 

on days when exceedances of the federal standards are projected to occur in that zone. 

Additionally, zones directly adjacent to an area where open burning is restricted are also 

allocated zero emissions in an effort to reduce pollutant transport into an area with 

already elevated pollutant concentrations. 

During the wood-burning season from November through February, the District 

implements even tighter open burning restrictions based on the daily residential woodburning declarations issued for the Check Before You Burn program. With the recent 

amendment of Rule 4901, residential wood-burning with unregistered devices is no 

longer allowed when an area’s forecasted PM2.5 concentration is expected to be 

greater than or equal to 20 μg/m3

. This threshold is now lower compared to past years 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-10 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

when it was set at 30 μg/m3.

 To be consistent with the residential wood-burning 

declaration, an area’s burn zones in SMS are allocated zero emissions when residential 

wood-burning is prohibited in that area. Following similar procedures discussed above, 

zones directly adjacent to an area where residential wood-burning is restricted are also 

allocated zero emissions. Under this policy, agricultural burning is placed under tighter 

control during the winter season and burning is only allowed when air quality is 

expected to be below 20 μg/m3, when meteorological conditions are projected to be 

conducive for pollutant dispersion, which is well below the current federal 24-hour 

average PM2.5 standard of 35 μg/m3

. 

Under the SMS, individuals who need to burn their agricultural waste first submit their 

permit request to the District, which includes information regarding the material that 

needs to be burned and the location of the burn project (see attachment for sample burn 

permit). If there are positive air quality and atmospheric dispersion conditions, the 

District allocates a certain amount of emissions to the applicable burn allocation zone. 

The SMS will then automatically call the specified contact’s phone number to notify 

them that burn allocation is available in their zone for their project. Through the phone 

system, the individual can then either notify SMS that they will proceed with their burn or 

hold off until another time. 

Through this process, SMS is able to automatically manage and notify a large number 

of stakeholders in the agricultural community on whether they can proceed with their 

burn project. If there are more requests for burning than there are emissions allocated 

in the system for a day, those individuals will be placed on a waiting list and given 

priority when another burn window opens. 

As agricultural burning projects are occurring across the Valley, District air quality 

enforcement staff inspect the region to observe permitted agricultural burns to ensure 

their practices conform to District regulations. In addition, on days when agricultural 

burning is not permitted, enforcement staff inspect the region to ensure that unpermitted agricultural burning is not occurring and to issue notices of violation (NOVs), 

as needed. 

The continued issuance of burn permits for certain crop categories is not expected to 

cause or substantially contribute to a violation of an applicable federal ambient air 

quality standard because the District follows its SMS procedures. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-11 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Emissions Inventory 

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 2.27 2.27 2.26 2.26 2.25 2.25 2.24 2.24 2.23

NOx 1.61 1.60 1.60 1.59 1.59 1.59 1.58 1.58 1.57

SOx 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05

Winter Average - Tons per day 

PM2.5 3.47 3.46 3.46 3.45 3.44 3.43 3.43 3.42 3.41

NOx 2.44 2.44 2.43 2.42 2.42 2.41 2.41 2.40 2.39

SOx 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.07

As previously stated, the emissions from this source category continue to decline and 

contribute 5.2% of average winter NOx and 5.6% of average winter PM2.5 emitted from 

stationary and area sources in the 2014 emission inventory. District regulatory efforts 

have fostered significant reductions in emissions from this source category. 

As detailed in Chapter 5, the significance threshold for source categories for the 

purpose of evaluating the application of BACM and MSM requirements is 1.4 tons per 

day (tpd) for PM2.5 combustion emissions, 13.1 tpd for NOx, and 1.0 tpd for SOx. As 

identified in the above table, emissions from open burning are lower than the NOx and 

SOx BACM/MSM significance thresholds. Therefore, the Clean Air Act does not require 

a NOx and SOx control measure evaluation for this source category for the purpose of 

satisfying BACM/MSM requirements; however, the District has still conducted a full 

control measure evaluation for Rule 4103. 

How does District Rule 4103 compare to federal and state rules and regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. 

State Regulations 

The following state regulation applies to sources covered under Rule 4103: 

 CH&SC §41850-41866 (Agricultural Burning) 

The District has continued to work closely with the stakeholders to identify economically 

feasible alternatives to open burning of various agricultural materials and to meet its 

legal obligation under the CH&SC. To fulfill the state law requirements, the District has 

implemented the requirements for most crop categories identified in CH&SC §41855.5. 

In addition to those requirements, the state law authorizes the District to postpone the 

burn prohibition dates for specific types of agricultural material if the District makes 

three specific determinations and the Air Resources Board (ARB) concurs. The 

determinations are: (1) there are no economically feasible alternatives to open burning 

for that type of material; (2) open burning for that type of material will not cause or 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-12 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

substantially contribute to a violation of an air quality standard; and (3) there is no longterm federal or state funding commitment for the continued operation of biomass 

facilities in the Valley or the development of alternatives to burning. 

The District amended Rule 4103 in April 2010 to incorporate CH&SC requirements and 

committed the District to review its determinations for any postponed crops and 

materials at least once every five years. In 2010, the District also evaluated each crop 

category identified in CH&SC §41855.5 to determine any technologically and 

economically feasible alternatives to open burning. After working extensively with 

stakeholders to understand viable alternatives to open burning and the associated 

costs, the District provided recommendations for allowing or prohibiting the open 

burning of agricultural material categories in the District’s 2010 Final Staff Report and 

Recommendations on Agricultural Burning. ARB concurred with the District’s 

determinations and recommendations; however, ARB made a one-time request that the 

District re-visit the 2010 findings after two years to determine if additional reductions in 

open burning were feasible. 

The District revisited its 2010 analysis in 2012 and submitted those findings to ARB. 

The 2012 Report showed that in the two years since the 2010 Report, there had been 

no significant changes in the economic feasibility of various alternatives to agricultural 

burning. The amount of agricultural materials accepted at biomass facilities continued 

to fluctuate based on market conditions and there were no long-term federal or state 

funding commitments for the operation of biomass facilities or development of 

alternatives to burning. EPA finalized approval for Rule 4103 on January 4, 2012 and 

deemed this rule as at least meeting RACT requirements.17 The District most recently 

reevaluated the availability of alternatives to open burning in the 2014 Reasonably 

Available Control Technology Demonstration for the 8-Hour Ozone State 

Implementation Plan (2014 RACT SIP). The District is committed to review its 

determinations for any postponed crops and materials by December of 2015. 

Current Status of Biomass Facilities 

Biomass power plants in the Valley will generally accept agricultural, forestry, 

construction, and urban residues. The power plants burn the material in combustors to 

produce steam and the steam is then used to spin turbines to generate electricity. 

Biomass power plants do not universally accept all agricultural material due to concerns 

that some materials may harm power plant machinery. Several issues have been noted 

concerning the types of material, such as citrus chips, that can be burned by the 

biomass power plants and the amount of agricultural materials that is accepted at the 

plants at any given time. 

Using the orchard removal materials for fuel at the biomass power plant is currently the 

most viable and cost effective alternative to open burning for growers due to available 

 

17 Revisions to the California State Implementation Plan, San Joaquin Valley Unified Air Pollution Control 

District, 75 Fed. Reg. 2, pp 214-217 (2012, January 4). (to be codified at 40 CFR Part 52) 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-13 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

tax credits for biomass facilities and required agricultural offsets for some biomass 

power plants. However, the ability to meet the needs of the agricultural industry in a 

timely and cost effective fashion is a critical factor in any action taken by the District to 

address the biomass industry’s long-term viability as an alternative to open burning. 

Farmers need certainty and timely removal of material so that they do not miss planting 

seasons. In the past, lack of coordination and available storage for biomass fuels has 

led to uncertainty as to when material would be removed from the field. This has been 

a major concern of the agriculture industry. If the process is not optimized, it can 

quickly result in a system that does not meet agriculture’s needs. 

In addition, the reliance on biomass fuel as a primary alternative to open burning is 

somewhat uncertain since there are no long-term federal or state funding commitments 

for biomass facilities in the Valley. In fact, the biomass industry has indicated that given 

current energy policy in California there is concern that biomass power facilities are in 

jeopardy. Many biomass plants in the Valley are nearing the end of their long-term 

contracts with utilities and find themselves in a position where the power that they 

provide is not the type of power that utilities are seeking (base load vs. intermittent) and 

that the prices being offered for new contracts are too low to support their operations. 

Two biomass power plants serving the Valley have shut down due to their inability to 

secure contracts with utilities at rates that are sufficient to sustain their operations. 

Greenleaf Power that operates the Tracy Biomass Plant, located in Tracy, reported that 

they shut down on October 31, 2014 and the Covanta facility located in Mendota was 

shut down in January 2015. Initially, another Covanta facility in Delano had indicated 

that they were likely to shut down, but is now reporting that they were able to secure a 

one-year extension on their current utility contract at the same rate that enables them to 

continue to operate. 

Staff has convened a number of productive meetings with agricultural stakeholders and 

representatives of the biomass industry in order to more fully understand the issues 

faced by the industry and develop a common vision of the future of biomass power 

amongst the stakeholders in the Valley. The meetings have been helpful in forging a 

better working relationship between agriculture representatives and biomass power 

producers and developing consensus on short-term and long-term solutions. 

The District and representatives from agriculture and biomass industries are working to 

develop and pursue specific actions with the legislative branch, utilities, Public Utility 

Commission, CalRecycle, and other government agencies to help level the playing field 

and allow the biomass industry to fairly compete. 

In June 2014, the District’s Governing Board adopted positions on two pieces of 

legislation that impact the biomass industry. The District adopted a position in support 

of AB 2363 (Dahle), which was sponsored by the biomass industry, and would make 

biomass plants more competitive by fully accounting for the costs associated with 

intermittent sources of renewable power (solar and wind) when comparing them to other 

sources of power. AB 2363 was signed by the Governor and will begin to help level the 

renewable energy playing field. The District also took a position in opposition to SB 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-14 Appendix C: BACM and MSM for Stationary and Area Sources 

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1139 (Hueso) that would have given preferential treatment to new geothermal power 

plants by requiring that utilities purchase specified amounts of new geothermal power. 

Ultimately, AB 1139 was not passed by the legislature. 

The District is also working with the stakeholders, including the Federal Department of 

Energy, California Energy Commission, and other partner agencies, to pursue clean 

alternatives to biomass power production for agricultural waste disposal. 

How does District Rule 4103 compare to rules in other air districts? 

BAAQMD 

 Regulation 5 (Open Burning) 

The District evaluated the requirements contained within BAAQMD’s Regulation 5 and 

found no requirements that were more stringent than those already in Rule 4103. 

BAAQMD Regulation 5 was amended on June 19, 2013 to add new fee requirements. 

The amendments did not implement any requirements more stringent than the current 

requirements in District Rule 4103. 

SMAQMD 

 Rule 407 (Open Burning) 

The District evaluated the requirements contained within SMAQMD’s Rule 407 and 

found no requirements that were more stringent than those already in Rule 4103. 

VCAPCD 

 Rule 56 (Open Burning) 

The District evaluated the requirements contained within VCAPCD’s Rule 56 and found 

no requirements that were more stringent than those already in Rule 4103. 

SCAQMD 

 Rule 444 (Open Burning) 

The District evaluated the requirements contained within SCAQMD’s Rule 444 and 

found no requirements that were more stringent than those already in Rule 4103. 

SCAQMD Rule 444 was amended on July 12, 2013 to include beach burning in the rule 

applicability. The amendments apply to sources that do not exist within District’s 

boundaries. Rule 444 also restricts burning on residential wood combustion curtailment 

days. As discussed in detail above, this is a practice that has already been 

implemented within the District. District Rule 4103 is still as stringent as SCAQMD Rule 

444. 

Evaluation Findings 

The District has evaluated all potential control technologies and all control technologies 

achieved in practice in another area or included in another state implementation plan. 

As demonstrated above, Rule 4103 currently has in place the most stringent measures 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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feasible to implement in the Valley and therefore meets or exceeds both BACM and 

MSM requirements for this source category. Therefore, there are no recommendations 

for additional regulatory actions for Rule 4103. 

The District carefully manages agricultural burning with its SMS with even tighter open 

burning restrictions based on the daily residential wood-burning declarations issued 

within the Check Before You Burn program. With the recent amendment of Rule 4901, 

residential wood-burning with unregistered devices is no longer allowed when an area’s 

forecasted PM2.5 concentration is expected to be greater than or equal to 20 μg/m3. 

This threshold is now lower compared to past years when it was set at 30 μg/m3.

 

Burning is only allowed when air quality is forecasted to be below 20 μg/m3, which is 

well below the current federal 24-hour average PM2.5 standard of 35 μg/m3. By 

restricting open burning to this level, impacts to ambient air quality are significantly 

minimized and are not expected to contribute to a violation of the federal PM2.5 

standards. Furthermore, the District continues to consider the economic feasibility of 

burning alternatives on a case-by-case basis and in accordance with the five year 

evaluation period outlined in Rule 4103 with the next evaluation scheduled for 2015. 

Further progress and complete phase-out of agricultural burning requires economically 

feasible alternatives that do not currently exist. Subsidies or preferential utility rates for 

power produced from biomass can serve as measures to enhance the economic 

feasibility of this alternative. Additional research is also needed to identify other 

technologically and economically feasible alternatives. A comprehensive strategy to 

promote these alternatives will also help in meeting renewable power goals and 

standards. As the District continues to develop new attainment plans that address 

increasingly stringent federal air quality standards, the District will continue to evaluate 

potential opportunities to reduce emissions from open burning in the Valley. 

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

C-16 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Figure C-2 Sample Agricultural Burn Permit (Front Page) 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-17 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

(Back Page) 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-18 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.2 RULE 4104 REDUCTION OF ANIMAL MATTER 

Discussion 

Rule 4104 is applicable to any source operation used for the reduction of animal matter. 

Adopted on May 21, 1992, primarily to control pathogens, this rule was amended for 

District rule number reorganization on December 17, 1992. Rule 4104 requires 100% 

VOC capture and a high level of destruction (1,200 degrees for 0.3 seconds). EPA 

finalized approval for Rule 4104 on March 9, 2010 and deemed this rule as being at 

least as stringent, if not more stringent than, RACT requirements. 

Source Category 

The reduction of animal matter includes rendering, cooking, drying, dehydration, 

digesting, evaporating, and protein concentration processes. The emission control 

equipment for these processes generally includes a condenser for VOC control and a 

venturi scrubber or cyclone, followed by either a packed bed scrubber or a thermal 

oxidizer. Blood drying facilities have additional processes controlled by cyclones and a 

baghouse. 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Winter Average - Tons per day 

PM2.5 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

These facilities generally use steam from a boiler (indirect-fired) or a rotary dryer (directfired) for their operations, which generates NOx emissions from these combustion units. 

Combustion units are regulated by other District rules; as such, those emissions are 

controlled by and accounted for as a part of other District rules. 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from this source category are lower than the BACM/MSM 

significance thresholds. Therefore, the Clean Air Act does not require a control 

measure evaluation for this source category for the purpose of satisfying BACM/MSM 

requirements; however, the District has still conducted a full control measure evaluation 

for the reduction of animal matter. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-19 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

How does District Rule 4104 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. 

State Regulations 

There are no state regulations applicable to this source category.

How does District Rule 4104 compare to rules in other air districts? 

SCAQMD 

 Rule 472 (Reduction of Animal Matter) 

The District evaluated the requirements contained within SCAQMD’s Rule 472 and 

found no requirements that were more stringent than those already in Rule 4104. 

BAAQMD 

 Regulation 12 Rule 2 (Rendering Plants) 

The District evaluated the requirements contained within BAAQMD’s Regulation 12 

Rule 2 and found no requirements that were more stringent than those already in Rule 

4104. 

SMAQMD 

 Rule 410 (Reduction of Animal Matter)

The District evaluated the requirements contained within SMAQMD’s Rule 410 and 

found no requirements that were more stringent than those already in Rule 4104. 

VCAPCD 

 Rule 58 (Reduction of Animal Matter)

The District evaluated the requirements contained within VCAPCD’s Rule 58 and found 

no requirements that were more stringent than those already in Rule 4104. 

Additional Emission Reduction Opportunities 

Packed Bed Scrubbers 

The District evaluated the potential opportunity to reduce emissions if facilities were to 

replace their thermal oxidizers with packed bed scrubbers. In certain installations, 

packed bed scrubbers may be more efficient at removing PM from the exhaust and 

additionally do not generate NOx or SOx emissions. However, determining the 

scrubber medium may take some experimenting on the part of the facility to ensure it 

does not cause an increase in emissions or violate other District rules. It would also 

need to be replaced periodically, adding to the cost of upkeep. Thermal oxidizers do 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-20 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

not present similar issues. Also, facilities subject to Rule 4104 produce only a very 

small amount of directly emitted PM2.5 and are otherwise already required to have a 

high level of control for emissions. The current requirements are as stringent as 

possible for these types of facilities. 

Regenerative Thermal Oxidizers 

The District also evaluated the potential opportunity to reduce emissions from facilities 

by replacing thermal oxidizers with regenerative thermal oxidizers (RTOs) with heat 

recovery, which is a current practice at some facilities in the Valley. RTO devices use 

less supplementary fuel. While using less fuel may reduce NOx emissions, this is not 

necessarily the case. The PM control efficiency is nearly the same for both thermal 

oxidizers and RTOs, and the total NOx emissions from this category are relatively small 

given that there are only a few units subject to this rule that are not already subject to 

other combustion rules limiting NOx emissions. Any new units would be evaluated 

through the District’s Best Available Control Technology New Source Review 

requirements. 

Evaluation Findings

Even though the reduction of animal matter is not a significant source of PM2.5, NOx, or 

SOx in the Valley, the District has evaluated all potential control technologies and all 

control technologies achieved in practice in other areas or included in other state 

implementation plans. As demonstrated above, Rule 4104 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 this source category. As the District 

continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from this source category in the Valley. 
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 2015 Plan for the 1997 PM2.5 Standard 

C.3 RULE 4106 PRESCRIBED BURNING AND HAZARD REDUCTION BURNING 

Discussion 

Adopted in June 2001 and approved by EPA as a SIP amendment in February 2002, 18

Rule 4106 is applicable to all prescribed burning and to hazard reduction burning in the 

wildland/urban interface within the Valley. Rule 4106 incorporated provisions made 

necessary by the March 23, 2000 amendment of Title 17 of the California Code of 

Regulations. Recognizing the importance of both prescribed burning and hazard 

reduction burning, the purpose of Rule 4106 is to permit, regulate, and coordinate the 

use of prescribed burning and hazard reduction burning while minimizing smoke 

impacts on the public. Through this rule, the District has expended considerable 

resources to ensure that the ignition of burn projects is only allowed when air quality 

and dispersion conditions are favorable, thus lessening the health impacts on Valley 

citizens and on air quality in the Valley. 

Source Category

This rule is applicable to range improvement burning, forest management burning, 

wildland vegetation management burning, and hazard reduction burning. Agricultural 

burning, which is subject to Rule 4103, is generally done by farmers to dispose of tree 

prunings, crop residue, and other agricultural materials; disease and pest control; and 

orchard removal. In contrast, prescribed burning generally includes forest waste, fire 

hazard reduction, rangeland management, wildlife habitat improvement, and ecosystem 

(forest health) burning. 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.76 0.76 0.76 0.76 0.77 0.77 0.77 0.77 0.77 

NOx 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.07 0.07 

SOx 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 

Winter Average - Tons per day 

PM2.5 0.88 0.88 0.88 0.88 0.89 0.89 0.89 0.90 0.90 

NOx 0.10 0.10 0.10 0.10 0.10 0.10 0.10 0.11 0.11 

SOx 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from prescribed burning and hazard reduction burning are 

lower than the BACM/MSM significance thresholds. Therefore, the Clean Air Act does 

 

18 67 Federal Register 39, pp. 8894-8897 (to be codified at 40 CFR Part 52). (2002, February 27). Revisions to the 

California State Implementation Plan, San Joaquin Valley Unified Air Pollution Control District. Retrieved from 

https://www.federalregister.gov/articles/2002/02/27/02-4526/revisions-to-the-california-state-implementation-plan-sanjoaquin-valley-unified-air-pollution. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-22 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

not require a control measure evaluation for this source category for the purpose of 

satisfying BACM/MSM requirements; however, the District has still conducted a full 

control measure evaluation for prescribed burning and hazard reduction burning. 

How does District Rule 4106 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 4106 compare to rules in other air districts? 

SCAQMD 

 Rule 444 (Open Burning) 

The District evaluated the requirements contained within SCAQMD’s Rule 444 and 

found no requirements that were more stringent than those already in Rule 4106. 

BAAQMD 

 Regulation 5 (Open Burning) 

The District evaluated the requirements contained within BAAQMD’s Regulation 5 and 

found no requirements that were more stringent than those already in Rule 4106. 

SMAQMD 

 Rule 501 (Agricultural Burning) 

The District evaluated the requirements contained within SMAQMD’s Rule 501 and 

found no requirements that were more stringent than those already in Rule 4106. 

VCAPCD 

 Rule 56 (Open Burning) 

The District evaluated the requirements contained within VCAPCD’s Rule 56 and found 

no requirements that were more stringent than those already in Rule 4106. 

Placer County APCD (PCAPCD)

 PCAPCD Rule 301 (Nonagricultural Burning Smoke Management) 

The District evaluated the requirements contained within PCAPCD Rule 301 and found 

no requirements that were more stringent than those already in Rule 4106. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-23 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

 PCAPCD Rule 303 (Prescribed Burning Smoke Management) 

The District evaluated the requirements contained within PCAPCD Rule 303 and found 

no requirements that were more stringent than those already in Rule 4106. 

 

Additional Emission Reduction Opportunities 

Prescribed Burning Emission Reduction Opportunities

Land Management Agencies (LMAs) are the agencies that regularly conduct prescribed 

burning operations. Since the adoption of Rule 4106, the District has developed 

cooperative relationships with the LMAs. Through this cooperation, the District advises 

the LMAs on which days would be the most conducive for igniting a burn project, based 

on air quality and meteorological conditions. The District continues to work with LMAs 

to identify favorable burning conditions with the goal of completing a maximum number 

of prescribed burning projects while minimizing air quality impacts. This collaborative 

effort ensures that the ignition of burn projects occurs when air quality and dispersion 

conditions are favorable, thus lessening the impacts on air quality in the Valley. 

Potential opportunities to reduce emissions from prescribed burning include the 

mechanical removal of the materials, firebox air curtain burners, and management of 

wild fires. 

Mechanical Removal of Materials 

One potential option to reduce burning materials would be to physically remove material 

from a project site. As these locations are not near roadways, it is often not practical or 

possible to bring mechanical equipment to remote and dense forest lands to collect and 

remove the material. Additionally, mechanical removal is much more expensive for the 

LMAs, who are already subject to budgeting restrictions, to reduce the fuels in an area 

as compared to burning. Mechanical removal of materials from forest areas is not 

technologically or economically feasible. 

Firebox Air Curtain Burners 

Assuming that a LMA could mechanically remove all of the material from a project burn 

site and that the material was placed in piles and prepared for burning, an alternative to 

open burning would be to use a firebox air curtain burner. A firebox air curtain burner is 

a device that circulates large volumes of air over a burning fire in an open topped fire 

proof metal box. When compared to open burning, firebox air curtain burners have 

been shown to greatly reduce PM and carbon dioxide emissions; however, the potential 

NOx emissions compared to open burning have not been fully evaluated yet. Because 

the Valley is a NOx-limited area, more research on the technology is needed to verify 

that there would be potential NOx emission reductions by switching from open burning 

practices to the use of firebox air curtain burners. 

Wildfires 

Often, primarily during the warm summer months, wildfires are naturally ignited through 

lightning strikes from passing storms. These wildfires have the potential to produce 

significant emissions and heavily impact residents within the Valley. When these 

wildfires occur, the District works with the responsible LMA in managing the fire as the 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-24 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

dispersion and air quality conditions fluctuate. This cooperation allows the LMA to be 

more aggressive with the fire when meteorological conditions are favorable and more 

defensive when the conditions are poor. The District will continue to use the tools 

available to guide the activities of LMAs when wildfires occur, and is continuously 

seeking opportunities to work with LMAs to improve the management of these fires in 

order to reduce emissions and impacts to Valley residents. 

Hazard Reduction Burning Emission Reduction Opportunities 

Hazard reduction burning is used exclusively by landowners in the wildland/urban 

interface within the foothill and mountain regions in the State Responsibility Areas, 

which comprise about 20% of the total land area in the Valley. Section 4291 of the 

California Public Resources Code (CPRC) states that structures must maintain a 

defensible perimeter of 100 feet in all directions; this defensible perimeter is commonly 

created through the clearing of vegetation. Although Section 4291 does not require it, 

most of this vegetation is burned because it is less expensive, faster, and more 

convenient than other options. Potential opportunities evaluated below include the 

reorganization of hazard reduction zones and alternatives to burning the vegetation. 

Reorganization of Hazard Reduction Zones 

Under Rule 4106, hazard reduction burning is only allowed when the District forecasts 

favorable air quality and dispersion conditions. Currently this forecast is based on a 

county-by-county basis, with appropriate elevation breaks. As an improvement to this 

zone system, and similar to agricultural burning, the Valley could be separated into 

smaller hazard reduction zones to provide more effective smoke management. 

Managing the allowance of hazard reduction burning under this type of scheme also has 

the potential to limit smoke impacts on residents. Establishing this type of management 

system would not cause an increase in costs for landowners, making this a cost 

effective opportunity. However, emissions reduced, if any, would be minimal, since the 

burning would still occur, just on different days when conditions are favorable. 

Alternatives to Burning 

As an alternative to the open burning of the vegetation, the District could encourage 

alternative methods like chipping or burn boxes through grant programs targeted at 

communities that regularly conduct hazard reduction burning. 

1. Chipping 

One potential alternative to the open burning of material is to use a chipper to break 

down the material into small pieces suitable for landscaping, dust control cover, or 

biomass burning. Evaluation of this alternative option revealed that chippers are not 

a viable alternative. The requirement by the CPRC to maintain a defensible 

perimeter of 100 feet is enforced annually; therefore, the organic materials to be 

cleared and disposed of consist of leaves, pine needles, weeds, and some small 

brush, all of which are not acceptable materials for wood chippers. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

2. Firebox Air Curtain Burners 

Another potential opportunity examined is the feasibility of usage of a firebox air 

curtain burner, which was described earlier. Again, this is not a feasible option for 

the Valley because the potential NOx emission reductions have not been verified. 

3. Biomass Removal Program 

A potential opportunity to reduce emissions from hazard reduction burning would be 

by removing the biomass from the area and sending it for combustion at a biomass 

plant, similar to a pilot program implemented by the PCAPCD in 2007. The pilot 

program in Placer County was evaluated below to determine feasibility for 

implementation in the Valley. 

PCAPCD Program

PCAPCD implemented a “Biomass Box” program beginning in the spring of 2007 to 

collect and utilize biomass that would traditionally be collected and burned as a part 

of hazard reduction efforts, for use as fuel for producing energy. The program, 

funded with a grant from PCAPCD, collected the biomass by distributing 20 to 40 

foot industrial containers throughout participating communities in the county. When 

full, the containers were transported to another location where the materials were 

grinded into useable fuel that biomass energy companies could accept. The 

chipped biomass was then loaded onto larger trucks and hauled to one of two 

biomass facilities. 

Figure C-3 Image of a Typical 40' Biomass Box Used in Placer County in 2007 

The final report by PCAPCD that evaluated this pilot program documented that from 

an emissions reductions standpoint the project was a success, with net air pollution 

reductions at 88.6%, including 24.7 tons of particulates and 4.0 tons of NOx reduced 

at a cost of $80,000. Based on the perceived success of this study, the District 
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evaluated this pilot program for potential emissions reductions and feasibility of 

implementation in the Valley. 

Hazard reduction in Placer County is overseen by the Placer County Biomass 

Program with help from local fire departments and land managers. The Placer 

County Biomass Program and PCAPCD confirmed that the community biomass bins 

are no longer prominently used. The program was initially designed to change the 

culture of hazard reduction burning by providing an alternative to burning. However, 

the bin program proved to have many complications that rendered it an ineffective 

program. One issue was that residents were disposing of items other than biomass 

into the bins. This caused problems for the chippers and produced less than ideal 

fuel for biomass plants. Additionally, PCAPCD determined that the transport of 

biomass bins any further than 30 miles round trip was cost prohibitive.19 

A few biomass bins were still in use as of 2013, but only in communities that 

explicitly requested them following the 2007 pilot project. PCAPCD determined that 

there are more cost effective options for removing residential biomass then using 

community biomass bins, such as using mobile chippers to provide residents with a 

low cost “curb side” chipping service. The chipped biomass is blown back onto the 

property for use as mulch or as a dust suppressant. The program is supported in 

part by grants from Placer County Resource Conservation District, Placer County 

Sheriff’s Department, PCAPCD, and Calfire. As stated above, chipping is not a 

feasible option to implement in the Valley. 

Evaluation Findings

Even though prescribed burning and hazard reduction burning are not a significant 

source of PM2.5, NOx, or SOx in the Valley, the District has evaluated all potential 

control technologies and all control technologies achieved in practice in other areas or 

included in other state implementation plans. As demonstrated above, Rule 4106 

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 this source 

category. As the District continues to develop new attainment plans that address more 

stringent National Ambient Air Quality Standards, the District will continue to evaluate 

potential opportunities to reduce emissions from prescribed burning and hazard 

reduction burning in the Valley. 

 

19 Storey, B., Biomass Program Manager, Placer County Executive Office, Personal Communication. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-27 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.4 RULE 4203 PARTICULATE MATTER EMISSIONS FROM THE 

INCINERATION OF COMBUSTIBLE REFUSE 

Discussion 

Rule 4203 is applicable to any person, operation, facility, incinerator, or equipment used 

to dispose or process combustion refuse. The rule limits the concentration of particulate 

matter emissions based on process weight rates, and prohibits the discharge of visible 

emissions. Rule 4203 was adopted on May 21, 1992 and subsequently amended for 

District rule number reorganization on December 17, 1992. 

Source Category 

There are currently 3 facilities in the Valley subject to Rule 4203. Units subject to this 

rule already meet BACT level requirements, which require the mitigation of air pollution 

to the maximum degree achievable using control technologies like baghouses and lime 

scrubbers. 

Emissions Inventory 

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Winter Average - Tons per day 

PM2.5 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

As detailed in Chapter 5, the significance threshold for source categories for the 

purpose of evaluating the application of BACM and MSM requirements is 1.4 tons per 

day (tpd) for PM2.5 combustion. As identified in the above table, emissions from the 

incineration of combustible refuse are lower than the BACM/MSM PM2.5 significance 

threshold. Therefore, the Clean Air Act does not require a control measure evaluation 

for this source category for the purpose of satisfying BACM/MSM requirements; 

however, the District has still conducted a full control measure evaluation for the 

incineration of combustible refuse. 

How does District Rule 4203 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no specific federal guidelines for particulate matter concentration in terms of 

EPA CTG, ACT, NSPS, NESHAP, or MACT requirements. EPA BACT standards 

require the use of a fabric filter or baghouse. District BACT standards are as stringent 

and require existing facilities to use a natural gas supplemental fuel with a baghouse. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-28 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 4203 compare to rules in other air districts? 

There are no analogous rules for this source category in BAAQMD. 

SCAQMD 

 Rule 473 (Disposal of Solid and Liquid Wastes) 

The District evaluated the requirements contained within SCAQMD’s Rule 473 and 

found no requirements that were more stringent than those already in Rule 4203. 

SMAQMD 

 Rule 407 (Open Burn)

The District evaluated the requirements contained within SMAQMD’s Rule 407 and 

found no requirements that were more stringent than those already in Rule 4203. 

VCAPCD 

 Rule 57 (Incinerators)

The District evaluated the requirements contained within VCAPCD’s Rule 57 and found 

no requirements that were more stringent than those already in Rule 4203. 

Evaluation Findings 

Even though particulate matter emissions from the incineration of combustible refuse 

are not a significant source of PM2.5 in the Valley, the District has evaluated all 

potential control technologies and all control technologies achieved in practice in other 

areas or included in other state implementation plans. As demonstrated above, Rule 

4203 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 this 

source category. As the District continues to develop new attainment plans that 

address more stringent National Ambient Air Quality Standards, the District will continue 

to evaluate potential opportunities to reduce emissions from the incineration of 

combustible refuse in the Valley. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-29 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.5 RULE 4204 COTTON GINS 

Discussion 

Adopted on February 17, 2005, Rule 4204 is intended to reduce particulate emissions 

from cotton ginning facilities operating within the Valley. The implementation of this rule 

has achieved 0.79 tpd of PM10 reductions from this source category. EPA finalized 

approval of Rule 4204 on November 9, 2006 and deemed this rule as meeting 

established RACT standards. 

The 2003 PM10 Plan identified cotton gins as a significant source of PM10 emissions in 

the Valley. The federal CAA requires air districts designated as Serious nonattainment 

for PM10 to implement BACM, including BACT, on significant stationary and area 

sources of PM10 and PM10 precursors. Although many gins in the Valley were already 

retrofitted with 1D3D high-efficiency cyclones, considered BACT, the District developed 

Rule 4204 to assure that all cotton gins met BACT requirements at the earliest 

practicable date. 

Source Category 

There are two types of cotton gins: saw and roller. A saw gin is commonly used for 

short fiber cotton where the cotton is pulled across knifed edges to remove seeds and 

trash. A roller gin is instead used for long fiber cotton and the cylinders or rollers carry 

the cotton across screens or perforated metal where the trash is removed. Throughput 

for saw gins can be higher than that of a roller gin, but a roller gin produces a higher 

quality end-product. 

Modern ginning uses pneumatic conveyance, in the form of fans blowing air, which 

moves the cotton gin material. Particulate matter emissions are the unwanted byproducts of this otherwise very efficient means of transferring massive quantities of 

cotton gin material from one process to the next process, such as from unloading to 

drying and cleaning. PM emissions from cotton ginning facilities occur mostly during a 

three-month period from October to December, the time of year during which the 

Valley’s ambient PM concentrations are highest. 

Cotton ginning, the process of separating the lint from the seed, has evolved from a 

labor-intensive process capable of producing small quantities of cotton to a highly 

efficient industry producing millions of bales. With this increase in production came the 

problem of how to handle the debris made up of plant and soil material that comes from 

machine harvesting the cotton. Since cotton gins use large quantities of air for 

conveying, the use of cyclones for air pollution abatement was a logical choice. 

Cotton gins are regulated through a combination of permit conditions and other 

prohibitory rules aside from Rule 4204. Permit conditions cite Rules 1070, 2201, 4101, 

4102, 4201, and 4202 as the regulatory basis for cotton gins: 

 Rule 1070 requires the keeping of daily records, which are available for District 

inspection upon request. 

 Rule 2201 covers the following areas: 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-30 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

a. Type of cyclones or other control devices for specific exhaust points. 

b. Allowable PM10 emission rate for the cotton gins as an integrated system 

and allowable PM10 emission rate for specific exhaust points. 

c. Bale throughput in bales/day or bales/season. 

 Rule 4101 prohibits the discharge into the atmosphere of air contaminants for a 

period or periods aggregating more than three minutes in any one hour, which is 

as dark as or darker than Ringelmann 1 or 20% opacity. 

 Rule 4102 prohibits the release of air contaminants that causes a public

nuisance. 

 Rule 4201 limits particulate matter emissions concentration to 0.1 grains/dscf or 

less. 

 Rule 4202 limits particulate matter emissions by establishing allowable emission 

rates based on process weights. 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.22 0.22 0.23 0.22 0.22 0.23 0.23 0.24 0.24 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Winter Average - Tons per day 

PM2.5 0.34 0.35 0.35 0.35 0.35 0.36 0.36 0.37 0.37 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from cotton gins are lower than the BACM/MSM significance 

thresholds. Therefore, the Clean Air Act does not require a control measure evaluation 

for this source category for the purpose of satisfying BACM/MSM requirements; 

however, the District has still conducted a full control measure evaluation for cotton 

gins. 

How does District Rule 4204 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. 

State Regulations 

There are no state regulations applicable to this source category. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-31 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

How does District Rule 4204 compare to rules in other air districts? 

There are no analogous rules for this source category in SCAQMD, BAAQMD, 

SMAQMD, or VCAPCD. 

Other Analogous Rules 

 New Mexico Administrative Code 20.2.66.1 (Cotton Gins) 

The District evaluated the requirements contained within New Mexico Administrative 

Code 20.2.66.1 and found no requirements that were more stringent than those already 

in Rule 4204. 

 Louisiana Department of Environmental Quality, Title 33 (Environmental Regulatory 

Code), Part III (Air) 

The District evaluated the requirements contained within Louisiana Department of 

Environmental Quality, Title 33 and found no requirements that were more stringent 

than those already in Rule 4204. 

 North Carolina Administrative Code Title 15A, Subchapter 2D, Section .0542 

(Control of Particulate Emissions from Cotton Ginning Operations) 

The District evaluated the requirements contained within North Carolina Administrative 

Code Title 15A, Subchapter 2D, Section .0542 and found no requirements that were 

more stringent than those already in Rule 4204. 

 South Carolina Air Pollution Control Regulations and Standards, Regulation 61-62.5, 

Standard No. 4, Section V (Cotton Gins) 

The District evaluated the requirements contained within South Carolina Regulation 61-

62.5, Standard No. 4, Section V and found no requirements that were more stringent 

than those already in Rule 4204. 

 Oklahoma Department of Environmental Quality, Air Pollution Control, 252:100-23 

(Cotton Gins) 

The District evaluated the requirements contained within South Carolina Regulation 61-

62.5, Standard No. 4, Section V and found no requirements that were more stringent 

than those already in Rule 4204. 

 Texas Commission on Environmental Quality, Air Quality Standard Permit for Cotton 

Gin Facilities and Cotton Burr Tub Grinders 

The District evaluated the requirements contained within the above rules and found no 

requirements that were more stringent than those already in Rule 4204. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-32 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Additional Emission Reduction Opportunities 

Research and PM2.5 Fraction 

Research was completed in 2013 by the United States Department of Agriculture 

Agricultural Research Service (USDA-ARS), in partnership with cotton associations, 

EPA, ARB, and the District to measure actual PM10 and PM2.5 emissions from stack 

sources and fugitive emissions in and around several ginning facilities. This research 

provided emission factors for comparison to previous estimations that are included in 

emission inventories and provided data for both types of cotton gins currently in use in 

California. This project was designed to measure emissions from facilities with current 

emissions control technologies in place and to improve emissions estimations by 

measurement with the highest quality methods and instruments. The project was not 

designed to evaluate new technologies or measures to further reduce 

emissions. Results for the seven gins that were sampled for the project indicate the 

estimated ratio of PM2.5 to PM10 is approximately 16%.20 This fraction of PM2.5 to 

PM10 is lower than indicated in the emissions inventory currently being used. Future 

research will include particle size analysis of EPA Method 17 samples, and modeling to 

compare model output and ambient sampling data and develop suggested modeling 

corrections. 

1D3D Cyclones with Expansion Chamber 

Currently, all cotton gins in the Valley are required to operate using a 1D3D cyclone. 

About two thirds of the 1D3D cyclones used in the Valley have an expanded chamber 

outlet. Research has shown that an expansion chamber allows for more flow since it is 

not as narrow. In initial tests, a larger D/3 size expanded chamber exit produced PM10 

emissions that were about 8% lower than those resulting from use of the standard, 

small-diameter (D/4) exit.21 However, there is no completed research indicating the 

fraction of PM2.5 emitted or the effectiveness of reducing PM2.5 by installing an 

expanded chamber. Since 1D3D cyclones are already required by the current rule, and 

there is no definitive data to verify the effectiveness in reducing PM2.5 emissions with 

an expansion chamber, this is not a feasible opportunity to reduce emissions. 

Loadout 

Rule 4204 currently requires wind screens for loadout. Two potential opportunities to 

reduce emissions through control options to capture PM10 emissions from the truck 

loading operation were identified as follows: 1) venting the loadout area to pre-cleaning 

cyclones and a baghouse; and 2) venting the receiving pit to a 1D-3D cyclone. While it 

is technologically feasible to enclose the loadout area and receiving pits and vent to the 

respective control devices, the District’s BACT Guideline 5.1.8 has found those options 

to not be cost effective. This analysis was calculated according to PM10 emission 

factors and again, the PM2.5 fraction is unknown at this time. 

 

20 United States Department of Agriculture, Agricultural Research Service. (2013). Characterization of Cotton Gin 

Particulate Matter Emissions. Obtained from http://buser.okstate.edu/air-quality/cotton-gin/national-study/. 21 Baker R.V. and Hughs S.E. (1998). Influence of Air Inlet and Outlet Design and Trash Exit Size on 1D3D Cyclone 

Performance. Transactions of the ASAE, vol. 42(1): 17-21. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-33 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Mechanical Conveyance 

Mechanical conveyance for the main trash handling system could be a potential 

opportunity to reduce emissions, but it has only been demonstrated as feasible for 

newly constructed or rebuilt cotton gins. Mechanical conveyance almost entirely 

eliminates emissions from cotton gin trash handling exhaust streams, which were 

previously moved pneumatically. The cotton gin trash handling systems only comprise 

a fraction of the emissions that are released from the full cotton ginning process. Newer 

or rebuilt cotton gins are able to accommodate a mechanical conveyance system since 

they are able to design the cotton gin around the equipment and space needed. 

Operators that have installed a mechanical conveyance system for their cotton gin have 

had to build a lower floor, below the main level containing the major cotton gin 

equipment, to house the mechanical conveyors. Therefore, as confirmed by industry 

representatives and equipment manufacturers, it is not technologically feasible to retrofit 

existing cotton gins with mechanical conveyance systems to replace existing trash 

handling equipment. Additionally, any new facilities would trigger New Source Review 

requirements and would be required to implement BACT level controls. 

Plenum Chambers 

Plenum chambers are in use at a number of cotton gins in the Valley. Plenum 

chambers are placed upstream of selected cyclones to remove large trash. Studies 

have been inconclusive in demonstrating an increase in PM control efficiency with the 

utilization of a plenum chamber. Most cotton ginning facilities that have installed 

plenum chambers are using those devices to reduce wear and tear on the cyclones, 

thus prolonging the life of the cyclones, and not for increased PM controls. 

Evaluation Findings

Even though cotton gins are not a significant source of PM2.5, NOx, or SOx in the 

Valley, the District has evaluated all potential control technologies and all control 

technologies achieved in practice in other areas or included in other state 

implementation plans. As demonstrated above, Rule 4204 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 this source category. As the District 

continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from cotton gins in the Valley. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-34 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.6 RULE 4301 FUEL BURNING EQUIPMENT 

Discussion 

Rule 4301 was last amended in 1992 and applies to all types of fuel burning equipment, 

except air pollution control equipment. The purpose of this rule is to limit emissions of 

air contaminants from fuel burning equipment by specifying maximum emission rates for 

SOx, NOx, and PM (identified in the rule as combustion contaminant emissions). EPA 

finalized approval of the 1992 amendments to Rule 4301 on May 18, 1999 and deemed 

this rule as being at least as stringent as established RACT requirements. 

Source Category 

Rule 4301 has a very broad applicability, as it applies to all types of fuel burning 

equipment. Since its early adoption in 1992, it has largely been superseded by several 

District rules with more stringent NOx requirements for specific types of fuel burning 

equipment. See the control measure evaluations for Rules 4306, 4307, 4308, 4309, 

4352, and 4703 for more specific information about the individual fuel burning 

equipment source categories. 

Emissions Inventory

There is no emissions inventory specific to Rule 4301; see Rules 4306, 4307, 4308, 

4309, 4352, and 4703 for the individual emissions inventories. 

How does District Rule 4301 compare with federal and state rules and 

regulations? 

Facilities subject to Rule 4301 are subject to various state rules and federal 

requirements, such as CTG, ACT, NSPS, NESHAP, and MACT. However, as 

previously mentioned, several District rules have superseded Rule 4301 with more 

stringent requirements. Comparisons of those District rules to the applicable federal 

and state rules are discussed within those control measure evaluations. 

How does District Rule 4301 compare to rules in other air districts? 

There are no analogous rules in BAAQMD, SMAQMD, and VCAPCD. 

SCAQMD 

 Rule 474 (Fuel Burning Equipment—Oxides of Nitrogen) 

The District evaluated the requirements contained within SCAQMD’s Rule 474 and 

found no requirements that were more stringent than those already in Rule 4301. 

Evaluation Findings 

District Rule 4301 alone cannot be considered to fulfill BACM/MSM requirements for 

this source category. The NOx requirements of this rule have been superseded by the 

requirements of other District rules that satisfy BACM/MSM for fuel burning equipment 

since all units subject to Rule 4301 are subject to a more specific NOx rule discussed 

elsewhere in this appendix. See the control measure evaluations for Rules 4306, 4307, 

4308, 4309, 4352, and 4703. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-35 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.7 RULE 4306 AND RULE 4320 ADVANCED EMISSION REDUCTION 

OPTIONS FOR BOILERS, STEAM GENERATORS, AND 

PROCESS HEATERS GREATER THAN 5.0 MMBTU/HR 

Discussion 

Rules 4306 and 4320 apply to any gaseous fuel or liquid fuel fired boiler, steam 

generator, or process heater with a total rated heat input greater than 5 million British 

thermal units per hour (MMBtu/hr). The purpose of these rules is to limit NOx and 

carbon monoxide (CO) emissions from boilers, steam generators, and process heaters 

of this size range. 

Rule 4320 is the third generation rule for this source category. The first District rule for 

this source category, Rule 4305 (Boilers, Steam Generators, and Process Heaters), 

was adopted on December 16, 1993. Rule 4305 was superseded by Rule 4306 

(Boilers, Steam Generators, and Process Heaters – Phase 3) on September 18, 2003 to 

implement a NOx control measure from the District’s ozone and PM10 attainment plans, 

lowering the NOx emissions limits in Rule 4305. Since adoption, Rule 4306 has been 

amended twice. 

The amendment of Rule 4306 in October 2008 was initially proposed to lower the NOx 

emission limit from 9 ppmv to 6 ppmv for units greater than 20 MMBtu/hr. It was 

determined that the proposed NOx limits could be accomplished by using selective 

catalytic reduction (SCR) or a combination of SCR and ultra-low NOx burners (ULNBs), 

thus making the lower limits technologically feasible. However, through the public 

workshop process and additional research it was also determined that most of the units 

subject to Rule 4306 have undergone several generations of NOx controls, and 

consequently, certain applications of SCR may not be cost effective and/or 

technological infeasible because of physical limitations. Therefore, the lower NOx limits 

were included in new Rule 4320 and an option was provided in the rule that allows for 

the payment of an annual emissions fee based on total actual emissions, rather than 

installation of additional NOx controls. These fees are used by the District to achieve 

cost effective NOx reductions through District incentive programs, the District’s 

Technology Advancement Program, and other routes. The previous versions of Rule 

4305 and 4306 combined with the implementation of Rule 4320 achieve approximately 

96% control of NOx emissions from this source category. 

The implementation of Rule 4320 does not substitute the requirements of Rule 4306, 

but enforces requirements supplementary to Rule 4306. As such, this evaluation is 

applicable to both Rule 4306 and Rule 4320. 

Source Category 

Facilities with units subject to this rule represent a wide range of industries, including 

but not limited to electrical utilities, cogeneration, oil and gas production, petroleum 

refining, manufacturing and industrial processes, food and agricultural processing, and 

service and commercial facilities. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-36 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

To recognize the operational and technical differences between different types of 

equipment subject to Rules 4306 and 4320, the different equipment types were 

separated into several major categories, with different requirements, including the 

following: 

 Units with a total rated heat input greater than 5.0 MMBtu/hr to 20.0 MMBtu/hr 

 Units with a total rated heat input greater than 20.0 MMBtu/hr 

 Oilfield steam generators of all ratings and fuel types 

 Refinery units of all ratings and fuel types 

 Low-use units limited by a Permit to Operate to an annual heat input greater than 

1.8 billion Btu/year but less than or equal to 30 billion Btu/year 

 Units at a wastewater treatment facility using less than 50% PUC quality fuel 

 Small specialty units operated by a small producer 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 1.27 1.25 1.23 1.21 1.19 1.17 1.14 1.13 1.10 

NOx 1.93 1.83 1.72 1.61 1.56 1.51 1.46 1.41 1.36 

SOx 0.60 0.59 0.24 0.24 0.23 0.23 0.23 0.22 0.22 

Winter Average - Tons per day 

PM2.5 1.25 1.24 1.21 1.19 1.17 1.15 1.13 1.11 1.09 

NOx 1.88 1.78 1.68 1.57 1.51 1.47 1.42 1.38 1.32 

SOx 0.58 0.57 0.24 0.23 0.23 0.23 0.22 0.21 0.21 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion emissions, 13.1 tons per day (tpd) for NOx, and 1.0 tpd 

for SOx. As identified in the above table, emissions from boilers, steam generators, and 

process heaters greater than 5.0 MMBtu/hr are lower than the BACM/MSM significance 

thresholds. Therefore, the Clean Air Act does not require a control measure evaluation 

for this source category for the purpose of satisfying BACM/MSM requirements; 

however, the District has still conducted a full control measure evaluation for this source 

category. 

How does District Rule 4306/4320 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG requirements for this source category. 

ACT 

 EPA-453/R-93-034 (Alternative Control Techniques Document – NOx emissions 

from Process Heaters)
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-37 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

The District evaluated the requirements contained within the ACT for NOx Emissions 

from Process Heaters and found no requirements that were more stringent than those 

already in Rules 4306 and 4320. 

 EPA-453/R-93-022 (Alternative Control Techniques Document – NOx Emissions 

from Industrial/Commercial/Institutional Boilers)

The District evaluated the requirements contained within the ACT for NOx Emissions 

from Industrial/Commercial/Institutional Boilers and found no requirements that were 

more stringent than those already in Rules 4306 and 4320. 

 EPA-453/R-93-023 (Alternative Control Techniques Document – NOx Emissions 

from Utility Boilers)

The District evaluated the requirements contained within the ACT for NOx Emissions 

from Utility Boilers and found no requirements that were more stringent than those 

already in Rules 4306 and 4320. 

NSPS 

 40 CFR 60 Subpart D (Standards of Performance for Fossil-Fuel Fired Steam 

Generators for Which Construction Is Commenced After August 17, 1971) 

The District evaluated the requirements contained within 40 CFR 60 Subpart D and 

found no requirements that were more stringent than those already in Rules 4306 and 

4320. 

 40 CFR 60 Subpart Db (Standards of Performance for Industrial-CommercialInstitutional Steam Generating Units) 

The District evaluated the requirements contained within 40 CFR 60 Subpart Db and 

found no requirements that were more stringent than those already in Rules 4306 and 

4320. 

 40 CFR 60 Subpart Dc (Standards of Performance for Small Industrial- CommercialInstitutional Steam Generating Units) 

The District evaluated the requirements contained within 40 CFR 60 Subpart Dc and 

found no requirements that were more stringent than those already in Rules 4306 and 

4320. 

NESHAP/ MACT 

 40 CFR 63 Subpart DDDDD (NESHAP for Major Sources: Industrial, Commercial, 

and Institutional Boilers and Process Heaters) 

40 CFR 63 Subpart DDDDD was amended on January 31, 2013 to include new 

emission limits for PM, CO, and total selective metals (TSM), replace numeric dioxin 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-38 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

emission limits with work practice standards, add new subcategories of facilities, and 

add alternative monitoring approaches for compliance with the PM limit. The PM limit in 

District Rule 4320 is more stringent for liquid fuels because it only allows liquid fuels to 

be burned during PUC quality natural gas curtailment periods. It is equivalent to 

DDDDD for all gasses burned except for gasses exceeding 40 μg/m3 of mercury. 

The District evaluated the requirements contained within the above NESHAP and found 

no requirements that were more stringent than those already in Rules 4306 and 4320. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 4306/4320 compare to rules in other air districts? 

SCAQMD 

 Rule 1146 (Emissions of Nitrogen from Industrial, Institutional, and Commercial 

Boilers, Steam Generators, and Process Heaters) 

SCAQMD Rule 1146 was amended on November 1, 2013 to include rule language 

clarifications and revisions to address SIP creditability issues. None of the amendments 

affected emissions reductions. 

The District evaluated the requirements contained within SCAQMD’s Rule 1146 and 

found no requirements that were more stringent than those already in Rules 4306 and 

4320. 

BAAQMD 

 Regulation 9 Rule 7 (Nitrogen Oxides and Carbon Monoxide from Industrial, 

Institutional and Commercial Boilers, Steam Generators and Process Heaters) 

The District evaluated the requirements contained within BAAQMD’s Regulation 9 Rule 

7 and found no requirements that were more stringent than those already in Rules 4306 

and 4320. 

 Regulation 9 Rule 10 (Nitrogen Oxides and Carbon Monoxide from Boilers, Steam 

Generators and Process Heaters in Petroleum Refineries) 

The District evaluated the requirements contained within BAAQMD’s Regulation 9 Rule 

10 and found no requirements that were more stringent than those already in Rules 

4306 and 4320. 

SMAQMD 

 Rule 411 (NOx from Boilers, Process Heaters and Steam Generators) 

The District evaluated the requirements contained within SMAQMD’s Rule 411 and 

found no requirements that were more stringent than those already in Rules 4306 and 

4320. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-39 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

VCAPCD 

 Rule 74.15 (Boilers, Steam Generators and Process Heaters) 

The District evaluated the requirements contained within VCAPCD’s Rule 74.15 and 

found no requirements that were more stringent than those already in Rules 4306 and 

4320. 

Additional Emission Reduction Opportunities 

Over the years, the District has adopted numerous generations of rules and rule 

amendments for boilers greater than 5 MMBtu/hr that have significantly reduced NOx 

and PM emissions from this source category. The emissions inventory for NOx from 

these boilers has dropped from 40.2 tpd in 1993 to 1.61 tpd in 2015. As part of these 

regulatory efforts, hundreds of boilers in the Valley have been equipped with the best 

available NOx and PM control technologies. Given the significant effort already made to 

reduce emissions from this source category, there are little remaining opportunities for 

obtaining additional emissions reductions. 

Low Temperature Oxidation 

The District researched emerging technologies that may have the potential to reduce 

emissions. A Low Temperature Oxidation (LTO) System was installed at a dairy in the 

SCAQMD and was able to reach NOx limits between 1.0- 3.2 ppmv for loads 4.1-13 

MMBtu/hr. The LTO system utilizes ozone to oxidize and control various pollutants, 

including NOx. According to the SCAQMD BACT database information, capital and 

installation costs ranged from $360,000 - $400,000 for the LTO system when it was 

installed in 1997.22 Installation within the South Coast region was heavily subsidized 

with government funding and the installation costs appear cost prohibitive for an 

installation that is not subsidized. In addition, the LTO system is classified as “Other 

Technologies” in the SCAQMD BACT guidelines, which means that the technology has 

not met the achieved in practice (AIP) criteria of six months of continuous operation at a 

minimum of 50% operating capacity and does not qualify as the lowest achievable 

emission rate (LAER). Since the technology has not been achieved in practice and cost 

prohibitive without significant subsidies, this is not a feasible opportunity at this time. 

EMx 

The District researched the potential for emissions reductions through EMx, the second 

generation of the SCONOx technology that is a post-combustion control that reduces 

NOx, SOx, CO, and volatile organic compound (VOC) emissions. This technology has 

not been AIP in the District and there is no available data that indicates that SCONOx or 

EMx has been installed on boilers even though the manufacturer’s website states that 

the technology is transferrable to industrial boilers. Based on research of the best 

available controls from EPA and other air districts, the SCONOx and EMx systems have 

only been utilized by power plants for control of turbine emissions. In fact, cost 

effectiveness analyses conducted by the District for the installation of SCONOx/EMx 

 

22 South Coast Air Quality Management District. (2012). SCAQMD Best Available Control Technology (BACT) 

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

C-40 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

units on large power plant turbine installations within the Valley have been found to not 

be cost effective. Given the high cost effectiveness demonstrated for turbines and lack 

of demonstrated practice with boilers, this technology is not feasible or cost effective for 

reducing emissions from this category. 

PM2.5 Limits for Alternative Fuels 

The majority of boilers (>5 MMBtu/hr) in the Valley combust Public Utilities Commission 

(PUC) quality natural gas, which contains a very low sulfur content and inherently has 

low emissions. Few boilers in the Valley use alternative fuels for their combustion 

processes. Alternative fuels include digester gas, produced gas, and liquid fuel. Units 

fired on digester gas or produced gas are already required to use inlet gas scrubbers to 

meet District rule requirements. Current rule language requires that liquid fuel shall be 

used only during a PUC-quality natural gas curtailment period provided it contains no 

more than 15 ppm sulfur. While the use of liquid fuel is strictly limited, the feasibility of 

reducing PM emissions through adding PM2.5 limits for units using liquid fuel was 

explored as part of the District’s comprehensive control measure evaluation. 

There are 83 units that are permitted to utilize liquid fuel in the Valley (>5 MMBtu/hr) 

during a natural gas curtailment with an average combined emissions inventory of 

approximately 0.034 tons per year of total PM. The low emissions inventory is 

attributed to the fact that these units either utilize liquid fuel as a backup if there is a 

natural gas curtailment. The following three technologies were researched as potential 

opportunities to reduce PM emissions: baghouses, electrostatic precipitators (ESPs), 

and wet scrubbers. Baghouses control total PM and PM2.5 emissions by 90-99%; 

ESPs control total PM and PM2.5 emissions by 90-99%; and wet scrubbers control 

large particulates (>PM5) by 99% and PM2.5 emissions by approximately 50%.23 

Currently, there are a few crude oil-fired or field gas-fired steam generators operating in 

crude oil production facilities that are required by their permits to operate SOx scrubbers 

and ESPs. However, baghouses are typically not used with liquid-fired boilers due to 

the potential clogging of the baghouse24 and are therefore not a recommended 

technology due to infeasibility and safety issues. 

 

23 Northeast States for Coordinated Air Use Management. (November 2008) Applicability and Feasibility of NOx, 

SO2, and PM Emissions Control Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. Retrieved 

from 

http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=0CB8QFjAA&url=http%

3A%2F%2Fwww.nescaum.org%2Fdocuments%2Fici-boilers-20081118-

final.pdf%2F&ei=7nfvVIivFai1sAT07IHIAg&usg=AFQjCNFBdQn7MVAibSTZIbHV7-

ojXkVlXQ&bvm=bv.86956481,d.cWc. 24 Northeast States for Coordinated Air Use Management. (November 2008) Applicability and Feasibility of NOx, 

SO2, and PM Emissions Control Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. Retrieved 

from 

http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=0CB8QFjAA&url=http%

3A%2F%2Fwww.nescaum.org%2Fdocuments%2Fici-boilers-20081118-

final.pdf%2F&ei=7nfvVIivFai1sAT07IHIAg&usg=AFQjCNFBdQn7MVAibSTZIbHV7-

ojXkVlXQ&bvm=bv.86956481,d.cWc. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-41 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

PM Potential Emissions Reductions for an ESP and Scrubber 

For the purposes of these calculations, the following assumptions were made: 

1. For simplicity, the analysis will evaluate the cost effectiveness of these 

technologies for total PM reductions from liquid fuel fired units. 

2. The PM control efficiency of an ESP is 99%. 

3. The PM control efficiency of a scrubber is 99%. 

Potential Emissions Reductions (ESP) = (Total PM Emissions) x (Control Efficiency) 

Potential Emissions Reduction (ESP) = 0.034 tons/year X 0.99 

Potential Emissions Reduction (ESP) = 0.0337 tons/ year (tpy) 

Potential Emissions Reductions (scrubber) = (Total PM Emissions) x (Control Efficiency) 

Potential Emissions Reduction (scrubber) = 0.034 tons/year X 0.99 

Potential Emissions Reduction (scrubber) = 0.0337 tons/ year (tpy) 

Annualized Cost of an ESP and Wet Scrubber 

The capital cost for the installation of an ESP for a 1-5 MMBtu/hr boiler ranges from 

$90,000 - $100,000 and the annual maintenance cost is $1,000-$2,000.25 For the wet 

scrubber system, EPA estimated the annualized cost at $5,300-$102,000 per sm3/sec 

at an average air flow rate of 0.7-47 sm3

/sec.26 The District used the following 

assumptions in the cost effectiveness calculations: 

1. The capital cost of an ESP for a 5 MMBtu/hr boiler is assumed to be $100,000. 

2. The annual maintenance cost of an ESP for a 5 MMBtu/hr boiler is assumed to 

be $2,000. 

3. The annualized cost of a wet scrubber system is assumed to be the median of 

the range above ($53,650 per sm3

/sec). 

4. The average air flow rate for a wet scrubber system is assumed to be the median 

of the range above (23.85 sm3/sec). 

5. The total capital and maintenance cost of an ESP will be calculated by 

multiplying the cost of 1 unit by the total number of units. 

6. The total annualized cost of a wet scrubber will be calculated by multiplying the 

annualized cost of 1 unit by the total number of units. 

7. Lifetime of the ESP is 10 years at 10% interest. To account for this, the 

annualized capital cost will be calculated by multiplying the total capital cost by 

the capital recovery factor of 0.1627 and adding the annual maintenance costs. 

Annual Cost(ESP) = (Total Capital Cost) x (0.1627) + (Annual Maintenance Cost x 83) 

Annual Cost(ESP) = ($100,000 x 83) x (0.1627) + ($2,000 x 83) 

Annual Cost(ESP) = $1,516,410/year 

 

25 Catherine Roberts. (March 2009) Information on Air Pollution Control Technology for Woody Biomass Boilers. 

Environmental Protection Agency Office of Air Quality Planning and Standards and Northeast States for Coordinated 

Air Use Management. 

26 EPA. (2002). Air Pollution Control Technology Fact Sheet: Spray-Chamber/Spray-Tower Wet Scrubber. Retrieved 

from http://www.epa.gov/ttncatc1/dir1/fsprytwr.pdf. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-42 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Annual Cost(scrubber) = (Annualized Cost of 1 unit) x (Number of Units) x (Avg. Flow Rate) 

Annual Cost(scrubber) = ($53,650/ sm3/sec) x (83) x (23.85 sm3/sec) 

Annual Cost(scrubber) = $106,202,858/ year 

Cost Effectiveness of an ESP and Wet Scrubber 

Cost Effectiveness = Annual Cost / Annual Emissions Reductions 

Cost Effectiveness(ESP) = ($1,516,410/year) / (0. 0337 tons/ year) 

Cost Effectiveness(ESP)= $44,997,329/ton of PM 

Cost Effectiveness(scrubber)= ($106,202,858/year) / (0. 0337 tons/ year) 

Cost Effectiveness(scrubber) = $3,151,420,104/ton of PM 

As illustrated above, neither PM control technology is a cost effective option for this 

source category. The cost of the ESP technology does not include costs of retrofitting 

equipment and/or the facility or compliance monitoring costs, which would drive the cost 

effectiveness up even more. 

Evaluation Findings

Even though boilers, steam generators, and process heaters greater than 5.0 MMBtu/hr 

are not a significant source of NOx, or SOx in the Valley, the District has evaluated all 

potential control technologies and all control technologies achieved in practice in other 

areas or included in other state implementation plans. As demonstrated above, Rule 

4306 and 4320 currently have in place the most stringent measures feasible to 

implement in the Valley and therefore meet or exceed both BACM and MSM 

requirements for this source category. As the District continues to develop new 

attainment plans that address more stringent National Ambient Air Quality Standards, 

the District will continue to evaluate potential opportunities to reduce emissions from this 

source category in the Valley. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-43 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.8 RULE 4307 BOILERS, STEAM GENERATORS AND PROCESS HEATERS–

2.0 MMBTU/HR TO 5.0 MMBTU/HR 

Discussion 

This rule applies to any gaseous fuel or liquid fuel fired boiler, steam generator, or 

process heater with a total rated heat input of 2.0 million British thermal units per hour 

(MMBtu/hr) up to and including 5.0 MMBtu/hr. The purpose of this rule is to limit 

emissions of NOx, carbon monoxide (CO), sulfur dioxide (SO2), and particulates from 

units subject to this rule. 

Rule 4307 was adopted on December 15, 2005 to establish emissions limits and control 

requirements for these units which were previously exempt because of their smaller 

size. Since its adoption, the rule has been amended three times. The October 2008 

amendments strengthened the rule by removing some exemptions, imposing NOx limits 

of 9 or 12 ppmv for new and replacement units, and adding a menu-approach for 

particulate matter control that also encompasses SOx controls. The rule was amended 

again in 2011 to specifically incorporate tree nut pasteurizers as a separate type of unit. 

EPA published a direct final approval of the 2011 amendments to Rule 4307 on 

February 12, 2015 and deemed this rule as being at least as stringent as established 

RACT requirements. NOx emissions have been controlled by over 84% for units in this 

source category. 

Source Category 

Based on District permits information, there are currently 540 permitted and PermitExempt Equipment Registration (PEER) units subject to Rule 4307 requirements. 

Facilities with units subject to this rule represent a wide range of industries, including 

but not limited to, medical facilities, educational institutions, office buildings, prisons, 

military facilities, hotels, and industrial facilities. 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.32 0.32 0.31 0.30 0.30 0.29 0.29 0.28 0.28 

NOx 0.49 0.46 0.43 0.41 0.39 0.38 0.37 0.36 0.34 

SOx 0.15 0.15 0.06 0.06 0.06 0.06 0.06 0.06 0.06 

Winter Average - Tons per day 

PM2.5 0.32 0.31 0.31 0.30 0.30 0.29 0.28 0.28 0.27 

NOx 0.47 0.45 0.42 0.40 0.38 0.37 0.36 0.35 0.33 

SOx 0.15 0.14 0.06 0.06 0.06 0.06 0.06 0.05 0.05 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from boilers, steam generators, and process heaters 2.0 to 

5.0 MMBtu/hr are lower than the BACM/MSM significance thresholds. Therefore, the 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-44 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Clean Air Act does not require a control measure evaluation for this source category for 

the purpose of satisfying BACM/MSM requirements; however, the District has still 

conducted a full control measure evaluation for this source category. 

How does District Rule 4307 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG or NSPS requirements for this source category. 

ACT 

 EPA–453/R-93-034 (Alternative Control Techniques Document–NOx Emissions from 

Process Heaters) 

The District evaluated the requirements contained within the ACT for NOx Emissions 

from Process Heaters and found no requirements that were more stringent than those 

already in Rule 4307. 

 EPA–453/R-94-022 (Alternative Control Techniques Document–NOx Emissions from 

Industrial/Commercial/Institutional Boilers) 

The District evaluated the requirements contained within the ACT for NOx Emissions 

from Industrial/Commercial/Institutional Boilers and found no requirements that were 

more stringent than those already in Rule 4307. 

 EPA–453/R-94-023 (Alternative Control Techniques Document–NOx Emissions from 

Utility Boilers) 

The District evaluated the requirements contained within the ACT for NOx Emissions 

from Utility Boilers and found no requirements that were more stringent than those 

already in Rule 4307. 

NESHAP/ MACT 

 40 CFR 63 Subpart DDDDD (NESHAP for Major Sources: Industrial, Commercial, 

and Institutional Boilers and Process Heaters) 

40 CFR 63 Subpart DDDDD was amended on January 31, 2013 to include new 

emission limits for PM, CO, and total selective metals (TSM), replace numeric dioxin 

emission limits with work practice standards, add new subcategories of facilities, and 

add alternative monitoring approaches for compliance with the PM limit. The PM limits 

in 40 CFR 63 Subpart DDDDD would not apply to Rule 4307 sources. Subpart DDDDD 

contains alternative requirements for units less than 10 MMBtu/hr and requires tuning 

every 2-5 years. 

The District evaluated the requirements contained within 40 CFR 63 Subpart DDDDD 

and found no requirements that were more stringent than those already in Rule 4307. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-45 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 4307 compare to rules in other air districts? 

SCAQMD 

 Rule 1146.1 (Emissions of Oxides of Nitrogen from Small Industrial, Institutional, and 

Commercial Boilers, Steam Generators, and Process Heaters) 

The District evaluated the requirements contained within SCAQMD’s Rule 1146.1 and 

found no requirements that were more stringent than those already in Rule 4307. 

BAAQMD 

 Regulation 9 Rule 7 (Nitrogen Oxides and Carbon Monoxide from Industrial, 

Institutional, and Commercial Boilers, Steam Generators, and Process Heaters) 

The District evaluated the requirements contained within BAAQMD’s Regulation 9 Rule 

7 and found no requirements that were more stringent than those already in Rule 4307. 

 Regulation 9 Rule 10 (Nitrogen Oxides and Carbon Monoxide from Boilers, Steam 

Generators and Process Heaters in Petroleum Refineries) 

The District evaluated the requirements contained within BAAQMD’s Regulation 9 Rule 

10 and found no requirements that were more stringent than those already in Rule 

4307. 

SMAQMD 

 Rule 411 (NOx from Boilers, Process Heaters and Steam Generators) 

The District evaluated the requirements contained within SMAQMD’s Rule 411 and 

found no requirements that were more stringent than those already in Rule 4307. 

VCAPCD 

 Rule 74.15.1 (Boilers, Steam Generators, and Process Heaters) 

The District evaluated the requirements contained within VCAPCD’s Rule 74.15.1 and 

found no requirements that were more stringent than those already in Rule 4307. 

Additional Emission Reduction Opportunities 

The District has adopted numerous rule amendments over the years for boilers that 

have significantly reduced emissions from units subject to Rule 4307. Most units 

subject to Rule 4307 are fired on Public Utilities Commission (PUC) quality natural gas, 

and are inherently low-emitters of SOx and PM2.5 emissions. The NOx limits 

implemented through Rule 4307 and its amendments will reduce emissions from over 

1,000 small (2-5 MMBtu/hr) boilers in the Valley when fully implemented, including from 

units that were previously exempt. As a result of these regulatory efforts, the emissions 

inventory for NOx from these boilers has dropped from 3.81 tpd in 2005 to 0.41 tpd in 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-46 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

2015. Additional emissions reductions are forthcoming with existing Rule 4307 as 

additional compliance dates are approaching in 2016. Given the significant efforts and 

investments already made to reduce emissions from this source category, there are little 

remaining opportunities for obtaining additional emissions reductions. 

EMx as Potential Control 

The District researched post-combustion controls such as EMx, the second generation 

of the SCONOx technology that reduces NOx, SOx, CO, and volatile organic compound 

(VOC) emissions. This technology has not been achieved in practice (AIP) in the 

District and there is no available data that indicates that SCONOx or EMx has been 

installed on boilers, particularly in this size range, even though the manufacturer’s 

website states that the technology is transferrable to industrial boilers. Based on 

research of the best available controls from EPA and other air districts, the SCONOx 

and EMx systems have only been utilized by power plants for the control of turbine 

emissions. In fact, cost effectiveness analyses conducted by the District for the 

installation of SCONOx/EMx units on large power plant turbine installations within the 

Valley have shown that this technology is not cost effective. Given the high cost 

effectiveness demonstrated for turbines and lack of demonstrated practice with boilers, 

this technology is not feasible or cost effective for reducing emissions from this 

category. 

 

PM2.5 Limits for Alternative Fuels 

The majority of boilers (2-5 MMBtu/hr) in the Valley combust PUC-quality natural gas; 

PUC natural gas contains a very low sulfur content and inherently has low emissions. 

Few boilers in the Valley use alternative fuels for their combustion processes. 

Alternative fuels include digester gas, produced gas, and liquid fuel. Units fired on 

digester gas or produced gas are already required to use inlet gas scrubbers to meet 

District rule requirements. Current rule language requires that on and after July 1, 2015 

liquid fuel shall be used only during a PUC quality natural gas curtailment period 

provided it contains no more than 15 ppm sulfur. While the currently limited use of 

liquid fuel will become even more strictly limited by July 2015, the feasibility of reducing 

PM emissions through adding PM2.5 limits for units using liquid fuel was explored as 

part of the District’s comprehensive control measure evaluation. 

There are 24 liquid fuel fired units in the Valley (2-5 MMBtu/hr) with an average 

combined emissions inventory of approximately 0.00077 tons per year of total PM. The 

low emissions inventory is attributed to the fact that these units either utilize liquid fuel 

as a backup if there is a natural gas curtailment or are minimally operated units. The 

following three technologies were evaluated as potential control options for reducing PM 

emissions: baghouses, electrostatic precipitators (ESPs), and wet scrubbers. 

Baghouses control total PM and PM2.5 emissions by 90-99%; ESPs control total PM 

and PM2.5 emissions by 90-99%; and wet scrubbers control large particulates (>PM5) 

by 99% and PM2.5 emissions by approximately 50%.27 However, baghouses are 

 

27 Northeast States for Coordinated Air Use Management. (November 2008) Applicability and Feasibility of NOx, 

SO2, and PM Emissions Control Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. Retrieved 

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

C-47 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

typically not used with liquid-fired boilers due to the potential clogging of the baghouse 

and are therefore not a recommended technology due to infeasibility and safety 

issues.28 

PM Potential Emissions Reductions for an ESP and Scrubber 

For the purposes of these calculations, the following assumptions were made: 

1. For simplicity, the analysis will evaluate the cost effectiveness of these 

technologies for total PM reductions from liquid fuel fired units. 

2. The PM control efficiency of an ESP is 99%. 

3. The PM control efficiency of a scrubber is 99%. 

Potential Emissions Reductions (ESP) = (Total PM Emissions) x (Control Efficiency) 

Potential Emissions Reductions (ESP) = 0.00077 tons/year X 0.99 

Potential Emissions Reductions (ESP) = 0.00076 tons/ year (tpy) 

Potential Emissions Reductions (scrubber) = (Total PM Emissions) x (Control Efficiency) 

Potential Emissions Reductions (scrubber) = 0. 00077 tons/year X 0.99 

Potential Emissions Reductions (scrubber) = 0.00076 tons/ year (tpy) 

Annualized Cost of an ESP and Wet Scrubber 

The capital cost for the installation of an ESP for a 1-5 MMBtu/hr boiler ranges from 

$90,000 - $100,000 and the annual maintenance cost is $1,000-$2,000.29 For the wet 

scrubber system, EPA estimated the annualized cost at $5,300-$102,000 per sm3

/sec 

at an average air flow rate of 0.7- 47 sm3/sec.30 The following assumptions were made 

for this cost effectiveness analysis: 

1. The capital cost of an ESP is assumed to be the median of the range above 

($95,000). 

2. The annual maintenance cost of an ESP is assumed to be the median of the 

range above ($1,500). 

 http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=0CB8QFjAA&url=http%

3A%2F%2Fwww.nescaum.org%2Fdocuments%2Fici-boilers-20081118-

final.pdf%2F&ei=7nfvVIivFai1sAT07IHIAg&usg=AFQjCNFBdQn7MVAibSTZIbHV7-

ojXkVlXQ&bvm=bv.86956481,d.cWc. 28 Northeast States for Coordinated Air Use Management. (November 2008) Applicability and Feasibility of NOx, 

SO2, and PM Emissions Control Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. Retrieved 

from 

http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=0CB8QFjAA&url=http%

3A%2F%2Fwww.nescaum.org%2Fdocuments%2Fici-boilers-20081118-

final.pdf%2F&ei=7nfvVIivFai1sAT07IHIAg&usg=AFQjCNFBdQn7MVAibSTZIbHV7-

ojXkVlXQ&bvm=bv.86956481,d.cWc. 29 Catherine Roberts. (March 2009) Information on Air Pollution Control Technology for Woody Biomass Boilers. 

Environmental Protection Agency Office of Air Quality Planning and Standards and Northeast States for Coordinated 

Air Use Management. 

30 EPA. (2002). Air Pollution Control Technology Fact Sheet: Spray-Chamber/Spray-Tower Wet Scrubber. Retrieved 

from http://www.epa.gov/ttncatc1/dir1/fsprytwr.pdf. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-48 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

3. The annualized cost of a wet scrubber system is assumed to be the median of 

the range above ($53,650 per sm3/sec). 

4. The average air flow rate for a wet scrubber system is assumed to be the median 

of the range above (23.85 sm3

/sec). 

5. The total capital and maintenance cost of an ESP will be calculated by 

multiplying the cost of 1 unit by the total number of units. 

6. The total annualized cost of a wet scrubber will be calculated by multiplying the 

annualized cost of 1 unit by the total number of units. 

7. Lifetime of the ESP is 10 years at 10% interest. To account for this, the 

annualized capital cost will be calculated by multiplying the total capital cost by 

the capital recovery factor of 0.1627 and adding the annual maintenance costs. 

Annual Cost (ESP) = (Total Capital Cost) x (0.1627) + (Annual Maintenance Cost) 

Annual Cost (ESP) = ($95,000 x 24) x (0.1627) + ($1,500 x 24) 

Annual Cost (ESP) = $406,956/year 

Annual Cost (scrubber) = (Annualized Cost of 1 unit) x (Number of Units) x 

(Average Flow Rate) 

Annual Cost (scrubber) = ($53,650/ sm3/sec) x (24) x (23.85 sm3/sec) 

Annual Cost (scrubber) = $30,709,260/ year 

Cost Effectiveness of an ESP and Wet Scrubber 

Cost Effectiveness = Annual Cost / Annual Emissions Reductions 

Cost Effectiveness (ESP) = ($406,956/year) / (0.00076 tons/ year) 

Cost Effectiveness (ESP) = $535,468,421/ton of PM 

Cost Effectiveness (scrubber) = ($30,709,260/year) / (0.00076 tons/ year) 

Cost Effectiveness (scrubber) = $40,406,921,053/ton of PM 

As illustrated above, neither PM control technology is a cost effective option for this 

source category. The cost of the ESP technology does not include costs of retrofitting 

equipment and/or the facility or compliance monitoring costs, which would drive the cost 

effectiveness up even more. 

Evaluation Findings

Even though boilers, steam generators, and process heaters 2.0 to 5.0 MMBtu/hr are 

not a significant source of PM2.5, NOx, or SOx in the Valley, the District has evaluated 

all potential control technologies and all control technologies achieved in practice in 

other areas or included in other state implementation plans. As demonstrated above, 

Rule 4307 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 this 

source category. As the District continues to develop new attainment plans that 

address more stringent National Ambient Air Quality Standards, the District will continue 

to evaluate potential opportunities to reduce emissions from this source category in the 

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

C-49 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.9 RULE 4308 BOILERS, STEAM GENERATORS AND PROCESS HEATERS–

0.075 MMBTU/HR TO LESS THAN 2.0 MMBTU/HR 

Discussion 

This rule applies to any person who supplies, sells, offers for sale, installs, or solicits the 

installation of any boiler, steam generator, process heater or water heater with a rated 

heat input capacity greater than or equal to 0.075 MMBtu/hr and less than 2.0 

MMBtu/hr. The purpose of this rule is to limit NOx and carbon monoxide (CO) 

emissions from units within this source category. As a point of sale rule, Rule 4308 

achieves emissions reductions as units subject to the rule are replaced over time. This 

rule has resulted in more than 93% control of emissions from this source category. 

Rule 4308 was adopted on October 20, 2005 to establish NOx emissions limits for these 

units which were previously exempt from District regulations because of their small size. 

The rule was amended in December 2009 to lower the NOx emissions limits to 20 ppmv 

for units fired on natural gas, with the exception of instantaneous water heaters and 

pool heaters greater than or equal to 0.075 MMBtu/hr but less than or equal to 0.4 

MMBtu/hr. In 2013, the District determined that a 20 ppmv limit was now 

technologically feasible and cost effective for instantaneous water heaters 0.075 

MMBtu/hr to 0.4 MMBtu/hr; as such, that emission limit was lowered during the 

November 2013 amendment of Rule 4308. EPA published a direct final approval the 

2013 amendments to Rule 4308 on February 12, 2015. 

Source Category 

Units subject to Rule 4308 are used in settings including, but not limited to, apartment 

buildings, large homes, small businesses, commercial buildings, manufacturing 

facilities, government facilities, restaurants, hotels, hospitals, educational institutions, 

and religious organizations. Affected persons include water heater manufacturers, 

plumbing wholesalers, supply stores, plumbers, contractors, and end-users. This pointof-sale approach allows the District to achieve NOx emission reductions without forcing 

immediate replacement of existing units to comply with rule requirements and thus 

placing an undo financial burden on the consumer. 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.61 0.60 0.59 0.58 0.57 0.56 0.55 0.54 0.53 

NOx 0.92 0.87 0.82 0.77 0.74 0.72 0.70 0.67 0.65 

SOx 0.28 0.28 0.12 0.11 0.11 0.11 0.11 0.10 0.10 

Winter Average - Tons per day 

PM2.5 0.59 0.58 0.57 0.56 0.55 0.54 0.53 0.52 0.51 

NOx 0.89 0.84 0.79 0.74 0.72 0.69 0.67 0.65 0.63 

SOx 0.28 0.27 0.11 0.11 0.11 0.11 0.10 0.10 0.10 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-50 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from these units are lower than the BACM/MSM significance 

thresholds. Therefore, the Clean Air Act does not require a control measure evaluation 

for this source category for the purpose of satisfying BACM/MSM requirements; 

however, the District has still conducted a full control measure evaluation for boilers, 

steam generators, and process heaters 0.075 to 2.0 MMBtu/hr. 

How does District Rule 4308 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, NSPS, NESHAP, or MACT requirements for boilers, steam 

generators, and process heaters of this size. 

ACT 

 EPA – 453/R-93-034 (Alternative Control Techniques Document—NOx Emissions 

from Process Heaters) 

The District evaluated the requirements contained within the ACT for NOx Emissions 

from Process Heaters and found no requirements that were more stringent than those 

already in Rule 4308. 

 EPA – 453/R-94-022 (Alternative Control Techniques Document—NOx Emissions 

from Industrial/Commercial/ Institutional Boilers)

The District evaluated the requirements contained within the ACT for NOx Emissions 

from Industrial/Commercial/Institutional Boilers and found no requirements that were 

more stringent than those already in Rule 4308. 

 EPA – 453/R-94-023 (Alternative Control Techniques Document—NOx Emissions 

from Utility Boilers)

The District evaluated the requirements contained within the ACT for NOx Emissions 

from Utility Boilers and found no requirements that were more stringent than those 

already in Rule 4308. 

State Regulations 

There are no state regulations that apply to this source category. 

How does District Rule 4308 compare to rules in other air districts? 

SCAQMD 

 Rule 1146.2 (Emissions of Oxides of Nitrogen From Large Water Heaters and Small 

Boilers and Process Heaters) 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-51 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

The District evaluated the requirements contained within SCAQMD’s Rule 1146.2 and 

found no requirements that were more stringent than those already in Rule 4308. 

BAAQMD 

 Regulation 9 Rule 6 (Nitrogen Oxides Emissions from Natural Gas-Fired Boilers and 

Water Heaters) 

The District evaluated the requirements contained within BAAQMD’s Regulation 9 Rule 

6 and found no requirements that were more stringent than those already in Rule 4308. 

 Regulation 9 Rule 7 (Nitrogen Oxides and Carbon Monoxide from Industrial, 

Institutional, and Commercial Boilers, Steam Generators, and Process Heaters) 

The District evaluated the requirements contained within BAAQMD’s Regulation 9 Rule 

7 and found no requirements that were more stringent than those already in Rule 4308. 

SMAQMD 

 Rule 411 (NOx from Boilers, Process Heaters and Steam Generators)

The District evaluated the requirements contained within SMAQMD’s Rule 411 and 

found no requirements that were more stringent than those already in Rule 4308. 

 Rule 414 (Water Heaters, Boilers and Process Heaters Rated Less Than 1,000,000 

Btu Per Hour)

The District evaluated the requirements contained within SMAQMD’s Rule 414 and 

found no requirements that were more stringent than those already in Rule 4308. 

VCAPCD 

 Rule 74.11.1 (Large Water Heaters and Small Boilers)

VCAPCD Rule 74.11.1 was amended on September 11, 2012 to implement a 20 ppmv 

NOx emission limit for all natural gas fired units with a rated heat input of 0.075-1.0 

MMBtu/hr, with the exception of pool heaters. All District units 0.075-1.0 MMBtu/hr (with 

the exception of pool heaters 0.075-0.4 MMBtu/hr) are currently subject to a 20 ppmv 

NOx emission limit. As such, there are no requirements in VCAPCD Rule 74.11.1 that 

are more stringent than those already in Rule 4308. 

 Rule 74.15.1 (Boilers, Steam Generators, and Process Heaters)

VCAPCD Rule 74.15.1 was also amended on September 11, 2012. The amendments 

incorporated a 20 ppmv NOx emission limit for natural gas fired units 1-2 MMBtu/hr and 

other administrative recordkeeping requirements. Rule 4308 contains a 20 ppmv NOx 

emission limit for all natural gas fired units 1-2 MMBtu/hr so the amendments did not 

implement any requirements more stringent than the requirements in District Rule 4308.

Therefore, there are no requirements in VCAPCD Rule 74.15.1 that are more stringent 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-52 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

than those already in Rule 4308. 

Placer County APCD (PCAPCD) 

 Rule 247 (Natural Gas-Fired Water Heaters, Small Boilers and Process Heaters) 

PCAPCD Rule 247 was amended on February 13, 2014; however, the amendments 

incorporated the same emission limits contained within District Rule 4308. Therefore, 

there are no requirements in PCAPCD Rule 247 that are more stringent than those 

already in Rule 4308. 

Additional Emission Reduction Opportunities 

Mobile Home Exemption 

The District evaluated the possibility of removing the exemption for water heaters used 

in mobile homes because multiple air districts do not exempt these sources in their 

analogous rules. However, because those air districts have different rule structures with 

regards to the size of devices regulated, District Rule 4308 requirements are as 

stringent as the other districts’ rules. 

For example, SCAQMD Rule 1146.2 does not regulate mobile home water heaters, per 

the definition for type 1 units, because they are subject to Rule 1121 (Control of 

Nitrogen Oxides from Residential Type, Natural Gas-Fired Water Heaters). SCAQMD 

Rule 1121 regulates units less than 0.075 MMBtu/hr, which is out of the size range of 

District Rule 4308. Similarly, in SMAQMD Rule 414, mobile home units are regulated in 

the size range of units less than 0.075 MMBtu/hr. District Rule 4902 (Residential Water 

Heaters) applies to units less than 0.075 MMBtu/hr and currently regulates mobile home 

water heaters with the same emission limit contained in SCAQMD and SMAQMD rules. 

BAAQMD Rule Regulation 9 Rule 6 regulates all units less than 2 MMBtu/hr, essentially 

combining the requirements of District Rules 4308 and 4902. 

In addition, after researching the size of mobile home water heaters, it was found that 

mobile home water heaters are not available in the 0.075-2.0 MMBtu/hr size range. 

Four mobile home retailers and three mobile home manufacturers were contacted to 

inquire about the size of mobile home water heaters. All seven contacts stated that the 

average size of a mobile home water heater is 30-40 gallons, whereas a 0.075 

MMBtu/hr water heater is approximately 80 gallons. One manufacturer and one retailer 

stated that 50 gallon mobile home water heaters are available but rarely used. If the 

exemption for mobile home water heaters in Rule 4308 were to be removed, it would 

not result in any additional emissions reductions since units do not exist in this size 

range. 

Recreational Vehicle Exemption 

The District evaluated the potential opportunity to remove the exemption for recreational 

vehicles (RVs). Stakeholder input indicates that there are very few units in RVs that fall 

under the size category subject to this rule. Most units in RVs are 12 gallons, which is 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-53 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

significantly smaller than the 80 gallon size of a typical 0.075 MMBtu/hr unit.31 Also, RV 

units are typically not used on a frequent basis and thus are small contributors to the 

NOx emissions of this source category. Other air districts, such as SCAQMD and 

BAAQMD, include this exemption in their rules. Removing this exemption would result 

in little to no emissions reductions because of the lack of units within this size range and 

the intermittent use of units in RVs. 

Evaluation Findings 

Even though boilers, steam generators, and process heaters 0.075 to 2.0 MMBtu/hr are 

not a significant source of PM2.5, NOx, or SOx in the Valley, the District has evaluated 

all potential control technologies and all control technologies achieved in practice in 

other areas or included in other state implementation plans. As demonstrated above, 

Rule 4308 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 this 

source category. As the District continues to develop new attainment plans that 

address more stringent National Ambient Air Quality Standards, the District will continue 

to evaluate potential opportunities to reduce emissions from this source category in the 

Valley. 

 

31 SJVAPCD. (2009). Final Staff Report for Amendments to Rule 4308 (Boilers, Steam Generators, and Process 

Heaters—0.075 MMBtu/hr to less than 2.0 MMBtu/hr). 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

C.10 RULE 4309 DRYERS, DEHYDRATORS, AND OVENS 

Discussion 

Rule 4309 is applicable to any dryer, dehydrator, or oven that is fired on gaseous fuel, 

liquid fuel, or is fired on gaseous and liquid fuel sequentially, and the total rated heat 

input for the unit is 5.0 million British thermal units per hour (5.0 MMBtu/hr) or greater. 

The purpose of this rule is to limit NOx and carbon monoxide (CO) emissions from 

these units, which result from the combustion of fuel in the burners. The rule enforces 

NOx emission limits between 3.5-12 ppmv for four categories of equipment, achieving 

approximately 34% control of total NOx emissions. 

Rule 4309 was adopted on December 15, 2005 and has not been amended. EPA 

finalized approval of Rule 4309 on May 30, 2007 and deemed this rule as being at least 

as stringent as established RACT requirements. 

Source Category 

Dryers, dehydrators, and ovens are utilized in a broad range of industries. Analyses 

performed for the rule adoption separated the unit types into four broad industry groups: 

dehydrators; asphalt/concrete; milk, cheese, and other dairy processing; and other. 

Dryers, dehydrators, and ovens currently operate either seasonally or year-round 

depending on the industry and the unit’s purpose within the process. There are 126 

units subject to this rule, ranging in size from 5.0 MMBtu/hr to 200 MMBtu/hr. 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.85 0.88 0.90 0.92 0.95 0.98 1.00 1.02 1.04 

NOx 0.20 0.20 0.21 0.22 0.22 0.23 0.24 0.24 0.25 

SOx 0.47 0.48 0.49 0.50 0.52 0.53 0.55 0.56 0.57 

Winter Average - Tons per day 

PM2.5 0.80 0.82 0.85 0.87 0.89 0.92 0.95 0.96 0.98 

NOx 0.18 0.18 0.19 0.19 0.20 0.20 0.21 0.21 0.22 

SOx 0.38 0.39 0.40 0.41 0.42 0.43 0.44 0.45 0.46 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from dryers, dehydrators, and ovens are lower than the 

BACM/MSM significance thresholds. Therefore, the Clean Air Act does not require a 

control measure evaluation for this source category for the purpose of satisfying 

BACM/MSM requirements; however, the District has still conducted a full control 

measure evaluation for dryers, dehydrators, and ovens. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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How does District Rule 4309 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, NSPS, NESHAP, or MACT requirements for this source 

category. 

Alternative Control Techniques (ACT) 

 EPA – 453/R-94-004 (Alternative Control Techniques Document–NOx Emissions 

from Cement Manufacturing) 

The District evaluated the requirements contained within the ACT for NOx Emissions 

from Cement Manufacturing and found no requirements that were more stringent than 

those already in Rule 4309. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 4309 compare to rules in other air districts? 

There are no analogous rules for this source category in BAAQMD, SMAQMD, or 

VCAPCD. 

SCAQMD 

 SCAQMD Rule 1147 (NOx Reductions from Miscellaneous Sources) 

The District evaluated the requirements contained within SCAQMD’s Rule 1147 and 

found no requirements that were more stringent than those already in Rule 4309. 

Additional Emission Reduction Opportunities 

The adoption of Rule 4309 has considerably reduced NOx and PM emissions from this 

source category. The emissions inventory for NOx from dryers, dehydrators, and ovens 

has dropped from 1.93 tpd in 2005 to 0.20 tpd in 2012. Although this source category 

had a relatively small emissions inventory prior to the adoption of Rule 4309, 

stakeholders have installed control equipment and modified their operations 

considerably to reduce emissions to ultra-low levels. Given the significant effort already 

made to reduce emissions from this source category, there are little remaining 

opportunities for obtaining additional emissions reductions. 

Asphalt Plants 

PUC-quality natural gas fuel is part of the BACT requirements for asphalt plants for the 

District, BAAQMD, and SCAQMD. There are currently nine asphalt plants in the Valley 

that do not utilize PUC-quality natural gas because some facilities are physically too far 

removed from natural gas lines to use natural gas. Six of these asphalt plants use LPG 

fuel or propane to comply with the same gaseous fuel fired limit as PUC-quality natural 

gas-fired facilities. The other three facilities utilize diesel gas; however, none of the 

facilities operate full time and their combined NOx emissions are less than 7 tons per 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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year. Therefore, requiring natural gas for all asphalt facilities is not a feasible 

opportunity that would generate significant emission reduction benefits. 

The District evaluated the potential opportunity to lower the NOx emissions limits for 

asphalt plants from the current limits of 4.3 ppmv (gaseous fuel) and 12 ppmv (liquid 

fuel) to make them closer or equivalent to the BAAQMD BACT limit of 3.9 ppmv @ 19% 

O2. To meet this limit, operators would need to install low-NOx burners or modify 

existing burners to comply with lower limits; however, all of the asphalt plants have 

already installed new low-NOx burners or modified their units to meet the 4.3 ppmv @ 

19% O2 and 12 ppmv @ 19% O2 emissions limits in Rule 4309. 

Based on District permit records, a good portion of the asphalt units fired on gaseous 

fuel would be in compliance with a 3.9 ppmv @ 19% O2 NOx limit. However, reducing 

the limit to 3.9 ppmv @ 19% O2 would reduce the margin of compliance the facility has, 

and would make it more difficult for the facility to show continued compliance. In 

addition, reducing the limit from 4.3 ppmv to 3.9 ppmv would be an administrative 

change in nature, since it would not require any additional control equipment or changes 

in operating techniques or practices to comply, and it would not generate additional 

emissions reductions from these units. 

A higher NOx limit is required for the liquid fuel fired facilities due to the characteristics 

of liquid fuels. In BAAQMD’s BACT guideline for hot mix asphalt facilities, there is a 

clause that states, “For remote locations where natural gas is not available, liquefied 

petroleum gas may be permitted up to 38 ppmvd NOx @ 15% O2 and fuel oil < 0.05 wt. 

% sulfur may be permitted up to 55 ppmvd NOx @ 15% O2.” This equates to 12.24 

ppmv @ 19% O2 for liquefied petroleum gas and 17.73 ppmv @ 19% O2 for fuel oil. 

The District’s Permits department enforces a limit of 4.3 ppmv @ 19% O2 for liquefied 

petroleum gas and 12 ppmv for other liquid fuels. Therefore, the District’s requirements 

are more stringent than both limits in the BAAQMD BACT guideline. 

Dehydrators 

Rule 4309 requires dehydrators be fired on PUC-quality natural gas. The District 

evaluated the potential opportunity to further reduce emissions by requiring the use of 

low-NOx burners; however, this option is infeasible due to the potential negative effects 

on product quality. Additionally, enforcing the emissions limits is potentially infeasible 

because monitoring and source testing of dehydrators is difficult to perform, if not 

impossible. 

Dryers 

The District considered the potential opportunity to add a requirement for the use of dust 

collection devices, such as baghouses. Through the District’s New Source Review Rule 

(Rule 2201), dust collection devices are already in place in the permit requirements for 

units that create PM emissions from handling the products they are drying. These 

facilities install baghouses or cyclones because they do not want to blow their product 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-57 Appendix C: BACM and MSM for Stationary and Area Sources 

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out of their stack. While baghouses can foster PM2.5 reductions, cyclones are 

generally not as effective in removing fine particulate matter. 32

The District researched the potential installation of baghouses on dryers. However, it is 

technologically infeasible to install a baghouse for some of the dryers subject to Rule 

4309. The purpose of a dryer is to remove moisture from a product, which means that 

the exhaust from dryers have a high humidity. Baghouses can have problems with high 

humidity exhaust streams because the bags become caked. The air stream would have 

to be dried somehow before entering the baghouse. As a result, this is not a feasible 

opportunity at this time. 

The District also evaluated the possibility of removing the exemption for column dryers 

and dryers with no stack and one or more sides open to the atmosphere. However, 

compliance with the proposed limits would be difficult to determine reliably given the 

design of these units. Column dryers have large fans to move the warm air through the 

material and air escapes through screens that cover the side of the dryer. Similarly, 

dryers with no stack and at least one side open deal with air escape, which makes 

monitoring and testing emissions difficult, if not impossible. Since source testing of 

these types of dryers is difficult due to the fact that there is not a stack where all 

emissions are exhausted, this is not a technologically feasible opportunity at this time. 

Evaluation Findings

Even though dryers, dehydrators, and ovens are not a significant source of PM2.5, 

NOx, or SOx in the Valley, the District has evaluated all potential control technologies 

and all control technologies achieved in practice in other areas or included in other state 

implementation plans. As demonstrated above, Rule 4309 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 this source category. As the District 

continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from dryers, dehydrators, and ovens in the Valley. 

 

 

32 Northeast States for Coordinated Air Use Management. (November 2008) Applicability and Feasibility of NOx, 

SO2, and PM Emissions Control Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. Retrieved 

from 

http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=0CB8QFjAA&url=http%

3A%2F%2Fwww.nescaum.org%2Fdocuments%2Fici-boilers-20081118-

final.pdf%2F&ei=7nfvVIivFai1sAT07IHIAg&usg=AFQjCNFBdQn7MVAibSTZIbHV7-

ojXkVlXQ&bvm=bv.86956481,d.cWc. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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C.11 RULE 4311 FLARES 

The purpose of Rule 4311 is to limit volatile organic compounds (VOC), NOx, and SOx 

emissions from any operation involving the use of flares, with the exception of a limited 

list of sources identified in the rule. Any unreasonable restrictions on flaring could 

potentially result in catastrophic consequences which may lead to explosions resulting 

in loss of property, injury, and potentially loss of human life. 

Flaring is a high temperature oxidation process used to burn combustible components, 

primarily hydrocarbons, of waste gases from industrial operations, primarily for the 

purpose of controlling emissions and as a safety device. The majority of waste gases 

flared are natural gas, propane, ethylene, propylene, butadiene and butane. During 

combustion, gaseous hydrocarbons react with atmospheric oxygen to form carbon 

dioxide (CO2) and water. In some waste gases, carbon monoxide (CO) is the major 

combustible component. In addition to serving as safety devices, the combustion of 

industrial gas streams in flares is also recognized as a means of reducing greenhouse 

gases (GHG), in line with California’s AB32 GHG reduction goals and emerging federal 

GHG reduction goals. 

Combustion efficiency depends on flame temperature, residence time in the combustion 

zone, vent gas flammability, auto ignition temperature, heating value, and turbulent 

mixing. When operated at an optimal combination of these factors, flares have a 

destruction efficiency of 98 percent or greater. Complete combustion converts all VOCs 

to CO2 and water; however incomplete combustion generates air pollutants such as 

NOx, sulfur dioxide, carbon monoxide, and particulate matter. Additionally, there is a 

possibility of release of hydrocarbons if they have not been completely combusted. To 

prevent the creation of smoke or soot, which is influenced by fuel characteristics and the 

amount and distribution of oxygen in the combustion zone, most industrial flares are 

steam-assisted or air-assisted. In some cases, another fuel must be added to flare gas 

to achieve the minimum heating value of 200-250 Btu/ft3

 required for complete 

combustion. 

There are two general types of flares: open and enclosed flares. Flares are further 

categorized by the height of the flare tip, and by the method of enhancing combustion 

by mixing at the flare tip (i.e., steam-assisted, air-assisted, pressure assisted, or nonassisted). 

Flaring in the San Joaquin Valley 

Flares serve two basic functions: as a safety device during unforeseeable and 

unpreventable emergency situations/standby situations and less commonly as a primary 

emissions control device for VOC emissions. As safety devices, flares are necessary to 

prevent catastrophic consequences such as the release of toxic gases and explosions, 

which could result in loss of property, injury, and loss of human life. In the Valley, the 

vast majority of flares are employed as emergency/standby control devices, which is in 

direct contrast with other regions, such as North Dakota, where flares are used for 

primary disposal of waste gas from oil and natural gas production. Also, while regions 

like North Dakota utilize flares to combust associated gas during the initial extraction 
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phase of the production process (i.e., directly from the well), Valley flares are typically 

used further down the process chain, primarily as a safety device associated with gas 

collection systems, resulting in far lower quantities of flared gas. 

Valley operators have generally evaluated all feasible and cost effective options for 

handling and disposing of the associated/waste gases generated by their facilities and 

installing a flare as the primary method of disposal would be the last resort. In addition 

to Rule 4311 requirements to evaluate and implement all feasible measures to reduce 

flaring activities, other associated rules also implement stringent capture and control of 

these gases. Therefore, most facilities have made significant investments to capture 

and utilize these process gases in a variety of methods and this ability has allowed 

facilities to maximize income generation. Some capture and treat these gases and sell 

them to natural gas/utility providers (generates monetary income), while others utilize 

these gases on-site to fuel equipment that generates electricity and/or provides process 

heating (saves fuel costs). In fact, most Valley facilities regard flaring events as a 

significant monetary cost, through directly lost profit or increased fuel costs. 

In the District’s evaluation of Valley flaring activity,33 nearly all of the flaring events were 

either one-time events due to new control equipment installation or maintenance of 

existing equipment, and therefore not repeated, or in response to emergency situations 

or process upsets. For example, one Valley facility (light oil production facility) 

experienced abnormally high flaring because the sales transmission pipeline was offline 

for repairs, an event beyond their control. Another facility (wastewater treatment plant) 

normally uses the fuel onsite to produce electricity and process heating, but could not 

do so because additional air pollution control devices were being installed. 

Flares in the Valley subject to the requirements in Rule 4311 are employed by a diverse 

group of industries for a wide variety of applications, as illustrated by the below list. In 

contrast, other air districts’ flare rules generally limit the applicability of their rules to 

petroleum production facilities or refineries. 

 Gas plants 

 Heavy oil production/ thermally enhanced oil recovery 

 Light oil production 

 Refinery operations 

 Wastewater treatment plants 

 Cheese production 

 Wine 

 Dairy operations 

 Flat glass production 

 Correctional facility 

 

33 SJVAPCD. (2014). Rule 4311 (Flares) Further Study. Retrieved February 3, 2015 from: 

http://valleyair.org/Air_Quality_Plans/docs/R4311.pdf. 
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 2015 Plan for the 1997 PM2.5 Standard 

Emissions Inventory 

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.16 0.16 0.16 0.16 0.16 0.16 0.17 0.17 0.17 

NOx 0.56 0.56 0.56 0.55 0.55 0.54 0.54 0.54 0.54 

SOx 0.33 0.33 0.33 0.33 0.32 0.32 0.33 0.32 0.32 

Winter Average - Tons per day 

PM2.5 0.16 0.16 0.16 0.16 0.16 0.16 0.17 0.17 0.17 

NOx 0.56 0.56 0.56 0.55 0.55 0.54 0.54 0.54 0.54 

SOx 0.33 0.33 0.33 0.33 0.32 0.32 0.33 0.32 0.32 

As detailed in Chapter 5, the significance threshold for source categories for the 

purpose of evaluating the application of BACM and MSM requirements is 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from flares are lower than the BACM/MSM significance 

thresholds. Therefore, the Clean Air Act does not require a control measure evaluation 

for this source category for the purpose of satisfying BACM/MSM requirements; 

however, the District has still conducted a full control measure evaluation for Rule 4311. 

Valley Flaring Activity Compared to Other Regions 

Flares in the Valley and other air districts are primarily engineered for emergency 

operation during process upsets and emergency situations. Given this use, any 

unreasonable restrictions on flaring could potentially result in catastrophic 

consequences which may lead to explosions resulting in loss of property, injury and 

potentially loss of human life. While flares can be used during maintenance, new 

equipment installations, and startup/shut-down, the main concern is safety. In this 

regard, Valley flares are similar to those in other districts, the difference being that 

facilities in SCAQMD, BAAQMD, and SBCAPCD are much larger. The facilities in those 

districts are mostly operated at massive oil and gas refineries, with significantly higher 

throughputs than those in the Valley. Temperatures and pressures are higher, cracking 

occurs regularly, and the flares must be engineered to control emergencies and process 

upsets on a larger scale. Flare gas is typically sent to a flare header, where it is 

distributed to multiple large flares. The flares at these facilities are much larger in 

physical size, as well as capacity, as shown in the table below. 

Table C-2 Comparison of Flaring Capacity for Flares in California Air Districts 

Air District Total Flares Median 

(MMBtu/hr) 

Mean 

(MMBtu/hr) 

Largest 

(MMBtu/hr) 

SJVAPCD 235 33 663 40,000 

SCAQMD 29 10,234 14,328 72,751 

BAAQMD 23 108 14,442 246,612 

VCAPCD 55 34 284 7,100 

SBCAPCD 75 17 1,242 18,200 
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Flaring capacities of the flares in the SCAQMD, BAAQMD, and SBCAPCD are all 

significantly higher than the flaring capacities of flares in the Valley, while those in 

VCAPCD are similar size to Valley flares. Flares in BAAQMD have a wide range of 

capacities, while those in SCAQMD are all greater than 1,000 MMBtu/hr. The figure 

below shows the average capacity of flares in the District, SCAQMD, BAAQMD, 

VCAPCD, and SBCAPCD. 

Figure C-4 Average Flare Capacities in California Air Districts 

With roughly ten times the number of flares, the Valley has total NOx emissions from 

flares that are less than BAAQMD and less than half of SCAQMD, as illustrated in the 

emission inventory tables below. The flaring data in the tables below is compiled from 

all flaring activities in each air district’s jurisdiction and is provided in the ARBmaintained 2012 CEPAM: NORCAL 2012 PM2.5 SIP Baseline Emission Projection 

Tool. 

0

2000

4000

6000

8000

10000

12000

14000

16000

District

SBCAPCD

VCAPCD

SCAQMD

BAAQMD

Mean Capacity (MMBtu/hr)
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Table C-3 NOx Emissions Inventories for Flares in California Air Districts (tpd) 

 Air District 2012 2013 2014 2015 2016 2017 2018 2019 

SJVAPCD 0.57 0.57 0.57 0.56 0.56 0.55 0.55 0.55 

SCAQMD 1.19 1.20 1.20 1.21 1.22 1.22 1.23 1.23 

BAAQMD 0.64 0.64 0.64 0.64 0.64 0.64 0.64 0.65 

VCAPCD 0.12 0.12 0.12 0.12 0.12 0.13 0.13 0.13 

SBCAPCD 0.09 0.09 0.09 0.08 0.08 0.08 0.08 0.08 

Table C-4 VOC Emissions Inventories for Flares in California Air Districts (tpd) 

Air District 2012 2013 2014 2015 2016 2017 2018 2019 

SJVAPCD 0.27 0.27 0.27 0.26 0.26 0.26 0.26 0.25 

SCAQMD 0.40 0.41 0.41 0.41 0.41 0.41 0.41 0.41 

BAAQMD 1.32 1.33 1.33 1.33 1.33 1.33 1.33 1.33 

VCAPCD 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05 

SBCAPCD 0.06 0.06 0.05 0.05 0.05 0.05 0.05 0.05 

Table C-5 SOx Emissions Inventories for Flares in California Air Districts (tpd) 

Air District 2012 2013 2014 2015 2016 2017 2018 2019 

SJVAPCD 0.34 0.34 0.34 0.34 0.33 0.33 0.33 0.33 

SCAQMD 3.27 3.27 3.27 3.27 3.28 3.28 3.28 3.28 

BAAQMD 0.58 0.58 0.58 0.58 0.58 0.58 0.58 0.58 

VCAPCD 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 

SBCAPCD 0.18 0.17 0.17 0.17 0.16 0.16 0.16 0.15 

In summary: 

 Emissions in SCAQMD, BAAQMD, and SBCAPCD are much higher per flare 

than in the Valley; 

 Valley facilities flare a far lower volume; 

 Each facility contributes only a small fraction of emissions; 

 Emissions are effectively controlled at these facilities; and 

 Flaring is necessary for safety. 

To supplement the discussion found later in this chapter comparing North Dakota 

Century Code 38-08-06.4 to District Rule 4311, the District examined flaring in North 

Dakota. Research indicates that North Dakota has become the second largest 

producer of oil in the United States, behind Texas. The recent boom in oil production 

has led to far greater production, without the infrastructure and regulation to support 

emissions control. Oil production facilities in North Dakota have focused on expanding 

oil production by opening new wells, and as a consequence have not invested in the 

installation of onsite cogeneration equipment or sales transmission pipelines. The result 
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has been the flaring off of approximately 29% of all natural gas produced in North 

Dakota34, compared to approximately 3.8% in the Valley (as shown in the table below). 

Rule 4311 Regulatory Background 

Rule 4311 was adopted in June 2002 to establish flaring requirements and reduce 

emissions from flares. Amendments were adopted on June 15, 2006 and June 18, 

2009. The September 2009 amendment incorporated requirements for flare 

minimization plans and increased the stringency of existing requirements for sulfur 

emissions. EPA finalized approval of the 2009 amendments to Rule 4311 on November 

3, 2011 and deemed this rule as being at least as stringent as established RACT 

requirements.35 On January 10, 2012 EPA finalized a partial approval/partial 

disapproval of the 2009 RACT SIP and deemed this rule as still being at least as 

stringent as established RACT requirements.36

Rule 4311 Components 

Rule 4311 applies to all operations involving the use of flares. Exemptions include 

flares operated in municipal solid waste landfills subject to the requirements of Rule 

4642, flares subject to the requirements of 40 CFR 60 Subpart WWW (Standards of 

Performance for Municipal Waste Landfills) or Subpart Cc (Emission Guidelines and 

Compliance Times for Municipal Solid Waste Landfills), and except for recordkeeping 

requirements, any stationary source that does not have the potential to emit at least ten 

tons per year of VOC and NOx (non-major sources). 

Of the 235 flares operating in the Valley, 126 are exempt from Rule 4311 requirements 

other than basic recordkeeping due to one of the following reasons: 

 The flare is not part of a major source - 60 flares 

 The flare is subject to other rules regulating landfills – 27 flares 

 The flare is not stationary (i.e. transportable units) – 39 flares 

Of the flares exempt from Rule 4311 requirements (other than record keeping), over 

90% flaring activity is associated with landfills that utilize flares as part of their federally 

mandated gas collection systems. These flares are already required to meet strict local 

and federal requirements through 40 CFR 60 Subpart WWW (Standards of 

Performance for Municipal Solid Waste Landfills), or Subpart Cc (Emission Guidelines 

and Compliance Times for Municipal Solid Waste Landfills) and District Rule 4642 

(Solid Waste Disposal Sites). Rule 4642 applies to any solid waste disposal sites which 

have a gas collection system and/or control device in operation or undergoing 

maintenance or repair. Major requirements include: 

 

34 Scientific American. (2013, September 12). North Dakota flared off $1 billion worth of natural gas last year. 

Retrieved February 14, 2015 from http://blogs.scientificamerican.com/plugged-in/2013/09/12/north-dakota-flared-off1-billion-worth-of-natural-gas-last-year/. 35 EPA. (2011, November 3). 76 FR 68106. Retrieved April 4, 2014 from http://www.gpo.gov/fdsys/pkg/FR-2011-11-

03/pdf/2011-28391.pdf

36 EPA. (2012, January 10). 77 FR 1417. Retrieved April 4, 2014 from http://www.gpo.gov/fdsys/pkg/FR-2012-01-

10/pdf/2012-139.pdf
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 For gas collection system: operate so that TOC concentrations do not exceed 

1000 ppmv at any point on the surface of the solid waste disposal site or along 

the gas transfer path of the gas collection system; install sampling ports on each 

well head; operate in a manner which maximizes the amount of landfill gas 

extracted while preventing overdraw that can cause fires or damage the gas 

collection system; control by a control device that meet the control device 

requirements. 

 For a control device: achieve a VOC destruction efficiency of at least 98% by 

weight, or reduce the VOC concentration to 20 ppmv or less; for those that have 

an Authority to Construct (ATC) permit issued prior to July 20, 1995, achieve a 

destruction efficiency of at least 90% by weight or reduce the VOC concentration 

to 20 ppmv; operate enclosed flares in accordance with 40 CFR 60.756(b) and 

40 CFR 60.18 and open flares in accordance with 40 CFR 60.756(c) and 40 CFR 

60.18. 

 During maintenance, notify the APCO 24 hours in advance, minimize the 

emissions during shutdown, and prevent shut down for more than 144 cumulative 

hours in any calendar year. 

 Other requirements not applicable to flares. 

In addition to Rule 4311 requirements, any new flares are subject to New Source 

Review (NSR) requirements (District Rule 2201) including Best Available Control 

Technology (BACT) requirements, meaning they may be required to implement even 

more stringent controls regardless of whether they are subject to Rule 4311. All 

sources must obtain an ATC permit before they are operated. 

Rule 4311 includes the following major requirements (described in more detail in the 

following sections): 

 Operation requirements that ensure the flare is achieving maximum destruction 

efficiency 

 Operation of measurement and monitoring devices to ensure all requirements 

are being met 

 VOC and NOx emission limits for ground-level enclosed flares 

 Flare minimization plans 

 Petroleum refinery SO2 performance targets 

 Extensive recordkeeping requirements including annual monitoring reports and 

reportable flaring event reports 

Operation Requirements 

General requirements for flare operation include: 

 Maintain a flame at all times when combustible gases are vented through the 

flare 

 Equip the outlet with an automatic ignition system, or operate with a pilot flame 

present at all times when combustible gases are vented through the flare, except 

during purge periods for automatic-ignition equipment flares 

 Except for flares equipped with a flow-sensing ignition system, install and operate 

a heat sensing device such as a thermocouple, ultraviolet beam sensor, infrared 
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sensor, or an alternative equivalent device, capable of continuously detecting at 

least one pilot flame or the flare 

 Use purge gas for purging flares that use flow-sensing automatic ignition systems 

and that do not use a continuous flame pilot 

 For open flares (air-assisted, steam-assisted, or non-assisted) in which the flare 

gas pressure is less than 5 psig, operate the flare pursuant to 40 CFR 60.18 

Emission Limits 

Emission reductions are obtained directly by requiring ground-level enclosed flares to 

meet the following emission standards for VOC and NOx: 

Table C-6 Rule 4311 Emission Limits for Ground-level Enclosed Flares 

Type of Flare and Heat 

Release Rate in MMBtu/hr VOC (lb/MMBtu) NOx (lb/MMBtu) 

Without Steam-assist 

<10 MMBtu 0.0051 0.0952 

10-100 MMBtu 0.0027 0.1330 

>100 MMBtu 0.0013 0.5240 

With Steam-assist 

All 0.14 as TOG 0.068 

Flare Minimization Plans 

Rule 4311 requires a Flare Minimization Plan (FMP) to be submitted to and approved by 

the District for any petroleum refinery with a flare or any flare with a flaring capacity 

greater than or equal to 5.0 MMBtu/hr. The rule prohibits facilities subject to FMP 

requirements from flaring unless it is consistent with a District-approved FMP and all 

commitments in that FMP have been met. FMPs must include all necessary information 

to satisfy the underlying regulatory requirements, and must be submitted to the District 

for approval. In addition to their initial submittal, FMPs must be modified prior to making 

any modifications to related equipment or processes, and at least every five years. 

FMPs are required to include the following: 

 Description and technical specifications for each flare and associated knock-out 

pots, surge drums, water seals, and flare gas recovery systems 

 Process flow diagrams of upstream equipment and process units venting to each 

flare (with identification of type and location of control equipment) 

 Description of equipment, processes, or procedures the operator plans to install 

or implement to eliminate or minimize flaring, and planned date of installation or 

implementation 

 Evaluation of prevention measures to reduce flaring that has occurred or may be 

expected to occur during planned major maintenance activities, including startup 

and shutdown 
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C-66 Appendix C: BACM and MSM for Stationary and Area Sources 

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 Evaluation of preventative measures to reduce flaring that may be expected to 

occur due to issues of gas quantity and quality. This includes an audit of vent 

gas recovery capacity of each flare system, storage capacity for excess vent gas, 

and scrubbing capacity available for vent gas for use as a fuel; and shall 

determine the feasibility of reducing flaring through the recovery, treatment, and 

use of the gas 

 Evaluation of preventative measures to reduce flaring caused by the recurrent 

failure of air pollution control equipment, process equipment, or a process to 

operate in a normal or usual manner. Evaluation shall determine adequacy of 

existing maintenance schedules and protocols for such equipment. A failure is 

recurrent if it occurs more than twice during any five year period as a result of the 

same cause. 

Of the 109 facilities subject to Rule 4311 requirements, 14 do not have a flaring capacity 

of at least 5.0 MMBtu/hr and are not operated at a petroleum refinery and are therefore 

not subject to FMP requirements. The remaining 95 are subject to FMP requirements. 

FMP submittals by facility type are summarized in the below table. 

Table C-7 Submitted FMPs Summarized by Industry 

Industry Summary Qty 

Cheese production 1 

Wine 2 

Correctional Facility 1 

Oil and natural gas production, processing, and transmission 76 

Petroleum refinery 7 

Dairy 1 

Flat glass 1 

Wastewater 6 

Total 95 

Actions identified in the FMPs are typically dependent on the facility and operation type, 

as well as the quality of gas being flared. Similarly, the feasibility of potential control 

options is highly dependent on the same factors. The following table is a sample of 

measures committed to in FMPs submitted to the District: 
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C-67 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Table C-8 Sample FMP Measures by Facility Type 

Facility 

Category Actions Identified in FMP to Minimize Flaring* 

Oil and Gas 

Production 

and 

Transmission 

Include permit limit on gas flared daily and annually 

Streamline startup, shutdown, and maintenance procedures to 

minimize equipment downtime, thereby minimizing flaring 

Hydrogen sulfide scrubbing of flare gases to condition for sale

Inject flare gas in DOGGR-approved wells 

Use other combustion devices (and offset the need for other natural 

gas fuel sources) such as glycol re-boiler/thermal oxidizer 

Wastewater 

Treatment/ 

Reclamation 

Install new equipment to combust digester gas in internal combustion 

engines, fuel cells, and process heaters 

Install equipment to allow digester gas storage and conditioning for 

greater use in turbines (additional storage is minimal and only capable 

of handling excess gas during minor process upsets) 

Wine 

Production 

Burn flare gas in steam generation boilers; coordinate plant 

operations that generate the flare gas with production operations 

requiring steam 

Cheese 

Production Modify boiler to combust a natural gas/digester gas blend 

Flat Glass 

Manufacturing 

Reduce idle time during calibration and purge test to reduce 

necessary flaring 

Dairy Farming Install additional gensets (electricity generation equipment located 

near the end user) to combust more produced biogas 

Many of the above measures are not feasible for all facilities. For oil and gas 

production, the flare gas produced is often in excess of what could be used onsite to 

power equipment. For these facilities, flares are generally used only under abnormal 

conditions, as the flare gas is usually high enough quality to sell for use at other 

facilities. 

For facilities other than oil and gas production, the gas produced is usually a much 

lower heating value and requires conditioning if combusted for electrical generation or 

process heating. Expensive modifications or new equipment is often required to allow 

said combustion activities and the flare gas is sometimes of too low quality or quantity to 

make these installations cost effective. Additionally, emissions from other combustion 

devices would likely be higher because flares are inherently low emitting and serve as 

combustion control devices. 

Of the 95 flares required to submit FMPs, 92 are standby flares or emergency flares that 

are only utilized when needed such as during maintenance or to dispose of excess flare 

gas or during emergencies. Only the remaining 3 flares in the Valley are permitted to 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

be used as primary disposal devices. Two of the three flares are used at an oil and 

natural gas production facility as strictly an emissions control device for vapors 

displaced from trucks only during load-out operations pursuant to requirements in 

District Rule 2201 (New and Modified Stationary Source Review Rule). The third flare is 

used at a cheese making facility as an emissions control device for gases generated at 

the wastewater anaerobic digester at the facility. As a component of their submitted 

FMP, this cheese making facility has committed to modify an on-site boiler to combust a 

natural gas/digester gas as a means of reducing current flaring activity. 

Petroleum Refinery SO2 Performance Targets 

Operators of petroleum refineries are required to minimize SO2 emissions to less than 

1.5 tons per million barrels of crude processing capacity. Starting January 1, 2017, 

operators of petroleum refineries will be required to lower this target to 0.5 tons SO2 per 

million barrels of crude processing capacity. 

Annual Monitoring Reports 

Rule 4311 also requires the operator of any petroleum refinery flare or any flare with a 

flaring capacity equal to or greater than 50 MMBtu/hr to submit an Annual Monitoring 

Report (AMR) to the District no later than July 31st of each calendar year, containing the 

following information: 

 Total volumetric flow of vent gas 

 Hydrogen sulfide content, methane content, and hydrocarbon content of vent gas 

 If vent gas composition is monitored by a continuous analyzer: average total 

hydrocarbon content by volume, average methane content by volume, and 

depending upon the analytical method used, total reduced sulfur content by 

volume or hydrogen sulfide content by volume of vent gas flared for each hour of 

the month 

 If the flow monitor measures molecular weight, the average molecular weight for 

each hour of each month 

 For any pilot and purge gas used, the type of gas used, the volumetric flow for 

each day and for each month, and the means used to determine flow 

 Flare monitoring system downtime periods, including dates and times 

 For each day and each month provide calculated sulfur dioxide emissions 

 A flow verification report for each flare 

Of the facilities subject to FMP requirements, 40 are not required to submit annual 

monitoring reports. Some of these facilities are too small or do not utilize their flares, 

but the majority have accepted specific limiting conditions on their permits to operate 

that limit the amount of flaring the facility can conduct to less than the threshold for 

reportable flaring events. The remaining 55 facilities are therefore subject to AMR 

requirements. Of these 55 flares, only one is used as a primary disposal device, one is 

dormant, and eleven are designated for emergency use only. The remaining flares are 

standby flares. 

Information from the AMRs has allowed the District to evaluate the total amount of vent 

gases combusted and their compositions and increased understanding of flaring 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-69 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

activities in the Valley. This information in turn allows the District to calculate the 

amounts of emissions from reported flaring and compare those values to verify the 

accuracy of the emissions inventory for flares. 

Reportable Flaring Events 

Rule 4311 requires annual reports to be submitted each year summarizing all reportable 

flaring events. A flaring event is considered a reportable flaring event if more than 

500,000 standard cubic feet (scf) of vent gas is flared per calendar day, or where sulfur 

oxide emissions are greater than 500 pounds per calendar day. Assuming an estimated 

heating value for flare gas of 1,000 Btu/scf, a flare must have a capacity greater than or 

equal to 20.8 MMBtu/hr to achieve a reportable flaring event, although most flares 

commonly operate at a small fraction of maximum capacity. Additionally, some low 

quality waste gases can have heating values of 200-300 Btu/scf, which would lower the 

minimum capacity for reportable flaring events. Reportable flaring event requirements 

are applicable to the operator of a flare subject to FMP requirements with the exception 

of flares that the operator can verify are not capable of producing reportable flaring 

events. 

The reports are required to include at least the following: 

 The results of an investigation to determine the primary cause and contributing 

factors of the flaring event 

 Any prevention measures considered or implemented to prevent recurrence 

together with a justification for rejecting any measures that were considered but 

not implemented 

 If appropriate, an explanation of why the flaring was an emergency and 

necessary to prevent accident, hazard or release of vent gas to the atmosphere, 

or where, due to a regulatory mandate to vent a flare, it cannot be recovered, 

treated, and used as a fuel at the facility 

 The date, time, and duration of the flaring event 

The majority of reportable flaring events are planned—thereby allowing for greater 

preparation and control—for repair, maintenance, or new equipment installations, 

including new air pollution control devices. Most of the events are one-time events. Of 

the gas flared, less than 20% is salable quality, lending support to the fact that facilities 

sell flare gas when feasible. 

Of the 109 flares subject to Rule 4311, 21 flares generated 395 reportable flaring events 

during the 2011-2012 period. This period is a conservative reflection of potential 

reporting flaring event activity in the Valley given the unusually high number of events 

reported by a single facility (described in more detail below). The table below 

summarizes these events by facility type. 
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C-70 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Table C-9 Summary of Total Reportable Flaring Events from 2011-2012 Period 

Industry Summary Qty of 

Flares 

Reportable Flare Events – 

Total 

(MMscf) 

Crude Oil and natural gas production 3 27.8 

Gas plant 2 12.0 

Light oil production 3 7.7 

Natural gas processing and production 5 42.8 

Oil and natural gas production 4 52.5 

Petroleum and NG production 1 20.9 

Petroleum refining 2 59.4 

Wastewater reclamation facility 1 124.2 

Total 21 347.4 

The following graph illustrates the fact that the majority of flaring events are for 

equipment installations, maintenance, and repair. 

Figure C-5 Summary of Reasons for Reportable Flaring Events (2011-2012) 

During this period, the largest percent of all gas flared during reportable flaring events 

was by a single wastewater treatment plant. According to the District-approved FMP for 

this facility, digester gas is utilized to create electricity and provide heat for the digesters 

(and offset the combustion of pipeline natural gas). The WWTP uses two 3.4 MW 

turbine engines and one 16.7 MMBtu/hr process boiler that are almost completely 

fueled by digester gas. Because there is no significant gas storage capacity, any 

excess digester gas or gas produced during interruptions to the turbines or boiler must 

be flared to avoid direct emissions to the atmosphere or potential gas build-up leading 

to explosions at the plant. To fulfill commitments in the FMP, the facility installed a 

small digester gas storage tank, installed additional digester gas conditioning, and 

increased the allowable digester gas fuel for the turbines from 50% to 100%. The 

Maintenance/ Repair

19%

Equipment Installations

51%

Startup/ Shutdown

13%

Equipment Failure

8%

Power Outage

5%

Reason Unkown

4%
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C-71 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

storage tank is capable of holding gas for small periods, such as during switchover 

between turbines, and the gas conditioning allows the use of selective catalytic 

reduction (SCR) on the turbines. The addition of this equipment has resulted in a 71% 

reduction in the volume of gas flared by the WWTP; however, during the 2011-2012 

reporting period the facility experienced abnormally high flaring activity. During this 

period, the turbines were out of service to allow installation of SCR control devices for 

reducing over 90% of NOx emissions from the turbines pursuant to District Rule 4703 

(Stationary Gas Turbines) and permitted emission limits. As a result, a large portion of 

the digester gas was flared. Out of the 395 total reportable flaring events in the Valley 

during the 2011-2012 reporting period, 164 occurred at the WWTP. Those events 

accounted for 36% of the total volume of gas flared during reportable events, more than 

three times the next highest volume at any facility. By contrast, the 2012-2013 reporting 

period showed only 46 reportable flaring events at this facility, all of which were for 

regular activities except one due to failure of a turbine. Because the majority of flaring 

events during the 2011-2012 reporting period were due to installations and are therefore 

one-time events, they are not part of normal facility operations. 

The following graph illustrates the percentages of gas flared from all sources during 

reportable flaring events for the 2011-2012 period. 

Figure C-6 Percent of Reportable Flaring from All Sources (2011-2012) 

Comparison of Rule 4311 to State, Federal, and Local Regulations 

Comparison of Rule 4311 to Federal Regulations 

There are no EPA CTG or ACT requirements for this source category. 

The following federal regulations apply to Rule 4311 sources: 

0

5

10

15

20

25

30

35

40

ABCDE FGH I J K LM

Percent of Total Volume Flared from Reportable

Flaring Events

Facility (Facility 'A' is Fresno/Clovis Regional WWTP)
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C-72 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

 NESHAP/MACT: 

o 40 CFR 63 Subpart SS (National Emission Standards for Closed Vent 

Systems, Control Devices, Recovery Devices and Routing to a Fuel Gas 

System or a Process) 

 NSPS: 

o 40 CFR 60.18 (General Control Device and Work Practice Requirements) 

o 40 CFR 65.147 (Flares) 

o 40 CFR 60 Subpart OOOO (Standards of Performance for Crude Oil and 

Natural Gas Production, Transmission and Distribution) 

o 40 CFR 60 Subpart Ja (Standards of Performance for Petroleum 

Refineries for Which Construction, Reconstruction, or Modification 

Commenced After May 14, 2007) 

Rule 4311 is as stringent as or more stringent than the above NSPS and NESHAP 

requirements. The most recently amended NSPS (40 CFR 60 Subpart OOOO and 40 

CFR 60 Subpart Ja) are discussed below. 

40 CFR 60 Subpart OOOO is a new NSPS requirement that was finalized by EPA on 

August 16, 2012. This NSPS may indirectly affect some Valley flares since there is a 

possibility that a flare is exempt from the majority of Rule 4311 and is used as a control 

device for a vapor controlled tank that is subject to Subpart OOOO. 

Affected facilities under this subpart that may use flares as an approved control device 

include centrifugal compressors, storage vessels, and onshore natural gas processing 

plants. If the facility chooses to meet the control requirements, then the flare must be 

designed and operated in accordance with §60.18(b) and must conduct the compliance 

determination using Method 22 at 40 CFR part 60, appendix A-7, to determine visible 

emissions. §60.18(b) was last amended on December 22, 2008, which is before the 

last amendment for District Rule 4311 (June 18, 2009). The requirements of the 2008 

amendments were closely evaluated during the District’s 2009 Rule amendment. EPA 

deemed Rule 4311 as being at least as stringent as established RACT requirements on 

January 10, 2012.37 Since Subpart OOOO has no new requirements for flares after the 

2012 EPA RACT approval, Rule 4311 continues to be at least as stringent as these 

requirements. 

40 CFR 60 Subpart Ja was amended by EPA on September 12, 2012. Amendments 

clarified existing requirements and applicability, including what constitutes a flare 

modification, clarification of secondary flares, and clarification of the records that must 

be maintained by the operator. EPA also added new requirements to Subpart Ja as 

part of these amendments, including flare related unit and process descriptions, 

assessments, and evaluations; analyses of causes and corrective actions for reportable 

flaring events; and sulfur limits for petroleum refineries. 

 

37 EPA. (2012, January 10). 77 FR 1417. Retrieved 2/11/15 from http://www.gpo.gov/fdsys/pkg/FR-2012-01-

10/pdf/2012-139.pdf.
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C-73 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Subpart Ja did not implement more stringent requirements than District Rule 4311. 

Subpart Ja has one new exemption for continuous monitoring, which allows for fewer 

requirements than previously required in the NSPS, and therefore, is not more stringent 

than current rule language. While there may be some minor differences in terminology 

or requirements making direct comparisons not possible, the same level of controls and 

emission reductions are achieved through District regulations as through this NSPS. 

Additionally, the District’s Permit Services Department continuously evaluates NSPS on 

a case-by-case basis to ensure the relevant flares comply with all federal requirements 

as they are promulgated. Rule 4311 is as stringent as, if not more stringent than, this 

NSPS. 

As demonstrated by the discussion above, Rule 4311 is as stringent as or more 

stringent than the applicable federal regulations. 

Comparison to State Regulations 

There are no state rules or regulations that apply to this source category.

Comparison to Regulations in other Air Districts 

As previously stated, EPA analysis of Rule 4311 resulted in the 2012 determination that 

Rule 4311 is as stringent as requirements in other air districts in California (76 FR 

68106); however, in keeping with the methodology of this plan, the District conducted a 

thorough examination of rules in other air districts, including the following: 

 SCAQMD Rule 1118 (Control of Emissions from Refinery Flares) 

 BAAQMD: 

o Regulation 12 Rule 11 (Flare Monitoring at Petroleum Refineries) 

o Regulation 12 Rule 12 (Flares at Petroleum Refineries) 

 SMAQMD and VCAPCD do not have an analogous rule for this source category. 

The District also conducted an exhaustive search for rules in all other air districts, 

including those outside of California, to identify any that might contain more stringent 

requirements. While Rule 4311 is as stringent as or more stringent than any rules in the 

nation, the District prepared comparisons to Santa Barbara County Air Pollution Control 

District (SBCAPCD) Rule 359 and North Dakota Century Code 38-08-06.4. The North 

Dakota rule is not included in the comparison table below because it does not contain 

most of the core requirements of California air district flare regulations. The following 

table compares major elements of Rule 4311 with those in other California air districts. 

Table C-10 Summary of Rule Requirement Comparisons 

District Rule 

4311 (Flares) 

SCAQMD Rule 

1118 

(Control of 

Emissions from 

Refinery Flares) 

BAAQMD 

Reg. 12 

Rule 11 

(Flare 

Monitoring at 

Petroleum 

Refineries) 

BAAQMD Reg. 

12 

Rule 12 

(Flares at 

Petroleum 

Refineries) 

VCAPCD Rule 

54 (Sulfur 

Compounds) 

SBCAPCD Rule 359 

(Flares and 

Thermal Oxidizers) 

DATES OF ADOPTION/ AMENDMENT

Adopted Jun 20, 

2002; Amended 

Jun 15, 2006; Jun 

18, 2009 

Adopted Feb 13, 

1998; Amended 

Nov 4, 2005 

Adopted Jun 4, 

2003 

Adopted Jul 20, 

2005 

Adopted Jul, 

1968; Revised 

Oct 1968; Jun 

1969; May 

Adopted Jun 28, 

1994 
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C-74 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

District Rule 

4311 (Flares) 

SCAQMD Rule 

1118 

(Control of 

Emissions from 

Refinery Flares) 

BAAQMD 

Reg. 12 

Rule 11 

(Flare 

Monitoring at 

Petroleum 

Refineries) 

BAAQMD Reg. 

12 

Rule 12 

(Flares at 

Petroleum 

Refineries) 

VCAPCD Rule 

54 (Sulfur 

Compounds) 

SBCAPCD Rule 359 

(Flares and 

Thermal Oxidizers) 

1972; Jul 1983; 

Jun 1994 

APPLICABILITY

All flares 

Flares used at: 

 Petroleum 

(petro.) 

refineries 

 Sulfur recovery 

plants 

 Hydrogen 

production 

plants 

Flares used at 

petro. 

refineries 

Flares used at 

petro. refineries 

Any person 

who 

discharges 

sulfur 

compounds 

from any 

source 

Flares and thermal 

oxidizers used at: 

 Oil and gas 

production 

 Petro. refinery 

 Natural gas 

services and 

transportation 

 Wholesale trade in 

petro./petro. 

products 

EXEMPTIONS

 Municipal solid 

waste landfill 

flares subject to 

Rule 4642 

 Flares subject to 

40 CFR 60 

WWW or Cc 

 Stationary 

sources w/ 

potential to emit 

<10 tons VOC 

and <10 tons 

NOx per year 

(Not exempt from 

recordkeeping) 

Exempt from 

sampling and 

analyses for 

higher heating 

values and sulfur 

concentration for 

flare event that: 

 Results from 

catastrophic 

event 

 Is safety hazard 

to sampling 

personnel; 

Sulfur dioxide 

(SO2) emissions 

(emissions) from 

flaring events 

caused by: 

 External power 

curtailment 

beyond 

operator’s 

control 

 Natural 

disasters 

 Acts of war or 

terrorism 

(Not exempt from 

flare monitoring 

system 

requirements) 

Flares and 

thermal 

oxidizers used 

for: 

 Emissions 

from organic 

liquid storage 

vessels (subj. 

to R. 8-5) 

 Emissions 

from loading 

racks (subj. 

to R. 8-6, 8-

33, or 8-39) 

 Emissions 

from marine 

vessel 

loading 

terminals 

(subj. to R. 8-

44) 

Thermal 

oxidizers used 

for: 

 Emissions 

from 

wastewater 

treatment 

systems 

(subj. to R. 8-

8) 

 Emissions 

from pump 

seals (subj. to 

R. 8-18) 

(except when 

emissions 

from pump 

Same as Rule 

11 

(except last 

exemption on 

list) 

Sulfur emission 

limit and avg. 

concentration 

limit don’t 

apply to: 

Unplanned 

flaring for 

emergency or 

safety if: 

 Not result of 

intentional or 

negligent act, 

omission, 

improper 

maintenance 

or setting of 

shut-in 

sensors 

 Results from 

operational 

problems 

(emergency 

blowdowns, 

process 

upsets, power 

outages, 

equipment 

breakdown) 

 Records of 

event kept 

 corrective 

measures 

immediately 

taken 

 Event lasts 

<24 hr. 

 Notify <4 hr. 

after 

Burning of sulfur, 

hydrogen sulfide, 

acid sludge, or other 

sulfur compounds in 

manufacturing of 

sulfur or sulfur 

compounds 

For oil and gas 

sources that recover 

sulfur as by-product 

of gas 

treating/sweetening, 

manufacturing 

exemption applies 

only to those specific 

processes 

(Except technologybased std.) Burning 

gas w/ net heating 

value <300 Btu/scf if 

fuel used to 

incinerate gas has 

sulfur compounds: 

 <15 grain/100 ft3 in 

Southern Zone 

 <50 grain/100 ft3 in 

Northern Zone 

Flare and thermal 

oxidizer units rated 

<1.7 MMBtu/hr., 

unless total 

cumulative rating of 

all such units at a 

source is >5 

MMBtu/hr. (Not 

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

C-75 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

District Rule 

4311 (Flares) 

SCAQMD Rule 

1118 

(Control of 

Emissions from 

Refinery Flares) 

BAAQMD 

Reg. 12 

Rule 11 

(Flare 

Monitoring at 

Petroleum 

Refineries) 

BAAQMD Reg. 

12 

Rule 12 

(Flares at 

Petroleum 

Refineries) 

VCAPCD Rule 

54 (Sulfur 

Compounds) 

SBCAPCD Rule 359 

(Flares and 

Thermal Oxidizers) 

are routed to 

flare header) 

Monitoring and 

reporting total 

hydrocarbon 

(HC) or 

methane 

composition 

doesn’t apply 

to flare that 

burns 

flexicoker gas 

if weekly 

sampling 

shows 

methane/nonmethane 

content of vent 

gas flared is 

<2%/<1% by 

volume 

detection and 

submit report 

if event >1 hr. 

Planned flaring 

if: 

 Notice 

submitted 

>72 hr. in 

advance, 

justifying work 

(reasons and 

steps to 

minimize 

sulfur 

emissions) 

 Notice can be 

submitted 

<72 hr. if 

hazardous 

situation, 

economic 

harm, or 

excess 

emissions 

 Submit 

planned 

flaring mgmt. 

plan 

 Records kept 

2 yrs. 

 District 

notified when 

work 

complete 

 Sulfur 

emissions are 

minimized 

 Excess 

emissions fee 

paid to 

District each 

year 

($5.00/lb. 

SO2 emitted) 

content std., 

technology std., 

monitoring, 

recordkeeping, and 

recording.) 

Flares and thermal 

oxidizers exempt 

from FMP: 

 Rated at <15 

MMBtu/hr, unless 

cumulative rating 

>50 MMBtu/hr. 

 Operations of only 

planned, 

continuous flaring 

due to nonavailability of a 

produced gas 

pipeline outlet 

FLARE MINIMIZATION PLAN (FMP) REQUIREMENTS

FMP requirements 

don’t apply if 

flaring caused by 

emergency and 

necessary to 

prevent accident, 

hazard or release 

of vent gas 

directly to the 

Owner/operator 

of petro. refinery 

exceeding 

performance 

targets submit 

FMP: 

 <90 days from 

end of year w/ 

emissions 

None 

FMP required 

for flares 

subject to rule 

and 3-month 

status reports 

required until 

FMP 

completed: 

 Technical 

Each operator 

submits a 

planned flaring 

management 

plan: 

 Measures to 

decrease FG 

volume and 

reduce sulfur 

Sources subject to 

rule and flares and 

thermal oxidizers 

rated at >15 

MMBtu/hr submit 

FMP: 

 Planned flaring: 

targeted max 

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

C-76 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

District Rule 

4311 (Flares) 

SCAQMD Rule 

1118 

(Control of 

Emissions from 

Refinery Flares) 

BAAQMD 

Reg. 12 

Rule 11 

(Flare 

Monitoring at 

Petroleum 

Refineries) 

BAAQMD Reg. 

12 

Rule 12 

(Flares at 

Petroleum 

Refineries) 

VCAPCD Rule 

54 (Sulfur 

Compounds) 

SBCAPCD Rule 359 

(Flares and 

Thermal Oxidizers) 

atmosphere 

FMP required for 

petro. refinery 

flare or any flare 

w/ capacity >5.0 

MMBtu/hr.: 

 Technical specs 

for each flare, 

knock-out pots, 

surge drum, 

water seal, and 

flare gas (FG) 

recovery system 

 Process flow 

diagrams of 

upstream 

equipment and 

process units 

venting to each 

flare 

 Equipment, 

processes, or 

procedures 

planned to install 

or implement to 

minimize flaring 

and planned 

date 

 Evaluations of 

preventative 

measures to 

reduce flaring 

expected due to 

planned major 

maintenance 

activities, gas 

quantity and 

quality issues, 

and recurrent 

failure of 

equipment or 

processes 

 Submit updated 

FMP every 5 

years and for 

new or modified 

equipment prior 

to installing 

exceeding 

target 

 Plan is pursuant 

to Rule 221 and 

fees pursuant to 

Rule 306 

 List all actions 

to be taken to 

meet targets: 

o Technical 

specs for 

flares, knockout pots, 

surge drums, 

water seals 

and FG 

recovery 

systems 

o Process flow 

diagrams of 

upstream 

equipment 

and process 

units venting 

to flares 

o Policies, 

procedures, 

and 

equipment 

improvements 

to minimize 

flaring and 

flare 

emissions 

o FG recovery 

equipment 

and treatment 

systems to be 

installed 

 FMPs available 

for 60-day 

public review 

prior to 

approval 

 45 days allowed 

to correct 

deficiencies 

 Facility in 

violation if FMP 

denied 

 Revised FMP 

submitted 90 

days after end 

of year if 

performance 

information for 

each flare 

 Upstream 

equipment 

and 

processes 

(Same as 

SJVAPCD 

and 

SCAQMD) 

 Equipment, 

processes, 

and 

procedures 

implemented 

in last 5 years 

to reduce 

flaring and 

those planned 

to be installed 

or 

implemented 

 Prevention 

measures, 

including 

schedule for 

implementatio

n for flaring: 

o That has or 

will occur 

during 

planned 

major 

maintenanc

e 

o Expected to 

occur due to 

issues of 

gas quantity 

and quality 

(include 

audits of 

capacities), 

or caused 

by recurrent 

failure of 

equipment 

or 

processes 

emissions 

 Description of 

planned 

operational or 

maintenance 

procedures 

that may 

cause flaring 

 Description of 

each flare 

system 

including 

design 

features 

 Description of 

any sulfur 

reduction 

system 

 Measures to 

be 

implemented 

to reduce the 

number of 

planned 

flaring events 

o <5% avg. monthly 

gas handled/ 

produced/ treated 

at source based 

on 3 years 

o Higher limit may 

be granted by 

APCO if 

demonstrated to 

be infeasible 

 Submit emissions 

mitigation plan if: 

o Volume limit 

>10% of avg. 

monthly gas 

o Sulfur content of 

flared gas >239 

ppmv/ >796 

ppmv in Southern/ 

Northern Zone 

 The emissions 

mitigation plan 

must achieve 50% 

reduction of greater 

of actual or 

proposed avg. 

monthly FG volume 

limit 

 Owner/operator 

reimburses for 

review and 

approval of plans 

FMP includes: 

 Measures to 

decrease volume of 

FG and planned 

flaring events 

 Measures to 

prevent emergency 

flaring and 

unplanned flaring 

 Flare system 

 FG monitoring 

system 

 Design and 

operation features 

of pilot and purge 

gas system 

 Design features of 

flare to handle 

nominal and peak 

gas flows and 

range of 

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

C-77 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

District Rule 

4311 (Flares) 

SCAQMD Rule 

1118 

(Control of 

Emissions from 

Refinery Flares) 

BAAQMD 

Reg. 12 

Rule 11 

(Flare 

Monitoring at 

Petroleum 

Refineries) 

BAAQMD Reg. 

12 

Rule 12 

(Flares at 

Petroleum 

Refineries) 

VCAPCD Rule 

54 (Sulfur 

Compounds) 

SBCAPCD Rule 359 

(Flares and 

Thermal Oxidizers) 

targets 

exceeded 

 Plans to reduce 

planned flaring 

emissions 

 Schedules to 

reduce planned 

shutdowns 

 Proposed study of 

different settings to 

minimize emissions 

 Summary of 

scheduled/typical 

planned flaring 

 Review FMP every 

5 years 

ANNUAL MONITORING REPORTS

For refinery flare 

or flare w/ flaring 

capacity >50 

MMBtu/hr: 

Operator submit 

annual report <30 

days after end of 

each 12 month 

period including: 

 Total volumetric 

flow of vent gas 

(scf) for each day 

 Contents of vent 

gas composition: 

o Hydrogen 

sulfide 

o Methane 

o HC 

 If vent gas 

composition 

monitored by 

continuous 

analyzer or 

analyzers: the 

following for 

each hour of the 

month: 

o Avg. total HC 

content by 

volume 

o Avg. methane 

content by 

volume 

o Total reduced 

sulfur content 

by volume or 

hydrogen 

sulfide content 

by volume 

 Avg. molecular 

Submit quarterly 

report <30 days 

after end of each 

quarter including: 

 Information 

required to be 

monitored: 

o Table of nine 

operating 

parameters, 

based on flare 

type (clean 

service, 

emergency 

service, 

general 

service) 

o Alternative 

flare vent gas 

sampling 

information 

necessary to 

calculate flare 

emissions 

o Flare 

monitoring 

system data 

o Images of 

visible 

emissions 

o Presence of 

pilot flame 

o Pilot gas and 

purge gas 

flow to each 

flare 

 Total daily and 

quarterly 

emissions of 

criteria 

Monthly report: 

 Total 

volumetric 

flow each day 

and month 

 If gas 

composition 

monitored w/ 

sampling, 

content by 

volume for 

each sample 

of total HC, 

methane, and 

H2S 

 If composition 

monitored w/ 

continuous 

analyzer, 

avg. content 

by volume of: 

total HC; 

methane; 

total reduced 

sulfur; H2S 

 Avg. 

molecular 

weight for 

each hour of 

the month (if 

measured) 

 For pilot & 

purge gas 

o Type of gas 

o Volumetric 

flow for 

each day 

and month 

o Means used 

to 

None None 

Submitted annually, 

by March 1 of the 

following calendar 

year, including: 

 Monthly volumes of 

gas flared per 

planned continuous 

and planned 

intermittent flaring 

categories 

 Summary of total 

gas volume 

released during 

emergencies and 

weighted-average 

H2S content for the 

entire volume 

 Monthly reporting 

on any exceedance 

of the allowable 

monthly volume of 

gases planned for 

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

C-78 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

District Rule 

4311 (Flares) 

SCAQMD Rule 

1118 

(Control of 

Emissions from 

Refinery Flares) 

BAAQMD 

Reg. 12 

Rule 11 

(Flare 

Monitoring at 

Petroleum 

Refineries) 

BAAQMD Reg. 

12 

Rule 12 

(Flares at 

Petroleum 

Refineries) 

VCAPCD Rule 

54 (Sulfur 

Compounds) 

SBCAPCD Rule 359 

(Flares and 

Thermal Oxidizers) 

weight for each 

hour of each 

month (if 

measured) 

 For pilot and 

purge gas: 

o Type of gas 

used 

o Volumetric flow 

for each day 

and each 

month 

o Means used to 

determine flow 

 Flare monitoring 

system downtime 

 SO2 emissions 

for each day and 

each month 

 Flow verification 

report for each 

flare 

pollutants from 

each flare and 

each flare event 

along with 

information 

used to 

calculate 

emissions 

 Description of 

cause and 

category of 

each flare event 

 Records of 

annual 

acoustical or 

temperature 

leak survey 

 Flare 

monitoring 

system 

downtime 

periods 

 Copy of written 

notices for all 

reportable air 

releases related 

to any flare 

event 

determine 

flow 

 For any 24-hr 

period when 

1 million scf 

flared, 

description: 

o Cause 

o Time and 

duration 

o Source 

o Measures 

to reduce or 

eliminate 

flaring 

 Monitoring 

system 

downtime 

periods 

 Images 

recorded for 

the month 

 Methane, 

non-methane, 

and SO2 

emissions for 

each day and 

for the month 

Semi-annual 

flow 

verification 

report, 

comparing flow 

measured by 

monitoring 

system and 

flow 

verification for 

same period of 

time 

REPORTABLE FLARING EVENT REPORTS

 Definition: 

o Flaring event 

where 

>500,000 scf 

gas flared/day 

or 

o SO2 emissions 

>500 lb/day 

o Ends when 

water seal 

integrity 

demonstrated 

or 

Requirements: 

 Notify by 

telephone <1 

hr. of 

unplanned flare 

event w/ 

emissions >100 

lb. VOC, >500 

lb. SO2, or 

>500,000 scf 

gas 

 Submit Specific 

Cause Analysis 

For any 24-

hour period 

during which 

>1 million scf 

of vent gas 

was flared: 

 Cause 

 Time of 

occurrence 

and duration 

 Source or 

equipment of 

origin 

Notify if volume 

flared >500,000 

scf per day: 

 Results of 

cause 

investigation 

 Measures to 

prevent 

recurrence 

 Justification 

for rejecting 

measures 

 Explanation 

For unplanned 

flaring >1 hr. in 

duration: 

 Notify <4hr. 

after 

detection 

 Submit report: 

o Date, time, 

duration, 

volume of 

gas flared 

o Reasons for 

flaring 

Exceedance not a 

violation if 

emergency: 

 Inform <4 hr. after 

start of next 

business day 

 Document event 

occurrence and 

causes 

 Submit <7days 

after end of event: 

o Description of 

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

C-79 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

District Rule 

4311 (Flares) 

SCAQMD Rule 

1118 

(Control of 

Emissions from 

Refinery Flares) 

BAAQMD 

Reg. 12 

Rule 11 

(Flare 

Monitoring at 

Petroleum 

Refineries) 

BAAQMD Reg. 

12 

Rule 12 

(Flares at 

Petroleum 

Refineries) 

VCAPCD Rule 

54 (Sulfur 

Compounds) 

SBCAPCD Rule 359 

(Flares and 

Thermal Oxidizers) 

o For flares w/o 

water seal, 

ends when flow 

<0.12 ft/s 

 Submit annual 

report 

summarizing all 

reportable flaring 

events: 

o Results of 

cause 

investigation 

o Mitigation/ 

corrective 

actions to 

prevent 

recurrence 

o Justification for 

rejecting 

measures 

o Explanation of 

why emergency 

and cannot be 

recovered 

o Date, time, 

duration 

w/in 30 days – 

cause, duration, 

mitigation/ 

corrective 

actions 

 Measures 

taken to 

reduce or 

eliminate 

flaring 

why 

consistent 

with FMP 

 Explanation of 

why 

emergency 

and cannot be 

recovered 

 Volume flared 

 Methane, 

non-methane, 

HC, and SO2

emissions 

o Settings 

pressure 

relief valves 

and 

max/min 

allowed 

safety 

settings 

o Corrective 

measures 

and actions 

to prevent 

recurrence 

o Sulfur 

emissions 

o Equipment 

or controls 

that failed 

For planned 

flaring: 

 Notice 

submitted 

>72 hr. prior: 

o Work that 

requires 

o Date and 

time 

o Expected 

gas volume 

and sulfur 

emissions 

o Steps or 

equipment 

to minimize 

sulfur 

emissions 

mitigating and 

corrective actions 

implemented 

o Demonstration 

reasonable steps 

taken to minimize 

excess emissions 

o Demonstration 

that emergency 

not caused by 

improperly 

designed 

equipment; lack of 

preventative 

maintenance; 

careless or 

improper 

operation; 

operator error; 

willful misconduct 

o Document that 

source was 

properly operated 

at time event 

occurred 

As demonstrated above, Rule 4311 is as stringent as or more stringent than analogous 

rules in other California air districts. 

SBCAPCD Rule 359 (Flares and Thermal Oxidizers)38

SBCAPCD Rule 359 was adopted on June 28, 1994. Provisions of this rule apply to the 

use of flares and thermal oxidizers at oil and gas production sources, petroleum refinery 

and related sources, and natural gas services. Rule 359 sets specific requirements for 

the sulfur content in gaseous fuels, technology based standards, flare minimization 

plans, emergency events, and emission and operational limits. 

 

38 Santa Barbara County Air Pollution Control District. (1994, June 28). Rule 359 Flares and Thermal Oxidizers. 

Retrieved February 13, 2015 from http://www.ourair.org/wp-content/uploads/rule359.pdf. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-80 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Section D.3 of Rule 359 requires a FMP be submitted by any source subject to this rule 

that operates a flare rated at 15 MMBtu/hour or greater. For planned flaring, the FMP 

for all sources subject to this rule shall list a targeted maximum monthly flared gas 

volume, which shall not exceed 5% of the average monthly gas 

handled/produced/treated at the source unless the operator demonstrates such a 

maximum volume to be infeasible based on safety, engineering or cost constraints and 

proposes a different percentage. Any flaring that causes an exceedance of the 

emission limits or standards of Rule 359 is also not considered to be in violation if the 

operator demonstrates that the exceedance resulted from an emergency event. 

Unlike District Rule 4311, SBCAPCD Rule 359 does not apply to the burning of sulfur 

compounds in the manufacturing of sulfur compounds. Additionally, under SBCAPCD 

Rule 359, flares for which flaring operations solely consist of planned, continuous flaring 

due to the non-availability of a produced gas pipeline are exempt from FMP 

requirements. 

Although FMPs in SBCAPCD Rule 359 are required to list a targeted maximum monthly 

flared gas volume of five percent (5%) of the average monthly gas 

handled/produced/treated, the operator can obtain approval of a higher percentage by 

demonstrating that the maximum flare volume limit is infeasible based on safety, 

engineering, or cost constraints, which leaves the rule open to allow a higher amount of 

flaring. The District evaluated the percentage of gas flared in the Valley and found that 

the average percentage of gas flared between 2009 and 2013 was well below 

SBCAPCD’s 5% theoretical level at 3.8% as shown in the table below. 

Table C-11 Percent of Gas Flared at Valley Facilities 

Year Of Data Gas Produced 

(MCF) 

5% Flared 

(if meeting 

SBCAPCD 

target) (Mscf) 

Actual Flared 

(Mscf) 

Percent of gas 

flared 

2009 223,220,118 11,161,006 7,134,977 3.2 

2010 241,676,822 12,083,841 7,884,879 3.3 

2011 240,000,594 12,000,030 8,324,237 3.5 

2012 216,232,509 10,811,625 10,147,080 4.7 

2013 238,058,188 11,902,909 10,581,415 4.4 

 

Total Average 

Percent of Gas 

Flared in Valley 

3.8% 

In addition, unlike SBCAPCD rule 359, Rule 4311 does not allow an exceedance of any 

emissions limits or the requirement to minimize flaring activity, regardless of the cause. 

Allowing such a measure in the Valley would result in a serious relaxation of rule 

requirements and a potential increase in emissions. Under the District’s rule, any 

exceedance or excess flaring not allowed under Rule 4311, regardless of the cause, 

would result in a violation and be subject to enforcement action. Flares subject to 

SBCAPCD Rule 359 whose flaring operations solely consist of planned, continuous 

flaring due to the non-availability of a produced gas pipeline outlet are also exempt from 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-81 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

FMP requirements while such flares subject to Rule 4311 are not exempt from FMP 

requirements and are still required to identify and implement actions that reduce flaring. 

Based on the discussion above, District Rule 4311 is clearly more stringent than 

SBCAPCD Rule 359 for the following reasons: 

 Rule 4311 applies to a broader range of sources than SBCAPCD Rule 359 

 SBCAPCD Rule 359 includes a performance standard for the volume of gas 

flared (5%), but also includes APCO discretion for allowing unlimited flaring 

activity 

 SBCAPCD Rule 359 contains several exemptions not allowed in Rule 4311, 

including the allowance for exceedance of emission limits 

 EPA analysis resulted in the 2012 determination that Rule 4311 is as stringent as 

requirements in SBCAPCD Rule 359 in terms of core RACT requirements 

 Overall, Rule 4311 results in significantly less flared gas relative to flaring 

capacity in the District as compared the allowable levels of flaring under 

SBCAPCD 

State of North Dakota 

 Century Code 38-08-06.439 

 Industrial Commission Order40

North Dakota Century Code 38-08-06.4 applies to flaring of gas produced with crude oil 

from an oil well. The North Dakota rule allows for the uncontrolled flaring of all gases 

during the first year after opening a new crude oil production well, after which flaring of 

the entire volume of gas must cease and the well must be: 

 Capped; 

 Connected to a gas gathering line; 

 Equipped with an electrical generator that consumes at least seventy-five percent 

(75%) of the gas from the well; 

 Equipped with a system that intakes at least seventy-five percent (75%) of the 

gas and natural gas liquids volume from the well for beneficial consumption by 

means of compression to liquid for use as fuel, transport to a processing facility, 

production of petrochemicals or fertilizer, conversion to liquid fuels, separating 

and collecting over fifty percent (50%) of the propane and heavier hydrocarbons; 

or

 Equipped with other value-added processes as approved by the industrial 

commission, which reduce the volume or intensity of the flare by more than sixty 

percent (60%). 

 

39 North Dakota Legislative Branch. (2013, August). Century Code 38-08-06.4 Flaring of Gas Restricted – Imposition 

of Tax – Payment of Royalties – Industrial Commission Authority. Retrieved February 13, 2015 from 

http://www.legis.nd.gov/cencode/t38c08.pdf?20150213153521. 40 North Dakota Industrial Commission. (2014, July 1). Order of the Commission. Obtained February 3, 2015 from 

https://www.dmr.nd.gov/oilgas/or24665.pdf.
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-82 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Because of excessive flaring in North Dakota, the North Dakota Industrial Commission 

acted on a motion of the commission to consider amending the current oil production 

rule to reduce the amount of flared gas by issuing an order in July 2014 to increase gas 

capture from oil wells. The order requires 74% of gas capture (instead of flaring) by 

October 2014, 77% by January 2015, 85% by 2016, and 90% by 2020. If such gas 

capture percentage is not attained at a maximum efficient oil production rate, the well 

may still continue to produce 200 barrels of oil per day if at least 60% of the monthly 

volume of associated gas produced from the well is captured. If the 60% gas capture 

target is not met, the well may continue to produce 100 barrels of oil per day. This 

Order of the Commission is not an actual rule amendment and, because it did not pass 

through the entire public process, could be defeated in court or simply expire January 

2016.41

Many of the sources subject to Rule 4311 design and operate their equipment and 

processes in a manner that inherently results in minimal flaring activity. Flare gas is 

typically flared further along in the process, rather than directly from production wells, 

resulting in less flaring activity. In contrast, sources in North Dakota flare large portions 

of the gas generated at oil production wells. This is a rudimentary oil production method 

that is often seen in regions with little to no history of emission regulations. Flaring in 

North Dakota has increased more than 50% in the past two years to levels previously 

unknown in the United States and comparable to those of Russia and Nigeria.42 

According to North Dakota's Department of Mineral Resources, 29 percent (29%) of the 

natural gas now extracted in North Dakota is flared off, which accounts for almost 28% 

of all flaring in the United States and one percent (1%) of all flaring worldwide.43 In 

April, 2014 alone, North Dakota wells burned off 10.3 billion scf of natural gas, worth 

almost $50 million on the spot market. The annual value of flared gas is reportedly 

worth as much as $1 billion.44 This excessive flaring is due in part to the addition of 

1,100 to 2,700 wells per year, with tens of thousands of wells still lacking access to a 

gas transmission pipeline.45,46 

Even with the recent order from the North Dakota Industrial Commission to increase gas 

capture to 74% by October 2014, 77% by January 2015, 85% by 2016, and 90% by 

2020, the District already requires a minimum of 95% gas capture and achieves over 

96%. In addition, because the North Dakota rule contains no requirements to control 

 

41 The Bismarck Tribune. (2015, January 19). Helm says tax revenue at risk if flaring, oil conditioning orders voided. 

Retrieved February 13, 2015 from http://bismarcktribune.com/news/state-and-regional/helms-says-tax-revenue-atrisk-if-flaring-oil-conditioning/article_e615f72d-d2ff-50a6-a151-4875945792c5.html 42 King & Spalding. (2014, June). Dispute Resolution, Oil & Gas Litigation. Retrieved February 13, 2015 from 

http://www.kslaw.com/library/newsletters/EnergyNewsletter/2014/June/article2.html. 43 North Dakota Pipeline Authority. Natural Gas Facts. Retrieved February 13, 2015 from 

http://northdakotapipelines.com/natgasfacts/. 44 General Electric. (2014, September 10). Taming North Dakota’s Gas Flares. Retrieved February 13, 2015 from 

http://www.gereports.com/post/97136504480/taming-north-dakotas-gas-flares. 45 Oil & Gas Monitor. (2014, August 11). Can a Flaring Problem Become Natural Gas Industry Advantage in North 

Dakota? Retrieved February 13, 2015 from http://www.oilgasmonitor.com/can-flaring-problem-become-natural-gasindustry-advantage-north-dakota/7617/. 46 North Dakota Department of Mineral Resources. Retrieved February 13, 2015 from 

http://www.ndoil.org/image/cache/NDPCAnnual092111_2.pdf. 
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the fraction of gas not addressed by one of the required options, a producer would be 

able to vent up to 40% of produced gas directly to the atmosphere and still have the 

ability to flare the full captured amount. For the first year of operation, operators of new 

oil production wells are permitted to flare 100% of produced gas. Additionally, the 

optional equipment used to control the captured gas, such as uncontrolled internal 

combustion engines, could easily increase emissions because flaring in itself is a highly 

effective control technology. Finally, a producer may obtain an exemption by 

demonstrating to the industrial commission that connection of the well to a natural gas 

gathering line is economically infeasible or that a market for the gas is not available and 

equipping the well with an electrical generator to produce electricity from gas or 

employing a collection system is economically infeasible. North Dakota regulators 

granted ninety-five percent (95%) of extension requests over the last two years.47 

In the Valley, operators do not have the flexibility to capture only 60% of associated gas 

or to obtain extensions or exemptions from rule requirements as allowed in the North 

Dakota rule. New steam enhanced wells (the vast majority of wells in the District are 

heavy oil steam enhanced wells) require an ATC permit before they are operated. As 

part of receiving an ATC, these wells are subject to the District’s New Source Review 

rule (District Rule 2201), which requires the installation of Best Available Control 

Technology (BACT) consisting of a system that collects and controls well vapors and 

must comply with a multitude of additional requirements (i.e, offsets, public noticing, 

health risk assessment, etc.). 

The District has two rules specific to the operation of crude oil wells. Rule 4401 (SteamEnhanced Crude Oil Production Wells) and Rule 4409 (Components at Light Crude Oil 

Production Facilities, Natural gas Production Facilities, and Natural Gas Processing 

Plants). These rules contain control requirements including a minimum 95% capture 

and control, periodic leak detection, and repair requirements for steam enhanced wells 

and light oil wells. These rules also require the development of an Operator 

Management Plan (OMP) that describes how a facility will comply. The OMP must be 

updated annually to reflect any changes to the OMP, including changes to address 

newly installed wells. These prohibitory rules are applicable to both existing and new 

wells. 

Regions such as North Dakota have only recently begun controlling emissions from 

flares and, as such, must make significant progress before matching the District in 

capture and control technology and stringency of regulations. After extensive analysis 

of the North Dakota rule requirements and comparison to those in the District, it is clear 

that Rule 4311 is significantly more stringent than North Dakota Century Code 38-08-

06.4 for at least the following reasons: 

 Rule 4311 applies to a broader range of sources than the North Dakota rule 

 

47 Scientific American. (2013, September 12). North Dakota flared off $1 billion worth of natural gas last year. 

Retrieved February 14, 2015 from http://blogs.scientificamerican.com/plugged-in/2013/09/12/north-dakota-flared-off1-billion-worth-of-natural-gas-last-year/. 
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 Rule 4311 requires 95% capture and treatment of produced gas, whereas the 

North Dakota rule only requires 60% capture and allows one year of unlimited 

flaring 

 The North Dakota rule does not contain any requirements that address the 

remaining 40% of produced gas 

 95% of facilities that requested extensions to the requirements of the North 

Dakota rule were approved 

Evaluation Findings 

Even though flares are not a significant source of PM2.5, NOx, or SOx in the Valley, the 

District has evaluated all potential control technologies and all control technologies 

achieved in practice in other areas or included in other state implementation plans. As 

demonstrated above, Rule 4311 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 this source category. 

As described in the section detailing FMP requirements, operators of flares in the Valley 

are already implementing all feasible measures to reduce flaring activity. Even for those 

devices that have been committed to in FMPs, alternative methods of disposal do not 

necessarily decrease emissions, and could even increase emissions compared to the 

baseline from flares; however, combusting gas onsite or transmitting it for use at other 

sources could prevent the additional combustion of other fuel, thereby reducing overall 

emissions in the Valley, if not actually reducing emissions from the combustion of the 

flare gas. 

In other air districts, the addition of transmission pipelines is the only major viable 

possible measure to reduce emissions. In the Valley, most producers of associated gas 

have access to transmission pipelines and are already selling as much gas as possible. 

The addition of pipelines would most likely not be performed by the facilities operating 

flares, but would instead be installed by utility companies such as PG&E. Requiring oil 

and gas producers that do not have access to transmission pipelines to construct them 

would be cost prohibitive and is beyond the scope of what is required by any other air 

district. 

Although Rule 4311 already meets BACM and MSM requirements, the District is 

committing to further evaluate Rule 4311 beginning in 2015. See Chapter 8 

(Commitment to Leave No Stone Unturned to Evaluate Additional Opportunities) for 

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

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C.12 RULE 4313 LIME KILNS 

Discussion 

Rule 4313 was adopted in 2003 to limit NOx emissions from the operation of lime kilns. 

Lime kilns can be used in a variety of manufacturing and processing operations, 

including food and agriculture. EPA finalized approval of the 2003 adoption of Rule 

4313 on September 4, 2003 and deemed this rule as being at least as stringent as 

established RACT requirements. 

Source Category 

There are currently no lime kilns operating in the Valley. At the time of rule adoption, 

there were a total of three lime kilns in the Valley, used at two sugar processing plants; 

however, these plants have been non-operational since 2008. Any lime kilns beginning 

operation in the Valley in the future would be required to meet District BACT 

requirements, per District Rules 2201 (New and Modified Stationary Source Review 

Rule) and 4001 (New Source Performance Standards). 

Emissions Inventory

There is no emissions inventory associated with lime kilns because there are no lime 

kilns operating in the Valley; no lime kilns are in the preliminary permitting process to 

become operational in the Valley, nor are any lime kilns expected to be operated in the 

Valley in the future. 

How does District Rule 4313 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG or ACT requirements for this source category. 

NSPS 

 40 CFR 60 Subpart HH (Standards of Performance for Lime Manufacturing Plants)

The District evaluated the requirements contained within 40 CFR 60 Subpart HH and 

found no requirements that were more stringent than those already in Rule 4313. 

NESHAP/ MACT 

 40 CFR 63 Subpart AAAAA (National Emission Standards for Hazardous Air 

Pollutants for Lime Manufacturing Plants) 

The District evaluated the requirements contained within 40 CFR 63 Subpart AAAAA 

and found no requirements that were more stringent than those already in Rule 4313.

State Regulations 

There are no state regulations applicable to this source category. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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How does District Rule 4313 compare to rules in other air districts? 

There are no analogous rules for this source category in SCAQMD, BAAQMD, 

SMAQMD, and VCAPCD. 

Evaluation Findings

There are no lime kilns operating in the Valley and thus no emissions or emission 

reduction opportunities for this source category. As previously mentioned, any lime 

kilns beginning operation in the future would be required to meet District BACT 

requirements. As such, Rule 4313 meets or exceeds both BACM and MSM 

requirements for this source category. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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C.13 RULE 4352 SOLID FUEL FIRED BOILERS, STEAM GENERATORS, AND 

PROCESS HEATERS 

Discussion 

The purpose of Rule 4352 is to limit NOx and carbon monoxide (CO) emissions from 

any boiler, steam generator or process heater fired on solid fuel. Prior to September 14, 

1994 solid fuel fired units were exempt from the requirements of District Rule 4305. The 

adoption of Rule 4352 established NOx limits of 200 parts per million volume (ppmv) for 

municipal solid waste facilities (MSW), 0.35 pounds per million British thermal units per 

hour (lb/MMBtu) for biomass facilities, and 0.20 Ib/MMBtu for all other solid fuel fired 

units. Since its adoption, the rule has been amended three times. The December 2011 

amendments strengthened the rule by lowering NOx emissions limits for all three source 

categories. However, no emissions reductions were quantified because the rule 

amendments were meant to satisfy EPA RACT requirements and all units were 

determined to be operating at the new emission limits. EPA finalized approval of Rule 

4352 on November 6, 2012 and deemed this rule as being at least as stringent as 

established RACT requirements. 

While previous rule-amending projects for Rule 4352 have not quantified specific 

emissions reductions, the use of biomass facilities in the Valley has fostered emissions 

reductions. As an energy source, biomass can either be used directly or converted into 

other energy products such as biofuel. Biomass facilities in the Valley reduce the 

amount of pollutants created by open burning practices and the landfilling of potential 

biofuels such as agricultural materials, and urban and forest wood waste products by 

utilizing these materials. The District has reduced the total acreage of agricultural 

materials burned in the Valley to date by more than 80%. 

Source Category 

Boilers, steam generators, and process heaters are used in a broad range of industrial, 

commercial, and institutional settings. Units subject to this rule fire on a variety of solid 

fuels: coal, petroleum coke, biomass, tire-derived fuel, and MSW. Although the output 

from units subject to the rule could be utilized in many settings, all of the operators 

within the Valley use the units’ output to generate electricity. There are 17 units subject 

to this rule located at 15 facilities. 

The two primary methods of controlling NOx emissions from boilers, steam generators, 

and process heaters are either to change the combustion parameters to reduce NOx 

formation (i.e., combustion modification) or to treat the NOx formed in the process 

before the NOx is emitted into the atmosphere (i.e., post-combustion control or flue gas 

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

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 2015 Plan for the 1997 PM2.5 Standard 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.62 0.65 0.67 0.72 0.76 0.79 0.82 0.84 0.87 

NOx 2.69 2.77 2.85 2.99 3.14 3.21 3.30 3.36 3.47 

SOx 0.56 0.57 0.59 0.61 0.64 0.66 0.68 0.69 0.71 

Winter Average - Tons per day 

PM2.5 0.61 0.64 0.66 0.71 0.75 0.77 0.81 0.83 0.86 

NOx 2.40 2.49 2.56 2.71 2.85 2.91 3.01 3.07 3.18 

SOx 0.54 0.56 0.57 0.59 0.62 0.64 0.66 0.68 0.69 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from solid fuel fired boilers, steam generators, and process 

heaters are lower than the BACM/MSM significance thresholds. Therefore, the Clean 

Air Act does not require a control measure evaluation for this source category for the 

purpose of satisfying BACM/MSM requirements; however, the District has still 

conducted a full control measure evaluation for solid fuel fired boilers, steam 

generators, and process heaters. 

How does District Rule 4352 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG requirements for this source category. 

ACT 

 EPA–453/R-94-022 (Alternative Control Techniques Document– NOx Emissions 

from Industrial/Commercial/ Institutional Boilers) 

The District evaluated the requirements contained within the ACT for NOx Emissions 

from Industrial/Commercial/Institutional Boilers and found no requirements that were 

more stringent than those already in Rule 4352. 

 EPA – 453/R-94-023 (Alternative Control Techniques Document– NOx Emissions 

from Utility Boilers) 

The District evaluated the requirements contained within the ACT for NOx Emissions 

from Utility Boilers and found no requirements that were more stringent than those 

already in Rule 4352. 

NSPS 

 40 CFR 60 Subpart Cb (Emission Guidelines and Compliance Times for Municipal 

Waste Combustors that are Constructed on or before December 19, 1995) 
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 2015 Plan for the 1997 PM2.5 Standard 

The District evaluated the requirements contained within 40 CFR 60 Subpart Cb and 

found no requirements that were more stringent than those already in Rule 4352. 

 40 CFR 60 Subpart D (Standards of Performance for Fossil-Fuel-Fired Steam 

Generators for which Construction is Commenced after August 17, 1971) 

The District evaluated the requirements contained within 40 CFR 60 Subpart D and 

found no requirements that were more stringent than those already in Rule 4352. 

 40 CFR 60 Subpart Db (Standards of Performance for Industrial-CommercialInstitutional Steam Generating Units) 

The District evaluated the requirements contained within the 40 CFR 60 Subpart Db and 

found no requirements that were more stringent than those already in Rule 4352. 

NESHAP/ MACT 

 40 CFR 63 Subpart DDDDD (NESHAP for Major Sources: Industrial, Commercial, 

and Institutional Boilers and Process Heaters) 

40 CFR 63 Subpart DDDDD was amended on January 31, 2013 to include new 

emission limits for PM, CO, and total selective metals (TSM), replace numeric dioxin 

emission limits with work practice standards, add new subcategories of facilities, and 

add alternative monitoring approaches. The District evaluated the requirements 

contained within this NESHAP and found no requirements that were more stringent than 

those already in Rule 4352. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 4352 compare to rules in other air districts? 

There are no analogous rules for this source category in VCAPCD. 

SCAQMD 

 Rule 1146 (Emissions of Oxides of Nitrogen from Industrial, Institutional, and 

Commercial Boilers, Steam Generators, and Process Heaters) 

The District evaluated the requirements contained within SCAQMD’s Rule 1146 and 

found no requirements that were more stringent than those already in Rule 4352. 

BAAQMD 

 Regulation 9 Rule 7 (Nitrogen Oxides and Carbon Monoxide from Industrial, 

Institutional, and Commercial Boilers, Steam Generators, and Process Heaters) 

The District evaluated the requirements contained within BAAQMD’s Regulation 9 Rule 

7 and found no requirements that were more stringent than those already in Rule 4352. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-90 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

 Regulation 9 Rule 11 (Nitrogen Oxides and Carbon Monoxide from Electric Power 

Generating Steam Boilers) 

The District evaluated the requirements contained within BAAQMD’s Regulation 9 Rule 

11 and found no requirements that were more stringent than those already in Rule 

4352. 

SMAQMD 

 Rule 411 (NOx from Boilers, Process Heaters, and Steam Generators) 

The District evaluated the requirements contained within SMAQMD’s Rule 411 and 

found no requirements that were more stringent than those already in Rule 4352. 

Additional Emission Reduction Opportunities 

Biomass Facilities 

The presence of biomass facilities in the Valley, from either new facilities or other solid 

fuel fired boilers that have converted to biomass, continues to significantly reduce NOx 

and PM emissions from open burning practices. However, the biomass industry has 

indicated that given current energy policy in California there is concern that biomass 

power facilities are in jeopardy. Many biomass plants in the Valley are nearing the end 

of their long-term contracts with utilities and find themselves in a position where the 

power that they provide is not the type of power that utilities are seeking (base load vs. 

intermittent) and that the prices being offered for new contracts are too low to support 

their operations. 

The District has learned that two biomass power plants have shut down due to their 

inability to secure contracts with utilities at rates that are sufficient to sustain their 

operations. Greenleaf Power that operates the Tracy Biomass Plant, located in Tracy, 

reported that they shut down on October 31, 2014 and the Covanta facility located in 

Mendota was shut down in January 2015. Initially, another Covanta facility in Delano 

had indicated that they were likely to shut down but is now reporting that they were able 

to secure a one-year extension on their current utility contract at the same rate that 

enables them to continue to operate. With additional biomass facilities on the brink of 

closure, it has become even more infeasible to require citrus orchard removals to be 

sent for use in biomass. 

The District has convened a number of productive meetings with agricultural 

stakeholders and representatives of the biomass industry in order to more fully 

understand the issues faced by the industry and develop a common vision of the future 

of biomass power amongst the stakeholders in the Valley. The meetings have been 

helpful in forging a better working relationship between agriculture representatives and 

biomass power producers and developing consensus on long-term solutions. The 

group has also discussed potential short term solutions. 

In June 2014, the District’s Governing Board adopted positions on two pieces of 

legislation that impact the biomass industry. The District adopted a position in support 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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of AB 2363 (Dahle), which was sponsored by the biomass industry, and would make 

biomass plants more competitive by fully accounting for the costs associated with 

intermittent sources of renewable power (solar and wind) when comparing them to other 

sources of power. AB 2363 was signed by the Governor and will begin to help level the 

renewable energy playing field. The District also took a position in opposition to SB 

1139 (Hueso) that would have given preferential treatment to new geothermal power 

plants by requiring that utilities purchase specified amounts of new geothermal power. 

Ultimately, AB 1139 was not passed by the legislature. 

 

Long-Term Solutions for Biomass 

There is consensus that biomass power producers currently are not on a level playing 

field in competing with other renewable sources of power for utility contracts. They are 

also not receiving any preferential treatment for the societal benefits for providing a 

cleaner alternative to the open burning of agricultural waste and assisting with meeting 

landfill diversion goals. 

Contracts between power producers and utilities are confidential, but the current market 

rate that the biomass plants can garner is approximately 6 cents/KWH. This is the rate 

that the utilities obtain through contracts with solar power providers. This low cost is 

made possible largely due to government subsidies provided for solar power production. 

Biomass power producers have indicated that it takes approximately 9-10 cents/KWH 

for the plants to cover their operating costs. 

The District and representatives from agriculture and biomass industries are working to 

develop and pursue specific actions with the legislative branch, utilities, Public Utility 

Commission, CalRecycle, and other government agencies to help level the playing field 

and allow the biomass industry to fairly compete. 

The District will also work with the stakeholders including the Federal Department of 

Energy, California Energy Commission, and other partner agencies to pursue clean 

alternatives to biomass power production for agricultural waste disposal. 

Selective Catalytic Reduction 

When comparing Rule 4352 to EPA and other air districts’ BACT requirements, it was 

noted that SCR systems are considered BACT. A SCR system reduces NOx emissions 

by converting the emissions to water and elemental nitrogen. In the analyses below, 

the District evaluated the cost effectiveness of requiring SCR for all three categories of 

solid fuel fired boilers: MSW, biomass, and other fuels. 

Cost Effectiveness of SCR for MSW Units 

Currently, facilities are generally equipped with Selective Non-Catalytic Reduction 

(SNCR) and utilize this technology to meet emission limits ranging between 165 ppmv 

to 210 ppmv. Although it appears that facilities can achieve a lower NOx limit beyond 

the current rule requirements, an additional NOx control technology such as Selective 

Catalytic Reduction (SCR) would be needed. In fact, the installations that are achieving 

lower NOx emissions were installed as new installations equipped with the SCR 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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technology. The District could not find an example of an SCR installation as a retrofit on 

an existing MSW facility. 

Though a retrofit installation has not been demonstrated in practice, the District 

conducted a cost effectiveness analysis to determine if installing SCR as a retrofit would 

be reasonable. The District used the following methodology and assumptions for this 

cost effectiveness analysis: 

Assumptions

 Baseline emission factor is 0.286 lb-NOx/MMBtu (equivalent to 165 ppmv @ 12% 

CO2) 

 SCR provides control to 50 ppmv at 7% O2 (47 ppmv @ 12% CO2) 

 Capital cost annualized at 10% interest for 10 years 

Cost data was obtained from a preconstruction approval by the Florida Department of 

Environmental Protection (FDEP) issued on December 23, 2010. The approval was 

issued for an MSW-fired combustor equipped with SCR for NOx control. The control 

equipment costs from the FDEP application include uncontrolled NOx emissions of 250 

ppmv and controlled NOx emissions of 50 ppmv which represents an 80% reduction in 

NOx from the SCR. However, 80% reduction from 165 ppmv @ 12% CO2 would yield 

controlled emissions of 33 ppmv, which is well below BACT. Therefore, controlled 

emissions are evaluated at the BACT limit of 47 ppmv @ 12% CO2.

 

The SCR installation is sized for a unit rated at approximately 460 MMBtu/hr used to 

produce superheated steam for an electrical generator. The District reviewed the 

expected exhaust parameters and found them comparable to the parameters for solid 

fuel-fired boilers in the Valley. Therefore, it is believed that this cost estimate provides a 

valid basis for estimating costs for installing SCR on boilers in the Valley. 

To maximize the emission reductions and economies of scale in estimating the retrofit 

costs, it is assumed that a 350 MMBtu/hr unit operating at full fire at 100% capacity 

factor year round for the MSW facility. The purpose of these assumptions is to err on 

the conservative side throughout the analysis. 

Emissions are calculated in the following table: 

Table C-12 Emissions from a MSW Unit 

Fuel Rating 

(MMBtu/hr) 

Time 

(hr/yr) 

EF 

(lb/MMBtu)

Emissions 

(lb/yr) 

Emissions 

(tons/yr) 

MSW (baseline) 350 8,760 0.286 876,000 438 

MSW (controlled) 350 8,760 0.081 248,346 124 

The capital and operational costs are sized to the facility size using the six-tenths rule, 

where: 

 CA is a known cost of equipment of size A 

 CB is the estimated cost of equipment of size B 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

 SB is the size of equipment B 

 SA is the size of equipment A 

CB = CA x (SB ÷ SA)

0.6

It is standard District policy for Best Available Control Technology (BACT) analyses to 

use a 10 year life and 10% interest rate unless information indicates otherwise; 

therefore the capital recovery factor (CRF) of 0.1627 will be used to annualize the 

capital costs. 

It is noted that the FDEP cost analysis is for a new unit with an adequately-sized 

induced draft (ID) fan. However, for a new unit the ductwork can be laid out in a way 

that minimizes pressure losses, allowing for a smaller ID fan than may be required for a 

retrofit. Affected sources have provided some estimates for additional electrical costs 

associated with the larger ID fan required for a retrofit, so these have been incorporated 

into the analysis. In addition, the FDEP analysis is for a new unit so it does not include 

the loss of revenue from taking a unit off-line to retrofit the new technology. For each 

unit it is estimated that the retrofit would require at least six months of downtime at 

$118/MW-hr; this will be added to the capital cost. Finally, the FDEP analysis 

specifically ignored sales tax on capital equipment on the grounds it is exempt from 

sales tax in Florida. This would not be the case in California, so 8% sales tax has been 

included. 

The cost effectiveness analysis for installing SCR on a MSW unit is as follows: 

Table C-13 Cost Effectiveness for Installing SCR on a MSW Unit

Description of Cost Cost Factor Cost Source 

Direct Capital Costs (DC): 

Purchase Equipment Costs (PE): 

(A) Basic Equipment: 

1) SCR System (Quote from Babcock Power) 6,790,099 FDEP48

2) Additional Ductwork (220 ft) $1,800/ft 336,110 FDEP 

3) Increased ID fan size 7,384 FDEP 

Subtotal of Basic Equipment A 7,133,593 FDEP 

(B) Instrumentation and controls: (1% of A) 0.01 A 71,336 FDEP 

(C) Freight: (5% of A) 0.05 A 356,680 FDEP 

(D) Taxes 0.08 (A+B+C) 604,929 OAQPS 

PE Total: 8,166,538 

Direct Installation Costs (DI): Assume Modular SCR w/ simple installation 

Foundation and Supports: 0.16 PE 1,306,646 FDEP 

Handling and Erection: 0.40 PE 3,266,615 FDEP 

Electrical: (quote from CH2M Hill) 0.10 PE 816,654 Industry 

Piping: (quote from CH2M Hill) 0.20 PE 1,633,308 Industry 

Insulation: 0.01 PE 81,665 OAQPS 

Painting: 0.01 PE 81,665 OAQPS 

 

48 All costs from FDEP size-adjusted using six-tenths rule from 460 MMBtu/hr to 350 MMBtu/hr. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

Description of Cost Cost Factor Cost Source 

Costs for Expansion of APC Building for SCR 

Components (quote Malcolm Pirnie) 366,665 FDEP 

DI Total: 7,553,218 

Retrofit (Deconstruct existing building/structures, 

estimated equal to DI total) 7,553,218 District 

Natural gas pipeline (replace fuel oil #2) 3,000,000 Industry 

Site Preparation and Buildings 

DC Total = PE + DI + retrofit + pipeline: 26,272,974 

Indirect Costs (IC): 

Engineering: 0.10 PE 816,654 OAQPS 

Construction and Field Expenses: 0.05 PE 408,327 OAQPS 

Contractor Fees: 0.10 PE 816,654 OAQPS 

Contingencies: 0.15 PE 1,224,981 FDEP 

Start-up: 0.02 PE 163,331 OAQPS 

Performance Testing: 0.01 PE 81,665 OAQPS 

Retrofit Downtime (6 months minimum, electricity 

sales and tipping fees) 11,000,000 Industry 

IC Total: 14,511,612 

Total Capital Investments (TCI = DC + IC): 40,794,586 

Direct Annual Costs (DAC): Assume SCR requires 0.5 hrs/shift 

Operating Costs (O): ( 1,095 shifts/year @ 3 shifts/day) 

Operator: 1.0 hr/shift $50/hr 54,750 FDEP 

Supervisor: 15% operator 8,213 OAQPS 

Maintenance Costs (M): 

Labor: 1.0 hr/shift $50/hr 54,750 FDEP 

Material: 100% labor 54,750 FDEP 

Utility Costs (U): 

Performance loss: $0.08848/kWhr 386,495 FDEP 

Electricity Cost: (additional 818 kW49) $0.08848/kWhr 634,019 Industry

Catalyst Replace: 123,071 FDEP

Total DAC: 1,316,048 

Indirect Annual Costs (IAC): 

Overhead: 60% O & M 87,828 OAQPS 

Insurance: 0.01 TCI 407,946 OAQPS 

Property Tax: 0.01 TCI 407,946 OAQPS 

Administrative: 0.02 TCI 815,892 OAQPS 

Annualized Total Capital Investment: interest rate 

(%) 10 

Period 

(years): 10 0.1627 TCI 6,637,279 District 

Policy 

Total IAC: 9,672,939 

Total Annual Cost (DAC + IAC): 9,672,939 

 

49 Resized from industry estimate of 2 trains, 628 kW/train, for a 715 MMBtu/hr facility, resized to 350 MMBtu/hr 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-95 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Table C-14 Summary of Cost Effectiveness for Installing SCR on a MSW Unit 

Fuel Type 

Baseline 

Emissions 

(tons/yr)

Controlled 

Emissions 

(tons/yr)

Emissions 

Reduced 

(tons/yr)

Adjusted 

Annualized 

Cost 

($/yr)

Cost 

Effectiveness 

($/ton)

MSW 438 124 314 9,672,939 $30,806/ton 

The cost effectiveness for installing SCR on a MSW fired boiler is $30,806 per ton of 

NOx reduced. It is important to note that this calculation is based off of a new 

installation of SCR, not a retrofit as would be required by Valley facilities. While some 

retrofit expenses have been included, operators would potentially incur additional costs 

when retrofitting to incorporate SCR including expenses for additional ductwork, 

installation of a new natural gas pipeline to replace the existing fuel oil supply, and 

labor; therefore, District staff assumes the cost effectiveness is even higher than 

presented in this analysis. 

Cost Effectiveness of SCR for Biomass Units 

Currently, facilities are generally equipped with SNCR and although it appears that 

facilities could possibly achieve a lower NOx limit beyond the revised proposed rule 

amendments, additional NOx control technology such as SCR would be needed. In 

fact, the installations that are achieving lower NOx emissions are typically installed as 

new installations equipped with the SCR technology, with one exception. One facility in 

the Valley has installed SCR on a smaller existing boiler under an experimental 

research exemption approved in February 2008. In March 2009, the District approved 

the facility’s application to replace the existing SNCR (which had become inoperable) 

with the SCR installed under the experimental research exemption. This modification 

did not result in any reduction in permitted emissions as the SCR-equipped boiler is only 

required to comply with the same emission limit the SNCR-equipped boiler was. This 

modification was incorporated into the Title V permit in September 2010. While this 

example may indicate that SCR is technologically feasible as a retrofit for smaller sized 

biomass-fired boilers, there are many other considerations unique to each facility that 

may inhibit the retrofit of a SCR system. Based on the following analysis, SCR is not 

cost effective at this time. It is important to note that this cost effectiveness analysis 

does not take into consideration the current economic struggles of the biomass industry, 

as previously described. 

The District used the following methodology and assumptions for this cost effectiveness 

analysis: 

Assumptions

 Baseline emission factor is 0.11 lb-NOx/MMBtu for Biomass(equivalent to 

85ppmv @ 3% O2) 

 SCR provides 80% control efficiency (from the provided cost estimates) 

 Capital cost annualized at 10% interest for 10 years 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-96 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Cost data was obtained from a preconstruction approval by the FDEP issued on 

December 23, 2010 as described above in the MSW section. 

To maximize the emission reductions and economies of scale in estimating the retrofit 

costs, it is assumed that a 700 MMBtu/hr unit is operating at full fire at 100% capacity 

factor year round is representative for the Valley biomass facilities. The purpose of 

these assumptions is to err on the conservative side throughout the analysis. 

Emissions are calculated in the following table: 

Table C-15 Emissions Calculations for a Biomass Unit 

Fuel 

Type 

Rating 

(MMBtu/hr) 

Time 

(hr/yr) 

EF 

(lb/MMBtu)

Emissions 

(tons/yr) 

Control 

Efficiency 

Emissions 

Reduced 

(tons/yr) 

Biomass 700 8,760 0.11 337.26 80% 269.8 

The capital and operational costs are sized to the facility size using the six-tenths rule, 

as described in the MSW section above. 

CB = CA x (SB ÷ SA)

0.6

Therefore; 

 CB = $9,672,939/year x (700 MMBtu/hr ÷ 350 MMBtu/hr)0.6 

 = $14,661,434/year 

It is standard District policy to use a 10 year life and 10% interest rate; therefore the 

capital recovery factor (CRF) of 0.1627 will be used to annualize the capital costs. 

Table C-16 Cost Effectiveness for Installing SCR on a Biomass Unit 

Fuel Type 

Adjusted 

Annualized Cost 

($/yr) 

Emissions 

Reduced (tons/yr) 

Cost Effectiveness 

($/ton) 

Biomass 14,661,434 269.8 $54,342/ton 

It is estimated based on the above data and assumptions that requiring the installation 

of SCR would provide a cost effectiveness of $54,342/ton for a biomass-fired boiler. 

The cost effectiveness was evaluated without taking into account additional potential 

costs involved in a retrofit of the facility. It should also be noted that the District’s cost 

effective analysis is very conservative since the installation of the SCR technology with 

an 80% control efficiency assumes a NOx emission level of approximately 17 ppmv @ 

3% O2. This level is lower than established BACT levels and well beyond RACT 

thresholds. Therefore, even with these conservative assumptions, the installation of 

SCR is not cost effective for these types of installations. 

 

Furthermore, the emission factors used above are short-term emission limits on a block 

24-hour average basis and in all probability will not be representative of actual annual 

emission rates. Indeed, the post-SCR emission factors for biomass is 0.022 lb/MMBtu, 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-97 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

which is well below the short-term emission limits for recently issued biomass-fired 

boiler ATCs. If, as appears possible, the post-SCR emission rates are higher than 

assumed above, then the quantity of emission reductions will be lower and the cost of 

emission reductions greater. Finally, it is vital to remember that the 700 MMBtu/hr boiler 

assumed for biomass boilers above is an idealized hypothetical chosen to maximize the 

economies of scale in using the six-tenths rule to scale the cost estimate. For any 

actual plant within the population of solid fuel-fired boilers in the Valley, the boiler rating 

will be lower (as small as 171.2 MMBtu/hr) and the cost of emission reductions will be 

correspondingly higher. 

Cost Effectiveness of SCR for Units Using Other Fuels 

Currently, facilities are equipped with SNCR and although facilities may be able to 

achieve a lower NOx limit beyond the revised proposed rule amendments, additional 

NOx control technologies such as SCR would be needed. District staff conducted a 

cost effectiveness analysis to determine if installing SCR as a retrofit would be 

reasonable. 

District staff used the following methodology and assumptions for this cost effectiveness 

analysis: 

Assumptions

 Baseline emission factor is 0.10 lb-NOx/MMBtu (equivalent to 73 ppmv @ 3% 

O2) 

 SCR provides 80% control efficiency (from the provided cost estimates) 

 Capital cost annualized at 10% interest for 10 years 

Cost data to install the SCR technology was obtained from a preconstruction approval 

the FDEP issued on December 23, 2010 as described above in the MSW section. 

To maximize the emission reductions and economies of scale in estimating the retrofit 

costs, it is assumed that a 700 MMBtu/hr unit operating at full fire at 100% capacity 

factor year round is representative for boilers firing on “other” fuels. The purpose of 

these assumptions is to err on the conservative side throughout the analysis. 

Emissions are calculated in the following table: 

Table C-17 Emissions Calculations for Other Units 

Fuel 

Type 

Rating 

(MMBtu/hr) 

Time 

(hr/yr) 

EF 

(lb/MMBtu)

Emissions 

(tons/yr) 

Control 

Efficiency 

Emissions 

Reduced 

(tons/yr) 

Other 700 8,760 0.10 306.6 80% 245.3 

The capital and operational costs are sized to the facility size using the six-tenths rule, 

as described in the MSW section above. 

CB = CA x (SB ÷ SA)

0.6
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-98 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Therefore; 

 CB = $9,672,939/year x (700 MMBtu/hr ÷ 350 MMBtu/hr)0.6 

 = $14,661,434/year 

It is standard District policy to use a 10 year life and 10% interest rate; therefore the 

capital recovery factor (CRF) of 0.163 will be used to annualize the capital costs. 

Table C-18 Cost Effectiveness for Installing SCR Other Unit 

Fuel Type 

Adjusted 

Annualized Cost 

($/yr) 

Emissions 

Reduced (tons/yr) 

Cost Effectiveness 

($/ton) 

Other 14,661,434 245.3 $59,769/ton 

It is estimated based on the above data and assumptions that requiring the installation 

of SCR would result in a cost effectiveness of $59,769/ton for an Other Fuel-fired boiler. 

The cost effectiveness was evaluated without taking into account additional potential 

costs involved in a retrofit of the facility. The District has determined that is not 

economically feasibility to require SCR based on this cost effectiveness analysis and did 

not further evaluate additional costs associated with a retrofit. It should also be noted 

that the District’s cost effective analysis is very conservative since the installation of the 

SCR technology with an 80% control efficiency assumes a NOx emission level of 

approximately 15 ppmv @ 3% O2. This level is lower than established BACT levels and 

well beyond RACT thresholds. Therefore, even with these conservative assumptions, 

the installation of SCR is not cost effective. 

Furthermore, the emission factors used above are short-term emission limits on a block 

24-hour average basis and in all probability will not be representative of actual annual 

emission rates. Indeed, the post-SCR emission factors for “other” fuels is 0.020 

lb/MMBtu, which is well below the short-term emission limits for recently issued ATCs. 

If, as appears possible, the post-SCR emission rates are higher than assumed above, 

then the quantity of emission reductions will be lower and the cost of emission 

reductions greater. Finally, it is vital to remember that the 700 MMBtu/hr boiler 

assumed for “other” fuels above is an idealized hypothetical chosen to maximize the 

economies of scale in using the six-tenths rule to scale the cost estimate. For any 

actual plant within the pollution of solid fuel-fired boilers in SJVAPCD, the boiler rating 

will be lower (as small as 171.2 MMBtu/hr) and the cost of emission reductions will be 

correspondingly higher. Based off of this information, it would not be cost effective to 

require Valley facilities to retrofit with additional NOx reduction technology beyond what 

is currently being used. 

Controls for Direct PM2.5 Emissions 

The District researched the potential opportunity of specifying required controls for 

direct PM2.5 emissions. Three technologies were recognized as being able to 

potentially reduce direct PM2.5 emissions: electrostatic precipitators (ESPs), 

baghouses, and cyclones. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-99 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

An ESP is a particulate collection device that removes particles from a flowing gas using 

the force of an electrostatic charge with a 90- 99.9% control efficiency of PM2.5 for solid 

fuel fired boilers within the 100-500 MMBtu/hr size range of District units.50 A 

baghouse, on the other hand, is a technology in which particulates are removed from a 

stream of exhaust gases as the stream passes through a large cloth bag. Baghouses 

have a PM2.5 removal effectiveness of 90-99.9% for solid fuel fired boilers in the size 

range of District units.51 Coal and coke-fired units generally use baghouses, but 

biomass boilers usually use ESPs because of the health and safety risk of the burning 

embers causing a fire in the baghouse. However, when cyclones are combined with the 

use of a baghouse, the burning embers are extinguished and allow for the use of a 

baghouse in a biomass facility52. This also reduces acid gases and some PM2.5 

compared to the use of a baghouse alone. 

All of the facilities subject to Rule 4352 have installed either a baghouse or ESP 

particulate matter removal system due to permitting requirements. Since the control 

efficiency ranges for both technologies are equivalent, there are currently no other PM 

controls more effective than current practices. 

Controls for SOx Emissions 

Potential opportunities to reduce SOx emissions from this source category were also 

researched. Most facilities subject to Rule 4352 currently inject limestone into the 

combustion chamber to react with fuel sulfur and produce various sulfate compounds, 

which can then be removed by the ESP or baghouse. This control technology typically 

achieves around 50% control of SOx emissions53; however, the emissions reduced are 

less for a low sulfuric fuel due to the lower concentration of sulfur dioxide (SO2) initially 

in the combustion products. 

Scrubbers are an add-on control technology that can achieve 70-95% control of SOx 

emissions for solid fuel fired boilers54. The only MSW facility in the Valley currently 

utilizes a semi-dry scrubber system to control SOx emissions. Therefore, the District 

calculated the average cost effectiveness of a scrubber system for biomass and 

coal/coke facilities. 

The District conducted a SOx BACT evaluation for a local power generation facility that 

was installing a biomass boiler and determined the capital costs for a wet scrubber 

 

50 Senior, C., Afonso, R. (January 2009). Applicability and Feasibility of NOx, SO2, and PM Emissions Control 

Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. Northeast States for Coordinated Air Use 

Management. 

51 Senior, C., Afonso, R. (January 2009). Applicability and Feasibility of NOx, SO2, and PM Emissions Control 

Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. Northeast States for Coordinated Air Use 

Management. 

52 Roberts, C. (2009). Information on Air Pollution Control Technology for Woody Biomass Boilers. Northeast States 

for Coordinated Air Use Management and the EPA Office of Air Quality Planning and Standards. 53 Alberta Research Council Inc. (2001). Technical Advice on Air Pollution Control Technologies for Coal-fired Power 

Plants. 54 Senior, C., Afonso, R. (January 2009). Applicability and Feasibility of NOx, SO2, and PM Emissions Control 

Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. Northeast States for Coordinated Air Use 

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

C-100 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

system are approximately $5.8 million. The annualized capital equipment cost is 

calculated by multiplying the installed equipment cost by the capital recovery factor of 

0.1627. 

Annual Capital Costs (ACcapital) 

ACcapital= $5,800,000 X 0.1627 

ACcapital= $943,660/year 

In addition, this system has additional costs for the sodium hydroxide reagent used in 

the scrubber which are estimated to be an additional $642,000 per year. Thus, the total 

annual cost would be: 

Total Annual Costs (ACtotal) 

ACtotal = Capital Costs + Reagent Costs = ($943,660/year) + ($642,000/year) 

ACtotal = $1,585,660/year 

Cost effectiveness is calculated by dividing the annual cost by the annual emissions 

reductions from District standard emissions. One cost effectiveness analysis was 

conducted for the biomass and coal/coke fired units in the Valley because the four 

coal/coke fired units are fired on biomass part of the time. 

The average SOx emissions limit of these units, based on District Permits SOx 

emissions limits, is 0.044 lb/MMBtu and the average heat input is 341 MMBtu/hr. An 

emissions factor of 0.27 lb/MMbtu at 24 hours per year is assumed to reflect the time 

needed for the startup and shutdown period, when the exhaust temperature is not high 

enough for controls to be fully effective. Therefore, those numbers were utilized to 

calculate annual standard emissions as follows: 

Annual Standard Emissions (AEstandard) 

AEstandard = [(0.044 lb/MMBtu) x (341 MMBtu/hour) x (8,760 hour/year)] + [(0.27 

lb/MMBtu) x (24 hour/year) x (341 MMBtu/hr)] 

AEstandard = 133,644.7 lb/year 

Potential emissions, using the technologically feasible emission limit of 0.012 lb/MMBtu 

that is achieved by the use of a wet scrubber system, can be calculated as follows: 

Annual Emissions with Wet Scrubber System (AEscrubber) 

AEscrubber = [(0.012 lb/MMBtu) x (341 MMBtu/hour) x (8,760 hour/year)] + [(0.27 

lb/MMBtu) x (24 hour/year) x (341 MMBtu/hour)] 

AEscrubber = 38,055.6 lb/year 

Therefore, the cost effectiveness would be: 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-101 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Cost Effectiveness (CE) 

CE= ($1,585,660/year) ÷ [(133,644.7 lb/year – 38,055.6 lb/year) x (1 ton/2,000 lb)] 

CE = $33,177/ton 

It is important to note that the cost effectiveness analysis above does not reflect the 

costs of additional electricity consumption, additional labor costs, additional solid waste 

disposal, and other operational changes or additions that would be required to comply 

with the lower limit. The option of scrubbers is not a cost effective option, and therefore, 

is not feasible. 

There are no additional technologies available to reduce SOx emissions from solid fuel 

fired units. 

Start-up Periods 

The possibility of reducing the allowed start-up period of solid fuel fired boilers was 

considered, since facilities are exempt from emissions limits during this period. 

Facilities subject to Rule 4352 are currently subject to a start-up limit of 96 

hours. Operators currently limit their start-up and shut-down times as much as possible 

since down time results in reduced productivity and profits. However, facilities 

periodically perform “cold repairs” on their solid fuel fired boilers for maintenance or 

trouble-shooting purposes. This requires operators to completely shut down the boilers, 

which in turn requires a longer start-up period to return to correct operating temperature. 

When the solid fuel fired boilers are starting up, the units are not operating with a full 

load which reduces emissions. Therefore, this is not a technologically feasible option 

for solid fuel fired facilities given the needs of current work practices. 

Evaluation Findings

Even though solid fuel fired boilers, steam generators, and process heaters are not a 

significant source of PM2.5, NOx, or SOx in the Valley, the District has evaluated all 

potential control technologies and all control technologies achieved in practice in other 

areas or included in other state implementation plans. As demonstrated above, Rule 

4352 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 this 

source category. As the District continues to develop new attainment plans that 

address more stringent National Ambient Air Quality Standards, the District will continue 

to evaluate potential opportunities to reduce emissions from solid fuel fired boilers, 

steam generators, and process heaters in the Valley. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-102 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.14 RULE 4354 GLASS MELTING FURNACES 

Discussion 

The provisions of Rule 4354 are applicable to glass melting furnaces in the Valley. The 

purpose of this rule is to limit NOx, SOx, volatile organic compounds (VOC), carbon 

monoxide (CO), and PM emissions from glass melting furnaces. 

Rule 4354 was adopted on September 14, 1994 and has been subsequently amended 

six times. Rule 4354 was amended September 16, 2010 to strengthen the NOx 

emission limits in the rule; EPA finalized approval for these amendments on August 29, 

2011. Rule 4354 was subsequently amended again in May 19, 2011 to implement 

updated start-up requirements; EPA finalized approval of the 2011 amendments to Rule 

4354 on January 31, 2013 and deemed this rule as being as stringent as, if not more 

stringent than, established RACT requirements. As a result of this stringent prohibitory 

rule and continuing efforts on behalf of this industry to reduce emissions, the Valley is 

home to glass-making facilities with glass melting furnaces that utilize the most advanced 

low-NOx firing technology. 

Source Category 

Industrial glass making is a continuous process with raw materials supplied to the 

furnace at the front end, and product taken off the line at the back end of the process. 

The raw materials for making glass are silica sand and soda ash. Melting these basic 

materials and forming them into the desired product geometry creates the final glass 

product. The different end products vary widely in raw material additives, processing 

equipment and conditions, and product quality requirements. The emission limits of 

Rule 4354 depend on the type of glass produced, furnace firing technology and the 

emission-averaging period. 

Rule 4354 is among the most stringent rules in the nation for glass melting furnaces. 

The NOx emission limits contained within Rule 4354 require the installation of the best 

available NOx technology (i.e. oxy-fuel firing or SCR systems).

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.33 0.34 0.35 0.36 0.38 0.39 0.39 0.40 0.40 

NOx 6.04 6.21 3.99 4.08 4.17 4.27 4.31 4.35 4.38 

SOx 1.96 2.00 1.83 1.87 1.90 1.93 1.95 1.96 1.98 

Winter Average - Tons per day 

PM2.5 0.33 0.34 0.35 0.36 0.38 0.39 0.39 0.40 0.40 

NOx 6.04 6.21 3.98 4.08 4.17 4.27 4.31 4.34 4.38 

SOx 1.96 2.00 1.83 1.87 1.90 1.93 1.95 1.96 1.98 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-103 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, PM2.5 and NOx emissions from glass melting furnaces are lower than 

the BACM/MSM significance thresholds. Therefore, the Clean Air Act does not require 

a control measure evaluation for this source category for the purpose of satisfying 

BACM/MSM requirements for PM2.5 and NOx; however, the District has still conducted 

a full control measure evaluation for glass melting furnaces. 

How does District Rule 4354 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG requirements for this source category. 

ACT 

 EPA-435/R-94-037 (Alternative Control Techniques Document—NOx Emissions 

from Glass Manufacturing)

The District evaluated the requirements contained within the above ACT and found no 

requirements that were more stringent than those already in Rule 4354. 

NSPS 

 40 CFR 60 Subpart CC (Standards of Performance for Glass Manufacturing Plants) 

The District evaluated the requirements contained within 40 CFR 60 Subpart CC and 

found no requirements that were more stringent than those already in Rule 4354. 

 40 CFR 60 Subpart PPP (Standards of Performance for Wool Fiberglass Insulation 

Manufacturing Plants) 

The District evaluated the requirements contained within 40 CFR 60 Subpart PPP and 

found no requirements that were more stringent than those already in Rule 4354. 

NESHAP/ MACT 

 40 CFR 61 Subpart N (National Emission Standard for Inorganic Arsenic Emissions 

from Glass Manufacturing Plants)

40 CFR 61 Subpart N was last amended February 27, 2014; however, this NESHAP 

only regulates inorganic arsenic emissions and therefore does not apply to this control 

measure evaluation. 

 40 CFR 63 Subpart NNN (National Emission Standards for Hazardous Air Pollutants 

for Wool Fiberglass Manufacturing Plants) 

The District evaluated the requirements contained within 40 CFR 63 Subpart NNN and 

found no requirements that were more stringent than those already in Rule 4354. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-104 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

 40 CFR 63 Subpart SSSSSS (National Emission Standards for Hazardous Air 

Pollutants for Glass Manufacturing Area Sources) 

The District evaluated the requirements contained within 40 CFR 63 Subpart SSSSSS 

and found no requirements that were more stringent than those already in Rule 4354. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 4354 compare to rules in other air districts? 

There are no analogous rules for this source category in VCAPCD and SMAQMD. 

SCAQMD 

 Rule 1117 (Emissions of Oxides of Nitrogen from Glass Melting Furnaces) 

The District evaluated the requirements contained within SCAQMD’s Rule 1117 and 

found no requirements that were more stringent than those already in Rule 4354. 

BAAQMD 

 BAAQMD Regulation 9 Rule 12 (Nitrogen Oxide Emissions from Glass Melting 

Furnaces)

 

The District evaluated the requirements contained within BAAQMD’s Regulation 9 Rule 

12 and found no requirements that were more stringent than those already in Rule 

4354. 

Additional Emission Reduction Opportunities 

SOx Limits for Container Plants 

The District evaluated the possibility of lowering the existing SOx limits for container 

plants from the current limits of 0.9 and 1.1 lbs of SOx per ton of glass, depending on 

cullet content, to the District BACT limit of 0.8 lbs/ton. The analysis below indicates that 

it is not technologically feasible to lower the SOx limits. 

The glass container industry is mandated by the State of California to use a minimum 

quantity of recycled glass (cullet) as part of the production process. The quantity of 

clear glass cullet available to glass manufacturers is very limited; therefore, cullet with a 

large portion of colored glass is included in each batch. The continued use of mixed 

color cullet is critically important to meeting California’s recycling goals. Due to the 

variable quality of mixed color cullet, SOx emissions produced by the melting of 

recycled cullet are also variable. 

Container glass manufacturers control multiple furnaces as a single unit, meaning that 

the exhaust from multiple furnaces are ducted together and the total emissions are 

averaged over the total amount of glass pulled from all furnaces. Because emissions 

are averaged across furnaces, EPA requires that there be a 10% air quality benefit, 

meaning that the overall limit for multiple furnaces be 10% less than the limit for a single 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-105 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

furnace. This imposes the lowest SOx emission limit on container glass furnaces, but 

allows operators to install one control device per facility rather than one add-on control 

device per furnace. SOx emissions limits for container glass were adopted at 1.1 

pounds per ton of glass produced if the operator uses at least 25% by weight of mixed 

color cullet and a limit of 0.9 pounds per ton of glass produced for all other container 

glass manufacturing. If the District were to lower the limits in the rule to 0.8 lbs/ton, then 

the 10% required air quality benefit for multiple furnaces extend beyond BACT, which is 

not feasible. The 0.8 lbs/ton BACT limit is equivalent to the 0.9 lbs/ton limit with the 

additional EPA required 10% air quality benefit. 

Evaluation Findings 

Even though glass melting furnaces are not a significant source of PM2.5 or NOx in the 

Valley, the District has evaluated all potential control technologies and all control 

technologies achieved in practice in other areas or included in other state 

implementation plans. As demonstrated above, Rule 4354 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 this source category. As the District 

continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from glass melting furnaces in the Valley. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-106 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.15 RULE 4550 CONSERVATION MANAGEMENT PRACTICES 

Discussion 

Rule 4550 is the District’s Conservation Management Practices (CMP) rule. Rule 4550 

was the first rule of its kind in the nation to reduce fugitive particulate emissions from 

agricultural operations through the reduction of passes of agricultural equipment and 

implementation of other conservation practices. Rule 4550 is unique because it is 

based upon a menu approach of control techniques to accommodate the variability of 

agricultural industries. The selected CMPs are listed on application forms that are 

submitted to the District for approval as a CMP Plan. Agricultural operations are 

required to maintain detailed records verifying use of the approved Conservation 

Management Practices. Approved CMP plans are enforced through onsite inspections 

and operators are required to submit applications and modify their plans when changing 

their conservation management practices. Through this rule, PM10 emissions have 

been reduced by 35.3 tons per day55, which is approximately a 24% reduction for this 

source category. 

The District worked extensively with stakeholders, growers, and the Agricultural 

Technical Committee for the San Joaquin Valley-wide Air Pollution Study Agency 

(AgTech) for two years prior to developing the Conservation Management Practices 

(CMP) Rule. Rule 4550 was adopted on August 19, 2004 to help bring the Valley into 

attainment of federal PM10 standards. Rule 4550 has served as a model for other 

regions seeking to reduce fugitive particulate emissions from agricultural sources. 

Upon adoption of Rule 4550, the District embarked on an ambitious implementation 

strategy, working extensively with agricultural stakeholders to ensure that affected 

sources were assisted as much as possible in complying with the requirements, and 

consequently ensuring that the CMP Program was successful. To this end, the District 

created special CMP application forms, which were designed to allow growers to select 

approved practices from simplified checklists. A special web page was created that 

contains answers to frequently asked questions, application forms, and other forms of 

assistance for agricultural operations. The District hired additional staff, including 

additional Small Business Assistance (SBA) staff, and took part in over 40 workshops 

throughout the Valley to assist sources in completing and submitting the required CMP 

application forms. The workshops were coordinated with agricultural stakeholders, and 

tremendous outreach was performed to ensure that as many affected sources as 

possible would attend and receive assistance at the workshops. As a result of these 

efforts, the District's CMP Program realized the following notable achievements: 

 Approximately 4,000 workshop participants, with many of the participants 

submitting CMP Plan applications during the workshops. 

 The District received and processed over 6,000 CMP Plan applications during 

2005. 

 

55 SJVAPCD. Conservation Management Practices Program Report for 2005. (2006, January 19). Retrieved from 

http://www.valleyair.org/farmpermits/updates/cmp_program_report_for_2005.pdf 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-107 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

 The practices used by valley agricultural sources encompass 3.2 million acres of 

farmland, and over 30,000 miles of unpaved roads. 

 The PM10 reductions are quantifiable and enforceable through approved CMP 

plans and inspections. 

 The collaborative effort responsible for the CMP program received US EPA 

Region IX's "2005 Environmental Award for Outstanding Achievement." 

The District also conducted an additional 60 workshops throughout the Valley over the 

last 10 years for the purpose of assisting sources comply with the CMP and other agrelated rules. 

EPA finalized approval of Rule 4550 on February 14, 2006 and determined that the rule 

met BACM requirements.56 Subsequent to EPA’s approval of Rule 4550, two separate 

lawsuits were filed challenging EPA’s approval of the rule as satisfying BACM. The 

Ninth District Court of Appeals, in both cases, agreed with EPA’s approval and 

reaffirmed EPA’s finding that Rule 4550 meets BACM requirements.

57,58 

Source Category 

This rule is applicable to on-field farming and agricultural operation sites located within 

the Valley. Rule 4550 limits fugitive dust emissions from farming operations by 

requiring CMP plans for farms with 100 acres or more, dairies with 500 or more mature 

cows, cattle feedlots with 190 or more cows, turkey ranches with 55,000 or more 

turkeys, chicken ranches with 125,000 or more chickens, and chicken egg ranches with 

82,000 or more laying hens. 

Rule 4550 specifies that agricultural operations must select at least one CMP from each 

of the identified applicable CMP categories. Animal feeding operation (AFO) sources 

subject to Rule 4550 that also grow field crops must select CMPs for their field crops, as 

well as their AFO. There are five CMP categories for the cropland source category, four 

CMP categories for the dairy source category, four CMP categories for the feedlot 

source category, and five CMP categories for the poultry source category. The selected 

CMPs must be noted on the applications provided and then submitted to the District for 

approval. Completed applications constitute a CMP Plan once approved by the District. 

Emissions from agricultural operations vary by many factors, some beyond the control 

of the agricultural operations. PM10 emissions are generated during land preparation 

activities, harvest activities, and post-harvest activities. Emissions are caused by the 

mechanical disturbance of the soil by implements and the tractors pulling them, 

 

56 71 Federal Register 30, 7683-7688. (2006, February 14). Revisions to the California State Implementation Plan; 

San Joaquin Valley Unified Air Pollution Control District. Retrieved from http://www.gpo.gov/fdsys/pkg/FR-2006-02-

14/pdf/06-1311.pdf 57 U.S. Court of Appeals for the Ninth Circuit. Latino Issues Forum v. EPA. Retrieved from 

http://njlaw.rutgers.edu/collections/resource.org/fed_reporter/NEWcircs/cir9/0671907_cir9.html 58 SJVAPCD. Court rules in favor of Air District ag rule. Second decision this week affirms PM progress. Retrieved 

from 

https://www.valleyair.org/recent_news/Media_releases/2009/PR%20Court%20decision%20favors%20District%20ag

%20rule.pdf 
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 2015 Plan for the 1997 PM2.5 Standard 

resulting in the entrainment of soil or plant materials into the air. Wind blowing across 

exposed agricultural land also causes the entrainment of PM10 into the air. In addition, 

PM10 emissions can also become entrained from vehicular travel over unpaved roads 

and unpaved parking/equipment areas. Conservation management practices fall into 

several broad categories and are intended to reduce emissions as follows: 

 The reduction of soil or manure disturbance; 

 Soil protection from wind erosion; 

 Equipment modifications to physically produce less PM10; and 

 Application of water or dust suppressants on unpaved roads and other travel 

areas to reduce emissions entrained by moving vehicles and equipment. 

Emissions Inventory 

There are no NOx or SOx emissions attributable to the sources subject to CMP 

requirements. The following emissions inventory table represents PM2.5 emissions 

only. 

 

Source 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day

Tilling Dust 5.17 5.14 5.12 5.09 5.07 5.04 5.02 5.00 4.97

Harvest Operations – Dust 7.28 7.25 7.23 7.20 7.18 7.15 7.12 7.10 7.07

Dust from Agricultural 

Lands (non-pasture) 6.15 6.12 6.08 6.05 6.02 5.99 5.96 5.93 5.90

Dust from Pasture Lands 1.09 1.09 1.08 1.08 1.08 1.07 1.07 1.06 1.06

Winter Average - Tons per day

Tilling Dust 7.37 7.33 7.29 7.25 7.21 7.18 7.14 7.10 7.06

Harvest Operations – Dust 0.31 0.31 0.30 0.30 0.30 0.29 0.29 0.29 0.29

Dust from Agricultural 

Lands (non-pasture) 4.36 4.33 4.30 4.28 4.25 4.23 4.20 4.17 4.15

Dust from Pasture Lands 0.23 0.23 0.23 0.23 0.23 0.23 0.22 0.22 0.22

As detailed in Chapter 5, the significance threshold for source categories for the 

purpose of evaluating the application of BACM and MSM requirements is 4.0 tons per 

day (tpd) for PM2.5 dust emissions. As identified in the above table, annual average 

emissions from pasture lands are lower than the BACM/MSM significance threshold. 

Therefore, the Clean Air Act does not require a control measure evaluation for that 

source category for the purpose of satisfying BACM/MSM requirements; however, the 

District has still conducted a full control measure evaluation for CMPs for all emission 

categories. 

Contribution of PM2.5 to PM10 Emissions from Agricultural Operations 

While Rule 4550 has been successful in reducing both PM10 and PM2.5 emissions, 

recent studies have indicated that the PM2.5 fraction of emissions makes up a small 

portion of the total particulate emissions from agricultural operations. Additionally, 

particulate emissions from agricultural operations are geologic in nature. These 

geologic particulate emissions make up a relatively small portion of the overall PM2.5 
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concentrations during the winter season and have relatively low toxicity relative to the 

organic carbon fraction of PM2.5 and to re-suspended road dust.59 

Accordingly, particulate emissions from agricultural sources do not play a significant role 

with regard to attainment of the PM2.5 standards addressed by this plan, and Rule 4550 

is primarily a PM10 reduction strategy. For example, 2004-2006 speciation analyses of 

PM2.5 from the Speciated Trends Network in Fresno and Bakersfield found that the 

annual average geologic fraction was 4% and 6%, respectively.60 Given that PM2.5 

emissions from agricultural field operations are generally subject to deposition near their 

source, the predominant source of this geologic PM2.5 would be urban re-suspended 

road dust with relatively little contribution from agricultural activities. 

PM2.5 emissions from agricultural field operations have been generally over-estimated 

in absolute terms due to species differences between the fine and coarse fractions of 

geologic emissions. Using Valley ambient measurements of trace elements, the 

PM2.5/PM10 ratios for the predominant trace elements found in fugitive dust have been 

estimated.61 The average ratio for aluminum and silicon was 0.05 and ranged between 

0.10 to 0.16 for calcium, titanium, and iron. Based on the relative abundances of these 

elements in fugitive dust, the overall PM2.5/PM10 ratio was estimated to be 0.06 (6%). 

This ratio estimate is substantially lower that the ratio of 0.20 reported previously for 

agricultural crops nationwide by MRI in 1996 based on limited supporting data and 

broad assumptions.62 Further review of Valley research on PM2.5/PM10 ratios shows a 

consistent mid-point estimate of 0.10.63 To summarize, PM2.5 comprises a small 

fraction of total PM10 emissions from field operations, approximately 10% in the Valley. 

Historically, both grid models and PM2.5 monitors used in field studies have significantly 

over-estimated overall PM2.5 emissions from agricultural field operations as well as 

their contribution to ambient PM2.5 concentrations. In respect to grid modeling biases, 

there is an expert consensus regarding the sources of grid model overestimation: (1) 

faulty emission factor algorithms, (2) imprecise or difficult to obtain activity data to apply 

these algorithms (including inability to account for the effect of actual meteorological 

conditions on emissions), (3) the multiplier used to infer PM2.5 from PM10 emissions, 

and (4) modeling transport over-estimation (especially in the treatment of particles near 

their point of emissions).64 

 

59 Rogge, W. F., Hildemann, L. M., Mazurek, M. A., Cass, G. R. and Simoneit, B. R. T. Sources of Fine Organic 

Aerosol—3. Road Dust, Tire Debris, and Organometallic Brake Lining Dust—Roads as Sources and Sinks. 

Environmental Science & Technology 27(9), 1892-1904. 1993. 

60 SJVAPCD. (2012). 2012 PM2.5 Plan. Retrieved from http://www.valleyair.org/Workshops/postings/2012/12-20-

12PM25/FinalVersion/04%20Chapter%204%20Sci%20Foundation%20and%20Modeling.pdf 61 Countess, R. Reconciling Fugitive Dust Emission Inventories with Ambient Measurements. 12th Annual EPA EI 

Mtg, San Diego, CA. April 29-May 1, 2003. 

62 Cowherd, C., and W. Kuykendal. (1996, June). Paper No. WP96.04, Proceedings of the Annual Meeting of the Air 

and Waste Management Association

63 Pace, T.G, EPA. (2005, April). Examination of the Multiplier Used to Estimate PM2.5 Fugitive Dust Emissions from 

PM10. Retrieved from http://www.epa.gov/ttn/chief/conference/ei14/session5/pace.pdf. 64 Pace, T.G, EPA. (2005). Methodology to Estimate the Transportable Fraction (TF) of Fugitive Dust Emissions for 

Regional and Urban Scale Air Quality Analyses. 
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In respect to over-estimation of PM2.5 transport, much of the ground level fugitive dust 

from soil disturbance is likely to be removed close to the source.65,66,67 This is due to 

the low release height and turbulence which keeps particles temporarily close to the 

surface where they are subject to removal by impaction on nearby surfaces, including 

vegetation and structures. Equally significant in respect to over-estimation of PM10 and 

PM2.5, grid models ignore all removal processes in the grid cell where the emissions 

originate. Given that 4 kilometers is a typical grid dimension, a considerable fraction of 

PM2.5 emitted under normal field operations could and often would be deposited within 

that cell. 

Wind-blown Dust in the Valley 

The Valley experiences wind-blown dust events from time to time typically during the 

spring and fall seasons when weather disturbances are most common. These events 

are less likely to occur during the long stagnation periods of the summer and winter. 

When soil conditions are dry, strong wind events often entrain coarse particulate matter 

into the atmosphere, carrying the pollution long distances across the Valley. This 

phenomenon has the potential to create higher concentrations of PM10 in its path of 

impact. 

Although these events primarily cause higher PM10 concentrations, there are rare 

instances where PM2.5 concentrations become elevated. In addition to the rarity of 

elevated PM2.5 concentrations, the PM2.5 values recorded during the strong stagnation 

periods of the winter season are usually much higher than those recorded during wind 

events. Because of this, the Valley’s PM2.5 design values are driven primarily by high 

winter-time concentrations, mostly due to organic carbon and the secondary formation 

of ammonium nitrate. Comparatively, the geologic component of the Valley’s peak 

PM2.5 concentrations is only a fraction of the mass formed through secondary 

processes and other sources. As a result, the wind events experienced in the Valley 

are not a significant contributor to the PM2.5 attainment challenges for the region, and 

placing further controls on this source would not make a substantial difference in the 

District’s PM2.5 design values. 

Continuous Evaluation of Potential CMPs 

The District evaluates the effectiveness of CMPs on a regular basis, as illustrated on the 

District’s web page under Requirements for Agricultural Operations.

68 Rule 4550 was 

adopted in August 2004, and during that same year the Ag CMP Handbook, the Poultry 

CMP Handbook, and a list of conservation management practices were posted to the 

same District site. In 2006, the District prepared and published a CMP Program Report 

 

65 Watson, J. G., J. Chow and contributors (2000, May). Reconciling Urban Fugitive Dust Emissions Inventory and 

Ambient Source Contribution Estimates. Desert Research Institute Report 6110.4F. Prepared for U.S. EPA. 

Retreieved from http://www.epa.gov/ttn/chief/efdocs/fugitivedust.pdf 66 Slinn, W. “Predictions for Particle Depositions to Vegetative Canopies”, Atmospheric Environment, 16: 1785-1794, 

1982. 

67 Etyemezian, V. et al., Desert Research Institute (2003, January) Field Testing and Evaluation of Dust Deposition 

and Removal Mechanisms – Final Report. Retrieved from 

http://www.westar.org/Docs/Dust/Transportable_Dust_Final_Report_DRI_WESTAR.pdf 68 SJVAPCD. Requirements for Agricultural Operations. http://www.valleyair.org/farmpermits/ 
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for 2005,69 in which the District provided an explanation of the key components of the 

CMP program and a detailed summary of the process of identifying and quantifying the 

emission reductions achieved through December 31, 2005. 

The District also posted a guidance document entitled, San Joaquin Valley Air Pollution 

Control District Approval of New Conservation Management Practices (CMPs),70 to the 

District web page in 2010. This document outlines procedures for the approval of new 

CMPs proposed by owners/operators to be used for compliance with the requirements 

of Rule 4550 conservation management practices. In addition, District Rule 4550 is 

brought up for discussion frequently in the AgTech Committee, which consists of 

various regulatory agencies, agricultural industry representatives, and university 

professors. The AgTech Committee has evaluated proposed CMPs for inclusion as part 

of the approved CMP list, including the promotion of conservation tillage at Valley farms, 

misting to reduce PM10 generated by disking, and almond harvesting techniques to 

reduce emissions. 

 Conservation Tillage/Combined Operations 

Conservation tillage includes types of tillage that reduce loss of soil and water in 

comparison to conventional tillage. Benefits include the reduction of passes and 

soil disturbance and soil improvements because it retains plant residue and 

increases organic matter. Examples of conservation tillage include converting to 

no or low till operations, implementing reduced till activities, adding soil/water 

amendments to improve resources, and reducing tillage needs. 

In the spring of 2008, EPA and USDA Agricultural Research Service (ARS) in 

collaboration with the District, NRCS, and other agencies/stakeholders performed 

a study of conservation tillage/combined operations and demonstrated significant 

PM emission reductions from this practice. EPA completed the final report in 

June 2013. This report, including the merits of conservation tillage/combined 

operations were discussed in great detail in the AgTech meetings and amongst 

industry stakeholders. It was determined that the conservation tillage/combined 

operations management practice is already included in nine out of the eleven 

crop categories with the other two crop categories consisting of a “nontillage/chemical tillage” option. Non-tillage requires no disturbance of soil and 

can achieve even more reductions than conservation tillage. In addition, Rule 

4550 already allows the option to select an “other” mitigation measure, which 

needs to be approved on a case by case basis. Since “conservation tillage” is 

already an approved conservation management practice, if an operator chose 

this for the “other” mitigation measure it would likely be approved. 

 

69 SJVAPCD. (2006, January 19). Conservation Management Practices Program Report for 2005. Retrieved 2/2/2015 

from http://www.valleyair.org/farmpermits/updates/cmp_program_report_for_2005.pdf. 70 SJVAPCD. (2010, December 14). San Joaquin Valley Air Pollution Control District Approval of New Conservation 

Management Practices (CMPs). Retrieved 2/2/2015 from 

http://www.valleyair.org/policies_per/Policies/SSP_3010.pdf. 
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 CSUF Foundation Report: MISTING: A Conservation Management Practice 

for Reducing PM10 Generated by Disking 

A study was performed between March 2008 and September 2011 to test if the 

addition of a Misting System Duct Control Unit manufactured by Diamond E. 

Manufacturing would reduce emissions from disking. The final report was 

published in December 2011. In January 2013, Diamond E. Manufacturing 

requested that the Diamond E. Manufacturing Dust Control Unit be added to the 

official CMP list. A District review of the report indicated that it did not provide 

sufficient information to demonstrate the minimum 10% reduction in PM10 

emissions and therefore, was not added to the official CMP list. If sufficient 

information demonstrating that the dust control unit achieves the minimum PM10 

reductions is provided in the future, this measure would be allowed to be 

selected under the existing CMP category: Cropland – Land 

Preparation/Cultivation, Equipment changes/Technological Improvements. 

 Harvesting Equipment to Reduce PM Emissions from Almond Harvest

Operations 

A study was performed in 2010 and 2011 by Texas A&M to evaluate a variety of 

improved almond harvesters and their ability to reduce PM emissions. A final 

report was published in January 2013, demonstrating that the newer harvesters 

achieved significant PM emissions compared to their predecessors. This specific 

measure was not added to the list of conservation practices because it was 

determined that using newer almond harvesters to reduce PM emissions would 

be allowed under the existing CMP Category: Cropland-Harvest, Equipment 

Changes/Technological Improvements. 

How does District Rule 4550 compare with federal and state rules and 

regulations? 

Federal requirements such as NSPS, NESHAP, MACT, CTGs, and ACTs and state 

regulations are not applicable to this source category. 

How does District Rule 4550 compare to rules in other air districts and states? 

The requirements and applicability of Rule 4550 were compared to analogous rules in 

other air districts and states to determine the stringency of Rule 4550 compared to 

those other rules. BAAQMD and VCAPCD do not have rules that are analogous to Rule 

4550. 

SMAQMD 

 Rule 215 (Agricultural Permit Requirements and New Agricultural Permit 

Review): District Rule 4550 is at least as stringent as if not more stringent than 

the analogous rule in SMAQMD. 

SCAQMD 

 SCAQMD has adopted agricultural best management practices (BMP) programs, 

which were approved by EPA as Best Available Control Measures (BACMs); 

however, the District’s CMP rule exceeds these standards. 
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Imperial County Air Pollution Control District (ICAPCD) 

 Rule 806 (Conservation Management Practices) 

Imperial County APCD (Imperial) first adopted their Regulation VIII rules in 2005 to 

implement requirements designed to reduce the amount of PM10 entrained in the 

ambient air as a result of emissions generated from anthropogenic fugitive dust 

sources. Rule 806 (Conservation Management Practices) is a part of this set of 

rules. EPA did not approve the Regulation VIII rules as amendments to the state 

implementation plan (SIP) in July 2010. After a public process and mediation 

between Imperial and EPA, on October 16, 2012, a revised rule was adopted with 

rule requirements effective on and after January 1, 2013. 

Imperial Rule 806 requires one conservation practice from each of three categories 

(land preparation and cultivation, harvesting, and cropland-other), but the rule also 

specifies that if the owner or operator of an Agricultural operation site chooses to 

implement conservation tillage as a conservation practice, then that owner/operator 

does not need to select any additional conservation practices. 

As stated earlier, the District’s CMP rule includes conservation tillage as a 

conservation management practice for nine out of the eleven crop categories, listed 

as an option under Land Preparation/Cultivation and/or under the Harvest section. 

The option to select conservation tillage is also available to all crops by program 

design because each of the three sections includes an “Other (approved on a caseby-case basis),” thus allowing conservation tillage to be chosen as a conservation 

practice by any owner/operator. District Rule 4550 is more stringent than Imperial 

Rule 806 where a Valley operator selects “conservation tillage” in one category, but 

still has to select two additional measures, resulting in even more emission 

reductions. Therefore, requirements in Rule 4550 are equivalent, if not more 

stringent than Imperial Rule 806. 

Arizona Department of Environmental Quality 

 The Arizona Department of Environmental Quality adopted agricultural BMP 

programs. 

The Arizona Agricultural Best Management Practices Committee was established in 

1998 by Arizona Revised Statutes (A.R.S) §49-457 to research and adopt BMPs for 

agricultural operations that generate dust. The BMPs are designed to reduce 

emissions of PM10 in the Maricopa County Serious PM10 nonattainment area. In 

2006, the Committee reconvened the Technical Workgroup to review the current use 

of BMPs in Maricopa County. 

The Arizona rule is not applicable to dairies, cattle feedlots, turkey ranches, chicken 

ranches, or chicken egg ranches. District Rule 4550 is more stringent than the 

Arizona rule for these categories. With regards to measures specific to agricultural 

crops, the measures offered as conservation practices in Arizona are similar to the 

conservation practices offered within District Rule 4550 and would likely yield similar 

amounts of emission reductions. 
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Evaluation Findings

EPA’s approval of Rule 4550 as BACM and the District’s review of similar rules in other 

regions demonstrate that the District has adopted the most stringent rule of its kind. 

Rule 4550 is more stringent than the Imperial rule and the Arizona rule, as both rules 

are not applicable to dairies, cattle feedlots, turkey ranches, broiler ranches, or layer 

hen ranches. With regards to measures specific to agricultural crops, the measures 

allowed as conservation practices in Imperial County and Arizona are similar to the 

conservation practices allowed under Rule 4550 and yield similar amounts of emission 

reductions. 

Given the relatively low contribution that emissions from this category make to the 

Valley’s PM2.5 concentrations and current stringent requirements under Rule 4550, the 

District has not identified any additional rule amendment opportunities for further 

emission reductions from source categories subject to CMP requirements to include in 

this plan. As demonstrated above, Rule 4550 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 this source category. 

Although Rule 4550 already meets BACM and MSM requirements, the District is 

committing to further evaluate Rule 4550 for additional opportunities. See Chapter 8 

(Commitment to Leave No Stone Unturned to Evaluate Additional Opportunities) for 

more information. 
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C.16 RULE 4692 COMMERCIAL CHARBROILING 

Discussion 

Rule 4692 applies to chain-driven charbroilers used to cook meat. The purpose of the 

rule is to limit volatile organic compound (VOC) and PM10 emissions from commercial 

charbroiling. The rule also specifies administrative, recordkeeping requirements, and 

test methods. 

The original rule, adopted in March 2002, reduced PM2.5 emissions from chain-driven 

charbroilers by 84%. The September 2009 rule amendment expanded rule applicability 

to more chain-driven charbroilers, reducing 25% of the remaining PM2.5 chain-driven 

charbroiler emissions. EPA finalized approval for Rule 4692 on November 3, 2011. 

The District evaluated Rule 4692 in its 2009 Reasonably Available Control Technology 

Demonstration for Ozone State Implementation Plans (2009 RACT SIP); however, EPA 

noted in its Technical Support Document (TSD) for the approval of Rule 4692 that the 

rule is not subject to RACT because it is not subject to CTG requirements and it does 

not regulate major sources. 

Source Category 

There are two types of commercial charbroilers: chain-driven and under-fired. A chaindriven charbroiler is a semi-enclosed broiler that moves food mechanically through the 

device on a grated grill to cook the food for a specific amount of time. An under-fired 

charbroiler has a metal "grid," a heavy-duty grill like that of a home barbecue, with gas 

burners, electric heating elements, or wood under the grid to cook the food. The smoke 

and vapors generated by cooking on either type of charbroiler contain water, VOCs, and 

PM. Larger particles and grease are typically captured by the grease filter of the 

ventilation hood over the charbroiler. The remaining VOCs and PM2.5 are exhausted 

outside the restaurant, unless a secondary control is installed. 

 

Currently, District Rule 4692 reduces emissions by requiring catalytic oxidizers for 

chain-driven charbroilers that meet rule applicability thresholds. Charbroiler exhaust is 

directed through the catalytic oxidizer with little loss of temperature. As hightemperature exhaust goes through the heated catalyst, PM and VOC are oxidized to 

carbon dioxide and water vapor. This chemical reaction releases energy that heats the 

catalyst and is transferred to a heat recovery system, so no additional fuel is needed for 

the unit. Controlling emissions from under-fired charbroilers has proven to be far more 

challenging. To date, no cost effective technologies have been demonstrated. 
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Emissions Inventory 

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 2.84 2.87 2.92 2.97 3.04 3.11 3.18 3.24 3.31 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Winter Average - Tons per day 

PM2.5 2.84 2.87 2.92 2.97 3.04 3.11 3.18 3.24 3.31 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

How does Rule 4692 compare with federal and state rules and regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. 

State Regulations 

There are no state regulations applicable to this source category. 

How does Rule 4692 compare to rules in other air districts? 

There are no analogous rules for this source category in SMAQMD. 

SCAQMD 

 Rule 1138 (Control of Emissions from Restaurant Operations) 

The District evaluated the requirements contained within SCAQMD’s Rule 1138 and 

found no requirements that were more stringent than those already in Rule 4692. 

BAAQMD 

 Regulation 6 Rule 2 (Commercial Cooking Equipment) 

BAAQMD Regulation 6 Rule 2 regulates both chain-driven and under-fired units. Newly 

installed under-fired units with more than 10 square feet of cooking area are required to 

limit emissions to 1 lb of PM10 per 1,000 lbs of cooked beef. Effective January 2013, 

the same emissions requirements also apply to pre-existing units. However, as the 

BAAQMD rule is implemented, a significant portion of under-fired charbroilers are below 

the applicability thresholds for grill size or amount of food cooked, and are thus exempt 

from rule requirements. In addition, BAAQMD has been unable to enforce this rule 

because no control technologies have been certified. 

The applicability thresholds for grill size in District Rule 4692 are lower than those in 

BAAQMD Regulation 6 Rule 2. Therefore, because BAAQMD Regulation 6 Rule 2 is 

not currently being enforced for under-fired charbroilers, District Rule 4692 is effectively 

more stringent. Additionally, the District committed in the 2012 PM2.5 Plan to amend 
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Rule 4692 in 2016 to expand applicability to include under-fired charbroilers. During the 

rule development process for this amendment, the District will examine all potential 

opportunities for further emission reductions. 

VCAPCD 

 Rule 74.25 (Restaurant Cooking Operations) 

The District evaluated the requirements contained within VCAPCD’s Rule 74.25 and 

found no requirements that were more stringent than those already in Rule 4692.

Additional Emission Reduction Opportunities 

Chain-Driven Charbroilers 

Rule 4692 requires emission controls for chain-driven charbroilers that cook 400 pounds 

of meat or more per week. In 2009, the amended rule was estimated to apply to about 

280 of the 427 chain-driven identified charbroilers of the Valley. This rule thus applies 

to about 65% of the units and a much greater percentage of the total emissions from 

chain-driven charbroilers since they are higher use. The applicability threshold for 

chain-driven charbroilers under Rule 4692 could be lowered to make smaller facilities 

subject to the rule. However, these currently-exempt chain-driven units are a very small 

portion of the total inventory for this category. Emissions reductions would be minimal 

and costly through this approach. Furthermore, the District’s applicability threshold is 

already lower than that of other air districts. 

Under-Fired Charbroilers 

Rule 4692 does not currently require emissions controls for under-fired charbroilers. 

Catalytic oxidizers are not effective for reducing emissions from under-fired charbroilers 

because the exhaust from these devices loses too much heat as it is directed to the 

control device, and the reactions at the catalyst cannot take place under this lower 

temperature. The following control strategies are more effective for under-fired 

charbroilers: 

 High efficiency particulate-arresting (HEPA) filtration systems: This system 

adds a HEPA filter to the appliance’s existing grease filters to effectively 

eliminate particulates down to about 0.3 microns in diameter. System 

maintenance is relatively easy to perform, but filters need to be regularly 

changed (perhaps weekly, depending on the amount of food cooked). 

 Electrostatic precipitators (ESPs): Exhaust particles become electrically 

charged as they pass through an electrically charged screen. These ionized 

particles are then collected by one of two oppositely-charged plates. ESP 

systems need filtration prior to the ESP itself to remove grease and larger 

particles from kitchen exhaust. These devices are cleaned daily with a clean-inplace system, and more thorough cleaning is required once or twice a year. 

Routine maintenance often requires hiring an outside company, since the ESP 

plates can weigh as much as 75 pounds. 
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 Wet scrubbers: A fine stream of water and detergent “washes” the particulates

from the kitchen exhaust. The particulate/water/detergent mix is then filtered; 

the filtered water/detergent mix is recycled through to clean more exhaust, and 

the particulate-laden wash water is discharged to the sewer system. In addition 

to the cost of the system itself, associated water/sewer usage costs and 

detergent costs can be high, although recent improvements in design are 

improving system efficiencies. 

 

These controls for under-fired charbroilers were unproven and extremely costly during 

the District’s 2009 amendment of Rule 4692. The costs of these under-fired charbroiler 

controls, as analyzed in 2009, ranged from $37,500 to $104,000, with a cost 

effectiveness of up to $58,200 per ton of PM2.5 reduced. However, the control 

technology for under-fired units has continued to develop over the past few years, in 

part through the District, SCAQMD, and EPA technology demonstration efforts. Since 

under-fired charbroilers are a larger part of the total commercial charbroiling inventory, 

and since these units are currently unregulated in the Valley, there is potential to 

achieve emissions reductions from under-fired charbroilers. 

In parallel with this plan, SCAQMD has also included a draft commitment in Chapter 4 

of their Draft 2012 AQMP to achieve a 1 tpd PM2.5 reduction from under-fired 

charbroilers, though the details of their approach are yet to be determined.71 SCAQMD 

would submit their approach into the SIP once technically feasible and cost effective 

options are confirmed. 

The District created and implemented a pilot program in 2009, the Charbroiler Incentive 

Program (ChIP), to provide grant funding to cover a significant portion of the cost of 

installing particulate control devices on under-fired charbroilers. However, there was no 

stakeholder interest in this program and no projects were funded under ChIP. The 

District released a Request for Qualifications (RFQ) for its Restaurant Charbroiler 

Technology Partnership (RCTP) in 2014 and received several applications that were 

approved to move forward with the contracting process. Multiple projects are still in the 

contracting phase and the District expects to begin demonstration of some of the above 

described control technologies by mid-2015. 

The District has also been tracking and involved with technology demonstration projects 

for under-fired charbroilers at other agencies, including testing of control technologies 

for under-fired charbroilers at University of California at Riverside’s Center for 

Environmental Research and Technology (CE-CERT). This program began in early 

2012 and several tests were completed in early 2014. Additional tests are ongoing. 

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

feasible control technologies will range from $40,000 to over $100,000, and monthly 

operation and maintenance costs will range from a few thousand dollars to tens of 

thousands of dollars. As such, it is yet to be seen whether any cost effective and 

 

71 SCAQMD. (2012). Draft 2012 AQMP. Retrieved from http://aqmd.gov/aqmp/2012aqmp/draft/Chapters/Ch4.pdf 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-119 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

technologically feasible control technologies will be identified and demonstrated in the 

next few years. However, as part of the 2016 rule amendment process, the District will 

examine all potential opportunities for further emissions reductions. 

Evaluation Findings

The District has evaluated all control technologies achieved in practice in other areas or 

included in other state implementation plans. As demonstrated above, Rule 4692 

currently has in place the most stringent measures feasible to implement in the Valley at 

this time and therefore meets or exceeds both BACM and MSM requirements for this 

source category. 

Rule 4692 achieves significant emissions reductions from chain-driven charbroilers; 

however, the rule does not require emissions controls for under-fired charbroilers. 

Analyses indicate that extending the applicability of the rule to include under-fired units 

could further reduce PM2.5 emissions by as much as 20% (0.4 tpd PM2.5) from the 

baseline inventory for under-fired charbroilers upon implementation in 2017, thus 

providing significant health benefits Valley-wide per the District’s Health Risk Reduction 

Strategy. Research and demonstration projects are underway to evaluate emission 

control technologies for under-fired charbroilers in support of this measure. As included 

in the 2012 PM2.5 Plan, the District will amend Rule 4692 in 2016 to add requirements 

for under-fired charbroilers, with an anticipated compliance date of 2017. The District 

will also consider development of a new incentive program to assist in the deployment 

of new technologies upon their development and commercial availability. 

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

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 2015 Plan for the 1997 PM2.5 Standard 

C.17 RULE 4702 INTERNAL COMBUSTION ENGINES 

Discussion 

Rule 4702 applies to any internal combustion (IC) engine rated at 25 brake horsepower 

(bhp) or greater. The purpose of this rule is to limit NOx, carbon monoxide (CO), 

volatile organic compounds (VOC), and SOx emissions from units subject to this rule. 

The District’s original IC engine rule, Rule 4701 (Internal Combustion Engines – Phase 

1), was adopted on May 21, 1992, superseded by Rule 4702, adopted on August 21, 

2003, and subsequently amended five times. The rule originally established NOx limits 

between 25-50 ppmv achieving 90-96% control for non-agricultural operations rich-burn 

engines and 65-75 ppmv achieving 85-90% control for non-agricultural operations leanburn engines. In its continuous effort to improve air quality in the Valley, the District has 

adopted numerous amendments to Rule 4702 that have resulted in significant 

reductions of NOx and PM emissions. 

Substantial emission reductions from agricultural IC engines have also been achieved 

through a combination of regulatory efforts and incentive actions. Rule 4702 has 

effectively reduced emissions from agricultural engines by 84% since the 2005 

amendments to the rule, with substantial investments being made by the affected 

sources to comply with the rule. The rule was further strengthened in August 2011 

when rule amendments implemented more stringent NOx limits as low as 11 ppmv for 

non-agricultural operations spark-ignited engines. Additional emission reductions are 

forthcoming under Rule 4702 as compliance dates for emission control requirements 

continue to approach over the coming years. 

Source Category 

An internal combustion engine is any engine that operates by burning its fuel inside the 

engine. Engines generate power by the combustion of an air/fuel mixture. The main 

types of engines are spark-ignited engines and compression-ignited (or diesel) engines. 

In the case of spark-ignited engines, a spark plug ignites the air/fuel mixture. Sparkignited engines come in several designs such as: two-stroke and four-stroke, rich-burn 

and lean-burn, turbocharged and naturally aspirated. Spark-ignited engines may use 

one or more fuels, such as natural gas, propane, butane, liquefied petroleum gas, oil 

field gas, digester gas, landfill gas, methanol, ethanol, and gasoline. 

Compression-ignited engines rely on heating of the inducted air during the compression 

stroke to ignite the injected diesel fuel. In addition to being classified into compressionignited and spark-ignited, IC engines can be further divided into two-stroke and fourstroke engines. Most diesel engines are four-stroke, while larger diesel engines often 

are two-stroke. Natural gas fired spark-ignited engines are usually four-stroke, but 

some operators prefer two-stroke engines for their applications. 

Engines are used by a variety of private businesses and public agencies throughout the 

Valley for a number of purposes, primarily for powering pumps, compressors, or 

electrical generators. Examples of businesses and industries that use engines include 

schools and universities, agriculture, oil and gas production and pipelines, petroleum 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-121 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

refining, manufacturing facilities, food processing, electrical power generation, landfill 

and waste water treatment facilities, and water districts. Many engines are limited or 

low use in nature, such as emergency standby engines that provide backup power 

when electric service is interrupted. 

Emissions Inventory 

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day

PM2.5 0.49 0.49 0.48 0.40 0.31 0.30 0.29 0.28 0.27

NOx 13.06 12.85 12.50 9.21 7.22 6.82 6.57 6.37 6.09

SOx 0.12 0.12 0.12 0.09 0.08 0.08 0.08 0.08 0.08

Winter Average - Tons per day 

PM2.5 0.36 0.36 0.35 0.30 0.24 0.23 0.23 0.22 0.21

NOx 9.44 9.29 9.03 6.82 5.51 5.24 5.07 4.93 4.72

SOx 0.10 0.10 0.09 0.08 0.07 0.07 0.07 0.07 0.07

As detailed in Chapter 5, the significance threshold for source categories for the 

purpose of evaluating the application of BACM and MSM requirements is 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from IC engines are lower than the BACM/MSM significance 

thresholds. Therefore, the Clean Air Act does not require a control measure evaluation 

for this source category for the purpose of satisfying BACM/MSM requirements; 

however, the District has still conducted a full control measure evaluation for IC 

engines. 

How does District Rule 4702 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA Control Technique Guidelines (CTG) requirements for this source 

category. Rule 4702 is at least as stringent as the following applicable federal 

regulations: 

ACT 

 EPA – 453/R-93-032 (Alternative Control Techniques Document – NOx Emissions 

from Stationary Reciprocating Internal Combustion Engines)

The District evaluated the requirements contained within the EPA – 453/R-93-032 ACT 

document and found no requirements that were more stringent than those already in 

Rule 4702. 

NSPS 

 40 CFR 60 Subpart IIII (Standards of Performance for Stationary Compression 

Ignition Internal Combustion Engines)
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-122 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

The District evaluated the requirements contained within 40 CFR 60 Subpart IIII and 

found no requirements that were more stringent than those already in Rule 4702. 

 40 CFR 60 Subpart JJJJ (Standards of Performance for Stationary Spark Ignition 

Internal Combustion Engines) 

The District evaluated the requirements contained within 40 CFR 60 Subpart JJJJ and 

found no requirements that were more stringent than those already in Rule 4702. 

NESHAP/ MACT 

 40 CFR 63 Subpart ZZZZ (NESHAP for Stationary Reciprocating Internal 

Combustion Engines) 

The District evaluated the requirements contained within 40 CFR 63 Subpart ZZZZ 

NESHAP and found no requirements that were more stringent than those already in 

Rule 4702. 

State Regulations 

The following state regulations apply to sources covered under Rule 4702: 

 17 CCR 93114 (ATCM to Reduce Particulate Emissions from Diesel-Fueled 

Engines—Standards for Nonvehicular Diesel Fuel)

 17 CCR 93115 (ATCM for Stationary Compression Ignition Engines)

The District implements the requirements of 17 CCR 93114 and 17 CCR 93115 through 

Rule 4702 and the District’s new source review permitting program (Rule 2201). 

How does District Rule 4702 compare to rules in other air districts? 

BAAQMD 

 Regulation 9 Rule 8 (Nitrogen Oxides and Carbon Monoxide from Stationary Internal 

Combustion Engines) 

The District evaluated the requirements contained within BAAQMD’s Regulation 9 Rule 

8 and found no requirements that were more stringent than those already in Rule 4702. 

SMAQMD 

 Rule 412 (Stationary Internal Combustion Engines Located at Major Stationary 

Sources of NOx)

The District evaluated the requirements contained within SMAQMD’s Rule 412 and 

found no requirements that were more stringent than those already in Rule 4702. 

VCAPCD 

 Rule 74.9 (Stationary Internal Combustion Engines)
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-123 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

The District evaluated the requirements contained within VCAPCD’s Rule 74.9 and 

found no requirements that were more stringent than those already in Rule 4702. 

SCAQMD 

 Rule 1110.2 (Emissions from Gaseous- and Liquid-Fueled Engines) 

 Rules 2000 – 2020 (RECLAIM program) 

South Coast Air Quality Management District (SCAQMD) regulates the emissions from 

IC engines through a combination of control measures. SCAQMD 1110.2 is directly 

applicable to IC engines and includes emissions limitations for various applications. 

SCAQMD’s RECLAIM program (Rules 2000 – 2020) allows most operators to purchase 

credits in lieu of instituting engine emissions controls otherwise required under 

SCAQMD 1110.2. Given these overlapping sets of requirements, Rule 4702 must be 

compared in context of both regulations. Additionally, many of the engine applications 

found in the San Joaquin Valley vary substantially from engine applications in 

SCAQMD; for example, engines used for agricultural irrigation pumping that exist in the 

Valley and are no longer found in SCAQMD. While not directly comparable, the 

following tables compare the emission limits between SCAQMD Rule 1110.2 and 

District Rule 4702. 

Table C-19 Comparison of District and SCAQMD NOx Emission Limits for NonAgricultural Operations (Non-AO) Spark-Ignited Waste Gas Engines 

Rated at >50 bhp (corrected to 15% oxygen on a dry basis) 

Engine Type District NOx Limit 

(ppmv) 

SCAQMD NOx 

Limit (ppmv) 

Waste Gas Fueled (Rich-Burn) 50 

Until 01-01-16 

bhp ≥ 500: 36 x ECF72

bhp < 500: 45 x ECF1

On and after 01-01-16 

11 ppmv 

Waste Gas Fueled (Lean-Burn) 65 ppmv or 90% 

reduction 

Until 01-01-16 

bhp ≥ 500: 36 x ECF1

bhp <500: 45 x ECF1

On and after 01-01-16 

11 ppmv 

 

72 The efficiency correction factor (ECF) is 1.0 unless: 1) The engine operator has measured the engine’s net specific 

energy consumption, in compliance with ASME Performance Test Code PTC 17 -1973, at the average load of the 

engine; and 2) the ECF-corrected emission limit is made a condition of the engine’s permit to operate. The ECF is 

never less than 1.0 so in some cases the SCAQMD limits could potentially be less stringent than the District’s NOx 

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

C-124 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Table C-20 Comparison of District and SCAQMD NOx Emission Limits for NonAO Spark-Ignited Engines Rated >50 bhp (corrected to 15% oxygen

on a dry basis) 

Engine Type District NOx Limit 

(ppmv) 

SCAQMD NOx 

Limit (ppmv) 

1. Rich-Burn 

Rich-Burn Engine (except for below 

special applications) 11 11 

Cyclic Loaded, Field Gas Fueled 50 11 

Limited Use 25 1173

2. Lean-Burn Engines 

Lean-Burn Engine (except for below 

special applications) 11 11 

Two-Stroke, Gaseous Fueled, >50 bhp 

and < 100 bhp 75 11 

Limited Use 65 112

Lean-Burn Engine used for gas 

compression 

65 ppmv or 93% 

reduction 11 

Table C-21 Comparison of District and SCAQMD NOx Emission Limits for 

Agricultural Operations (AO) Spark-Ignited Engines Rated >50 bhp 

(corrected to 15% oxygen on a dry basis) 

Engine Type District NOx Limit SCAQMD NOx Limit 

1. Rich-Burn 90 ppmv or 80% reduction 11 

2. Lean-Burn 150 ppmv or 70% reduction 11 

3. Certified and installed on or 

before June 16, 2005 

Meet a Certified Spark-Ignited 

Engine Standard of 

HC + NOx < 0.6 g/bhp-hr 

11 

 

Medium and large operators in the South Coast Air Basin are most likely part of the 

South Coast RECLAIM program and are subsequently not required to meet the engine 

emission limitations included in Rule 1110.2. All facilities that emit over a certain 

threshold are required to participate in the RECLAIM program. As part of the RECLAIM 

program certain companies receive emission allocations every year and each allocation 

is good for 12 months. The portion of the allocation not needed to offset the operator’s 

own emissions can be sold to other companies. If the operator does not receive an 

emission allocation, they must buy emission credits from operators with unused 

emission allocations. In this way, the RECLAIM program is similar to a cap-and-trade 

program. The District does not have a RECLAIM-type program for this source category 

and all operators are required to meet the stringent emission limitations included in Rule 

4702. 

 

73 SCAQMD exempt units that operate less than 500 hours from this limit; District defines “limited use” units as those 

operating less than 4,000 hours and only exempts engines operating less than 200 hours. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-125 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Although the SCAQMD emission level of 11 ppm has not yet been proven as 

technologically feasible in agricultural settings and it is unclear what percentage of 

facilities are complying with the current SCAQMD NOx limits for non-ag categories, the 

District evaluated the cost-effectiveness and feasibility of implementing an 11 ppmv 

NOx emission limit for the following categories of IC engines: 

 Non-Agricultural Operations (Non-AO) Waste Gas Engines 

 Non-AO Spark-Ignited Engines 

 Cyclic Loaded, Field Gas Fueled 

 Limited Use Engines 

o Lean-Burn Engines 

o Rich-Burn Engines 

 Two-Stroke, Gaseous Fueled Engines 50-100 bhp 

 Lean-Burn Engines Used for Gas Compression 

 Agricultural Operations (AO) Spark-Ignited Engines 

The District also evaluated the cost-effectiveness and feasibility of implementing 

intermediate NOx emission limits for AO spark-ignited engines that more closely match 

the current NOx emission limits for non-AO limited use rich-burn and lean-burn engines. 

The following analyses were conducted: 

 25 ppmv NOx emission limit for AO Rich-Burn Spark-Ignited Engines 

 65 ppmv NOx emission limit for AO Lean-Burn Spark-Ignited Engines 

To determine potential emissions reductions, the District used the following equations: 

 NOx = (BHP x HR x EF x LF) / (CF) 

Where: 

NOx = Current annual NOx emissions or potential annual NOx emissions 

in ton/year 

BHP = engine power 

HR = annual hours of operation 

EF = NOx emission factor 

LF = engine load factor 

CF = conversion factor from grams to pounds 

The estimated annual NOx emissions reduction was calculated using the following 

equation: 

Potential Emissions Reduction = current annual NOx emissions – potential NOx 

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

C-126 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

NOx Emission Limitation for Non-Agricultural Operations (Non-AO) Waste Gas 

Engines: 

The District analyzed the technological feasibility of lowering the NOx emission limit for 

waste gas engines and determined that due to the variability of waste gas, additional 

levels of NOx control on existing waste gas engines can pose significant technical and 

feasibility challenges. Waste gas includes landfill gas, which is generated at landfills, 

and digester gas, which is generated from anaerobic digestion. Both landfill and 

digester gas result from the decomposition of organic matter by microorganisms in the 

absence of oxygen. Unlike pipeline natural gas, the composition of waste gas is not 

consistent or guaranteed. The heating value and composition of the gas (e.g. methane 

and oxygen contents) will vary with the type of materials that enter the landfill or 

digester and can also fluctuate seasonally or even daily. Both landfill and digester 

gases contain impurities, such as siloxanes, sulfur compounds, and halides. Landfill 

gas also contains entrained particulate matter, and both landfill and digester gas may 

contain particulate that results from combustion of the impurities in the gas. The 

contaminants in waste gas can coat and/or poison catalysts, rendering them 

ineffective. Because of its variable composition and contaminants, untreated waste gas 

is not interchangeable with pipeline-quality natural gas and extensive and costly 

cleanup would be necessary to allow the use of catalytic emission controls needed to 

achieve 11 ppmv. This is not a practical option for most existing waste gas-fired 

engines, which were not designed to include the required gas systems and catalytic 

controls. 

In addition to the District’s efforts to identify additional potential technology options for 

this category, SCAQMD has also been evaluating this issue. In February 2008, 

SCAQMD amended Rule 1110.2 to include an 11 ppmv limit for waste gas engines 

rated at >50 bhp. The original compliance date for this emissions limit was July 1, 2012, 

with the assumption that SCAQMD would complete a Technology Assessment to verify 

the feasibility of available control technologies for waste gas engines. However, 

SCAQMD had to amend Rule 1110.2 in September 2012 to extend the compliance 

deadline for waste gas engines from 2012 to 2016 in order to allow for more time to 

complete their Final Technology Assessment, which is currently still incomplete and has 

yet to identify feasible technology options. Additionally, these sources may also be in a 

position to avoid installing additional NOx control technologies through their participation 

in SCAQMD’s RECLAIM program. 

District Rule 4702 contains the most stringent limits feasible for existing waste gasfueled engines based on the use of combustion processes that minimize emissions 

without the use of post-combustion catalytic controls. Therefore, Rule 4702 meets or 

exceeds BACM and MSM for non-AO waste gas fueled spark-ignited engines. 

Additionally, the District continues to investigate potential NOx and SOx control 

technologies for waste gas engines through its Technology Advancement Program, with 

projects currently approved for funding that will continue to demonstrate new 

technologies in this sector. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-127 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

NOx Emission Limitation for Non-AO Spark-Ignited Engines: 

Cyclic Loaded, Field Gas Fueled 

Cyclic-loaded, field gas fueled engines can achieve some level of control, but not the 

stringent level of control that can be imposed on engines that operate in a narrow and 

more stable range of loads. The exhaust gas temperature of cyclic loaded engines 

varies as a function of the engine load; however, catalyst chemistry is dependent on a 

minimum temperature to be effective in reducing emissions. When the cyclic load 

engine is operating in a particular engine load range, the exhaust gas temperature can 

reach the catalyst’s effective range and allow for emissions to be well-controlled; 

however, as the engine cycles out of this load range, the exhaust gas temperature 

becomes too low for effective emissions control. Since the exhaust temperature 

fluctuates frequently for this category of units, it is technologically infeasible to require a 

lower NOx limit for cyclic loaded field-gas fueled engines. The current emission limit for 

this category of engines meets or exceeds BACM and MSM for these sources. 

Limited Use Engines 

During the 2011 amendments to Rule 4702, the District created this category of engines 

based on the high costs and cost effectiveness associated with the installation of 

additional controls for these engines (> 4,000 hours of operation). As discussed in the 

staff report, the NOx emission reductions foregone from not lowering the existing NOx 

limits to 11 ppmv for limited use engines was insignificant (about 0.004 tons per day in 

2011).74 

However, since the evaluation was conducted in 2011, the District re-evaluated the cost 

effectiveness of lowering the NOx emission limits to 11 ppmv for limited use non-AO 

rich-burn and lean-burn engines. The costs in the analyses below were gathered from 

information in the District’s Permits database, IC engine manufacturers, and operators.

Limited Use Lean-Burn Engines 

When evaluating the ability to lower NOx emissions to 11 ppmv, an operator can either 

retrofit the existing lean-burn IC engine with a selective catalytic reduction (SCR) 

system or install a new lean-burn engine with an SCR system. In many cases, 

retrofitting an existing IC engine is technologically infeasible or may require substantial 

additional unanticipated costs (such as the incompatibility of an older engine with less 

sophisticated operating controls with additional control technology, additional 

labor/maintenance costs, etc.). However, for the purpose of evaluating all potential 

controls, the District has included both options in the below analysis. 

 

74 SJVAPCD. (2011, August 18). Adopt Revised Proposed Amendments to Rule 4702 (Internal Combustion Engines). 

Retrieved from 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2011/August/Agenda_Item_10_Aug_18_2011.

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

C-128 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Table C-22 Annual Costs for Retrofitting an Existing Limited Use Lean-Burn 

Engine and Installing a New Limited Use Lean-Burn Engine with SCR 

Item Assumptions/Methodology Cost 

Average Engine Power 

Rating 1100 brake horsepower (bhp) n/a 

Annual Operation 2500 hours (hr) n/a 

Capital Costs

New Engine Cost (without 

SCR) 

Includes: engine, freight, installation, start-up, 

additional equipment (belt guards, fuel connection, 

etc.), and tax 

$110,656 

Annualized Engine Capital 

Costs (10 years, 10%) 0.163 x New Engine Cost $18,037 

SCR Equipment Costs

SCR System $73,000 per engine $73,000 

550 gallon double wall 

plastic urea tank and 

accessories 

$5,270 per tank $5,270 

3 hp rotary screw air 

compressor with dryer and 

receiver tank 

$5,875 per compressor package $5,875 

Total SCR Equipment Costs Equipment costs x 20% profit/mark-up $100,974 

SCR Installation Costs

Start-up and Commissioning 

Rate $1,500/day; assume 1 day for each system $1,500 

Electrical upgrade to power 

compressor n/a $0 

Total SCR Installation Costs $1,500 

Total SCR Capital Costs SCR Equipment Costs + SCR Installation Costs $102,474 

Annualized SCR Capital 

Costs (10 years, 10%) 0.163 x Total SCR Capital Costs $16,703 

Annual Operating and Maintenance Costs

Annual Reagent (urea) Cost $3 per gallon; 1 gallon/hr 

Cost = $3 x 2500 hr $7,500 

Annual Increase in Fuel 

Cost (due to drop in fuel 

efficiency with SCR) 

Fuel usage = 9,322.5 standard cubic feet per hour 

(scf/hr) 

Fuel cost (per 1,000 scf) = $7.36 

Fuel cost (per hour) = (9,322.5 x $7.36) / 1000 

Fuel cost (per year) = hourly cost x 2500 hr 

2.5% drop in fuel efficiency 

Added Fuel Cost = Annual fuel cost x 2.5% 

$4,288 

Annual Electricity Cost (for 

compressor) 

3 hp compressor = 2.24 kW power rating 

Electricity rate for industrial operations = $0.132/kWhr 

Hourly electricity cost = 2.24 kW x $0.132/kW-hr 

Daily meter charge = $49.281 

Annual electricity cost = hourly cost x 2500 hr 

Annual meter charge = daily meter charge x 365 

days 

Total utility cost = Annual electricity cost + Annual 

meter charge 

$18,728 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-129 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Item Assumptions/Methodology Cost 

Annual Catalyst Cost Life of catalyst = 5 years 

Cost per catalyst = $5,000 

Catalyst costs for 10 years = $5,000 x 2 

Annualized cost = $10,000 x 0.163 

$1,630 

Annual Maintenance Cost Maintenance = $0.02 per bhp per hour of operation 

Annual cost = $0.02 x 1,100 bhp x 2500 hr $55,000 

Annual Operating & 

Maintenance (O&M) Costs 

Annual O&M = Annual Reagent Cost+ Annual 

Increase in Fuel Cost + Annual Electricity Cost + 

Annual Catalyst Cost + Annual Maintenance Cost 

$87,147 

Annual Cost for Retrofit of 

LB Engine with SCR 

Annualized SCR Capital Cost + Annual O&M Cost $103,850 

Annual Cost for New LB 

Engine with SCR 

Annualized Engine Capital Cost + Annualized SCR 

Capital Cost + Annual O&M Cost $121,887 

The emissions reductions are calculated below: 

BHP = 1,100 bhp 

HR = 2,500 hours/year (hr/yr) 

EF1 = 0.78 g-NOx/bhp-hr (equivalent to 65 ppmvd NOx at 15% O2; 

assuming 35% thermal efficiency) 

EF2 = 0.132 g-NOx/bhp-hr (equivalent to 11 ppmvd NOx at 15% O2;

assuming 35% thermal efficiency) 

LF = 0.8 

CF = 453.6 grams/pound (g/lb) 

Current NOx = (BHP x HR x EF1 x LF) / (CF) 

 = (1,100 bhp x 2500 hr/yr x 0.78 g-NOx/bhp-hr x 0.8) / (453.6 g/lb) 

 = 3,783 lb-NOx/year 

Potential NOx = (BHP x HR x EF2 x LF) / (CF) 

 = (1,100 bhp x 2500 hr/yr x 0.132 g-NOx/bhp-hr x 0.8) / (453.6 g/lb) 

 = 640 lb-NOx/year 

Potential Emissions Reduction = Current NOx – Potential NOx 

Potential Emissions Reduction = (3,783-640 lb) x (1 ton / 2,000 lb) 

Potential Emissions Reduction = 1.57 tons/year 

Cost Effectiveness 

The cost effectiveness is the added cost, in dollars per year, of the control technology, 

divided by the emissions reductions achieved, in tons per year. Based on the 

calculations above, the cost effectiveness of retrofitting or replacing current limited use 

lean-burn spark-ignited engines is as follows: 

 Retrofitted limited use lean-burn engine with SCR: $66,086/ton of NOx 

reduced 

 New limited use lean-burn engine with SCR: $77,564/ton of NOx reduced 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-130 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

As demonstrated in the analysis and summary above, it is not cost effective to require 

the retrofit or replacement of limited use lean-burn engines to achieve 11 ppmv. 

Limited Use Rich-Burn Engines 

When evaluating the ability to lower NOx emissions to 11 ppmv, an operator will 

generally retrofit the existing rich-burn IC engine with a nonselective catalytic reduction 

(NSCR) system. In many cases, retrofitting an existing IC engine is technologically 

infeasible or may require substantial additional unanticipated costs (such as the 

incompatibility of an older engine with less sophisticated operating controls with 

additional control technology, additional labor/maintenance costs, etc.). However, for 

the purpose of evaluating potential controls in this category, the District has included the 

less costly, potentially feasible scenario of retrofitting an existing rich-burn engine with 

NSCR in the below analysis. 

Table C-23 Annual Costs for Retrofitting an Existing Limited Use Rich-Burn 

Engine 

Item Assumptions/Methodology Cost 

Average Engine Power 

Rating 500 bhp n/a 

Annual Operation 2500 hours (hr) n/a 

Capital Costs 

New Catalyst System Includes: catalyst, air-to fuel ratio controller, ignition 

system, and installation $75,000

Annualized Catalyst 

Capital Cost (10 years, 

10%) 

0.163 x New Catalyst System $12,225 

Annual Cost for Retrofit of 

RB Engine with New 

Catalyst 

Annualized Catalyst Capital Cost $12,225 

The emissions reductions are calculated below: 

BHP = 500 bhp 

HR = 2,500 hours/year (hr/yr) 

EF1 = 0.30 g-NOx/bhp-hr (equivalent to 25 ppmvd NOx at 15% O2; 

assuming 35% thermal efficiency) 

EF2 = 0.132 g-NOx/bhp-hr (equivalent to 11 ppmvd NOx at 15% O2;

assuming 35% thermal efficiency) 

LF = 0.8 

CF = 453.6 grams/pound (g/lb) 

Current NOx = (BHP x HR x EF1 x LF) / (CF) 

 = (500 bhp x 2500 hr/yr x 0.30 g-NOx/bhp-hr x 0.8) / (453.6 g/lb) 

 = 661 lb-NOx/year 

Potential NOx = (BHP x HR x EF2 x LF) / (CF) 

 = (500 bhp x 2500 hr/yr x 0.132 g-NOx/bhp-hr x 0.8) / (453.6 g/lb) 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-131 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

 = 291 lb-NOx/year 

Potential Emissions Reduction = Current NOx – Potential NOx 

Potential Emissions Reduction = (661 - 291 lb) x (1 ton / 2,000 lb) 

Potential Emissions Reduction = 0.19 tons/year

Cost Effectiveness 

The cost effectiveness is the added cost, in dollars per year, of the control technology, 

divided by the emissions reductions achieved, in tons per year. Based on the 

calculations above, the cost effectiveness of retrofitting or replacing current limited use 

rich-burn spark-ignited engines is as follows: 

 Retrofitted limited use rich-burn non-AO engine with new catalyst: 

$66,015/ton of NOx reduced 

As demonstrated in the analysis and summary above, it is not cost effective to require 

the retrofit or replacement of limited use rich-burn engines to achieve 11 ppmv, even 

without including additional substantial costs, such as annual operating and 

maintenance costs. 

Two-Stroke, Gaseous Fueled Engines 50-100 bhp 

There is no control technology compatible with two-stroke, gaseous fueled engines, 

including SCR, which will allow these units to achieve a NOx emission limit below 75 

ppmv. An 11 ppmv NOx emission limit is not technologically feasible for these engines; 

the current limit implements BACM and MSM for two-stroke, gaseous fueled engines 

less than 100 bhp. 

Lean-Burn Engines Used in Gas Compression 

Similar to the “Limited Use” engine category, during the 2011 amendments to Rule 

4702, the District created this category of engines based on the technological 

infeasibility to control these types of engines. Lean-burn engines used in gas 

compression in the Valley are used in natural gas distribution and storage service, and 

these engines frequently experience changing load conditions. As noted in EPA’s 

Stationary IC Engine Technical Support Document75, SCR use is problematic for these 

engines due to the fluctuations over a broad range of conditions. For this reason, EPA 

states that there is an insufficient basis to conclude that SCR is an appropriate 

technology for large lean-burn engines used for gas compression. The current emission 

limit is achievable through low-NOx combustion technology, which includes changes to 

the engine’s timing, enhanced control of the air-fuel ratio, and other changes that lower 

NOx emissions. Due to the technological complexities associated with lean-burn 

engines used in gas compression, the current emissions limit implements BACM and 

MSM for these units. 

 

75 EPA. (2003, October). Stationary Reciprocating Internal Combustion Engines Technical Support Document for 

NOx SIP Call. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-132 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

NOx Emission Limitation for AO Spark-Ignited Engines: 

Potential methods for reducing NOx emissions from Agriculture Operation (AO) sparkignited engines include retrofitting them with emission control technologies or replacing 

them. As the below analysis demonstrates, given the high costs and limited seasonal 

nature of operation of AO spark-ignited engines, requiring additional controls beyond 

the existing stringent requirements is not cost-effective and often technologically 

infeasible. Despite the technological feasibility issues associated with retrofitting or 

replacing existing AO spark-ignited engines, the District evaluated the cost 

effectiveness and feasibility of achieving an 11 ppmv NOx emission limit for the 

following scenarios: 

 Installing a new IC lean-burn engine with SCR as a replacement for an existing 

unit 

 Retrofitting an existing lean-burn IC engine with SCR 

 Installing a new rich-burn engine with a three-way catalyst system as a 

replacement for an existing unit 

The District also evaluated the cost effectiveness and feasibility of achieving 

intermediate NOx emission limits of 25 ppmv for AO rich-burn spark-ignited engines and 

a 65 ppmv for lean-burn spark-ignited engines, similar to the corresponding limited use 

engine limits for non-AO engines. The scenarios evaluated include: 

 Installing a new IC lean-burn engine as a replacement for an existing unit to meet 

65 ppmv 

 Installing a new rich-burn engine with a three-way catalyst system as a 

replacement for an existing unit to meet 25 ppmv 

The costs in the analyses below were gathered from information in the District’s Permits 

database, IC engine manufacturers, and agricultural industry representatives. 

AO Lean-Burn Engines (11 ppmv) 

When evaluating the ability to lower NOx emissions to 11 ppmv, an agricultural operator 

can either retrofit the existing lean-burn IC engine with a selective catalytic reduction 

(SCR) system or install a new lean-burn engine with an SCR system. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-133 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Table C-24 Annual Costs for Retrofitting an Existing AO Lean-Burn Engine with 

SCR and Installing a New AO Lean-Burn Engine with SCR 

Item Assumptions/Methodology Cost 

Average Engine Power 

Rating 241 brake horsepower (bhp) n/a 

Annual Operation 2500 hours (hr) n/a 

Capital Costs (Engine)

New Engine Cost (without 

SCR) 

Includes: engine, freight, installation, start-up, 

additional equipment (belt guards, fuel connection, 

etc.), and tax 

$109,480 

Annualized Engine 

Capital Costs (10 years, 

10%) 

0.163 x New Engine Cost $17,845 

SCR Equipment Costs 

SCR System $73,000 per engine $73,000 

550 gallon double wall 

plastic urea tank and 

accessories 

$5,270 per tank $5,270 

3 hp rotary screw air 

compressor with dryer and 

receiver tank 

$5,875 per compressor package $5,875 

Total SCR Equipment Costs Equipment costs x 20% profit/mark-up $100,974 

SCR Installation Costs

Start-up and 

Commissioning Rate $1,500/day; assume 1 day for each system $1,500 

Electrical upgrade to power 

compressor $43.22/foot; avg. 1,020 feet to extend electrical line $44,084 

Total SCR Installation Costs $45,584 

Total SCR Capital Costs SCR Equipment Costs + SCR Installation Costs $146,558 

Annualized SCR Capital 

Costs (10 years, 10%) 0.163 x Total SCR Capital Costs $23,889 

Annual Operating and Maintenance Costs (SCR)

Annual Reagent (urea) Cost $3 per gallon; 1 gallon/hr 

Cost = $3 x 2500 hr $7,500 

Annual Increase in Fuel 

Cost (due to drop in fuel 

efficiency with SCR) 

Fuel usage = 1750.7 standard cubic feet per hour 

(scf/hr) 

Fuel cost (per 1,000 scf) = $7.36 

Fuel cost (per hour) = (1,750.7 x $7.36) / 1000 

Fuel cost (per year) = hourly cost x 2500 hr 

2.5% drop in fuel efficiency 

Added Fuel Cost = Annual fuel cost x 2.5% 

$805 

Annual Electricity Cost (for 

compressor) 

3 hp compressor = 2.24 kW power rating 

Electricity rate for AO = $0.136/kW-hr 

Hourly electricity cost = 2.24 kW x $0.136/kW-hr 

Annual electricity cost = hourly cost x 2500 hr 

$761 

Annual Catalyst Cost Life of catalyst = 5 years 

Cost per catalyst = $5,000 

Catalyst costs for 10 years = $5,000 x 2 

Annualized cost = $10,000 x 0.163 

$1,630 

Annual Maintenance Cost Maintenance = $0.02 per bhp per hour of operation 

Annual cost = $0.02 x 241 bhp x 2500 hr $12,050 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-134 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Item Assumptions/Methodology Cost 

Annual Operating & 

Maintenance (O&M) Costs 

Annual O&M = Annual Reagent Cost+ Annual 

Increased Fuel Cost + Annual Electricity Cost + 

Annual Catalyst Cost + Annual Maintenance Cost 

$22,746 

Annual Cost for Retrofit 

of LB Engine with SCR 

Annualized SCR Capital Cost + Annual O&M Cost $46,635 

Annual Cost for New LB 

Engine with SCR 

Annualized Engine Capital Cost + Annualized SCR 

Capital Cost + Annual O&M Cost $64,480 

*The values within this table are rounded. 

The emissions reductions are calculated below: 

BHP = 241 bhp 

HR = 2,500 hours/year (hr/yr) 

EF1 = 2.092 g-NOx/bhp-hr (equivalent to 150 ppmv) 

EF2 = 0.132 g-NOx/bhp-hr (equivalent to 11 ppmv) 

LF = 0.65 

CF = 453.6 grams/pound (g/lb) 

Current NOx = (BHP x HR x EF1 x LF) / (CF) 

 = (241 bhp x 2500 hr/yr x 2.092 g-NOx/bhp-hr x 0.65) / (453.6 g/lb) 

 = 1,806 lb-NOx/year 

Potential NOx = (BHP x HR x EF2 x LF) / (CF) 

 = (241 bhp x 2500 hr/yr x 0.132 g-NOx/bhp-hr x 0.65) / 453.6 

 = 114 lb-NOx/year 

Potential Emissions Reduction = Current NOx – Potential NOx 

Potential Emissions Reduction = (1806-114 lb) x (1 ton / 2,000 lb) 

Potential Emissions Reduction = 0.85 tons/year 

Cost Effectiveness (AO Lean-Burn, 11 ppmv) 

The cost effectiveness is the added cost, in dollars per year, of the control technology, 

divided by the emissions reductions achieved, in tons per year. Based on the 

calculations above, the cost effectiveness of retrofitting or replacing current AO leanburn spark-ignited engines is as follows: 

 Retrofitted lean-burn engine with SCR: $55,118/ton of NOx reduced 

 New lean-burn engine with SCR: $76,209/ton of NOx reduced 

In addition to the unique feasibility issues that AOs face with regards to the installation 

and maintenance of IC engines (see below), the cost effectiveness values above 

demonstrate that it is not cost effective to retrofit or replace existing AO lean-burn 

engines with new more controlled engines. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-135 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

AO Lean-Burn Engines (65 ppmv) 

When evaluating the ability to lower NOx emissions to 65 ppmv, an agricultural operator 

would have to replace the existing lean-burn IC engine with a new lean-burn engine 

certified to meet 65 ppmv. 

Table C-25 Annual Costs for Installing a New AO Lean-Burn Engine 

Item Assumptions/Methodology Cost 

Average Engine Power 

Rating 241 brake horsepower (bhp) n/a 

Annual Operation 2500 hours (hr) n/a 

Capital Costs (Engine)

New Engine Cost (without 

SCR) 

Includes: engine, freight, installation, start-up, 

additional equipment (belt guards, fuel connection, 

etc.), and tax 

$109,480 

Annualized Engine 

Capital Costs (10 years, 

10%) 

0.163 x New Engine Cost $17,845 

Annual Operating and Maintenance Costs 

Annual Maintenance Cost Maintenance = $0.01 per bhp per hour of operation 

Annual cost = $0.01 x 241 bhp x 2500 hr $6,025 

Annual Cost for New LB 

Engine 

Annualized Engine Capital Cost + Annual O&M 

Cost $23,870 

*The values within this table are rounded. 

The emissions reductions are calculated below: 

BHP = 241 bhp 

HR = 2,500 hours/year (hr/yr) 

EF1 = 2.092 g-NOx/bhp-hr (equivalent to 150 ppmv) 

EF2 = 0.78 g-NOx/bhp-hr (equivalent to 65 ppmv) 

LF = 0.65 

CF = 453.6 grams/pound (g/lb) 

Current NOx = (BHP x HR x EF1 x LF) / (CF) 

 = (241 bhp x 2500 hr/yr x 2.092 g-NOx/bhp-hr x 0.65) / (453.6 g/lb) 

 = 1,806 lb-NOx/year 

Potential NOx = (BHP x HR x EF2 x LF) / (CF) 

 = (241 bhp x 2500 hr/yr x 0.78 g-NOx/bhp-hr x 0.65) / 453.6 

 = 673 lb-NOx/year 

Potential Emissions Reduction = Current NOx – Potential NOx 

Potential Emissions Reduction = (1806-673 lb) x (1 ton / 2,000 lb) 

Potential Emissions Reduction = 0.57 tons/year 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-136 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Cost Effectiveness (AO Lean-Burn, 65 ppmv) 

The cost effectiveness is the added cost, in dollars per year, of the control technology, 

divided by the emissions reductions achieved, in tons per year. Based on the 

calculations above, the cost effectiveness of replacing current AO lean-burn sparkignited engines is as follows: 

 New lean-burn engine: $42,146/ton of NOx reduced 

In addition to the unique feasibility issues that AOs face with regards to the installation 

and maintenance of IC engines (see below), the cost effectiveness value above 

demonstrates that it is not cost effective to replace existing AO lean-burn engines with 

newer less polluting engines. 

AO Rich-Burn Engines (11 ppmv) 

When evaluating the ability to lower NOx emissions to 11 ppmv, an agricultural operator 

can install a new rich-burn engine with 3-way catalyst. 

Table C-26 Annual Cost for Installing a New AO Rich-Burn Engine with a 3-way 

Catalyst 

Item Assumptions/Methodology Cost 

Average Engine Power 

Rating 256 bhp n/a 

Annual Operation 2500 hr n/a 

Total Capital Costs 

New Engine Cost Includes: engine with 3-way catalyst, freight,

installation, and tax $95,000 

Annualized Engine 

Capital Costs (10 years, 

10%) 

0.163 x New Engine Cost $15,485 

Annual Operating and Maintenance Costs (SCR)

Annual Added Fuel Cost 

(due to drop in fuel 

efficiency with catalyst) 

Fuel usage = 1,859.7 scf/hr 

Fuel cost (per 1,000 scf) = $7.36 

Fuel cost (per hour) = (1,859.7 x $7.36) / 1000 

Fuel cost (per year) = hourly cost x 2500 hr 

Assume 2.5% drop in fuel efficiency 

Added Fuel cost = Annual fuel cost x 2.5% 

$855 

Annual Catalyst Cost Life of catalyst = 5 years 

Cost per catalyst = $5,000 

Catalyst costs for 10 years = $5,000 x 2 

Annualized Catalyst Cost = $10,000 x 0.163 

$1,630 

Annual Maintenance Cost Maintenance = $0.02 per bhp per hour of operation 

Annual Maintenance Cost = $0.02 x 256 bhp x 

2500 hr 

$12,800 

Annual Operating & 

Maintenance (O&M) 

Costs

Annual O&M = Annual Added Fuel Cost + Annual 

Catalyst Cost + Annual Maintenance Cost $15,285

Annual Cost for New 

RB Engine with 3-way

Annualized Engine Capital Cost + Annual O&M 

Cost $30,770
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-137 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

*The values within the above table are rounded. 

The emissions reductions are calculated below: 

BHP = 256 bhp 

HR = 2,500 hours/year 

EF1 = 1.255 g-NOx/bhp-hr (equivalent to 90 ppmv) 

EF2 = 0.132 g-NOx/bhp-hr (equivalent to 11 ppmv) 

LF = 0.65 

CF = 453.6 grams/pound 

Current NOx = (BHP x HR x EF1 x LF) / (CF) 

 = (256 bhp x 2500 hr/yr x 1.255 g-NOx/bhp-hr x 0.65) / 453.6 

 = 1,151 lb-NOx/year 

Potential NOx = (BHP x HR x EF2 x LF) / (CF) 

 = (256 bhp x 2500 hr/yr x 0.132 g-NOx/bhp-hr x 0.65) / 453.6 

 = 121 lb-NOx/year 

Potential Emissions Reduction = Current NOx – Potential NOx 

Potential Emissions Reduction = (1,151-121 lb) x (1 ton / 2,000 lb) 

Potential Emissions Reduction = 0.52 tons/year 

Cost Effectiveness (AO Rich-Burn, 11 ppmv) 

The cost effectiveness is the added cost, in dollars per year, of the control technology, 

divided by the emissions reductions achieved, in tons per year. Based on the 

calculations above, the cost effectiveness of replacing current AO rich-burn engines is 

as follows: 

 New rich-burn engine with a 3-way catalyst to meet 11 ppmv: $59,754/ton of 

NOx reduced 

In addition to the unique feasibility issues that AOs face with regards to the installation 

and maintenance of IC engines (see below), the cost effectiveness value above 

demonstrates that it is not cost effective to replace existing AO spark-ignited engines 

with new controlled engines. 

AO Rich-Burn Engines (25 ppmv) 

In order to meet a 25 ppmv, an agricultural operator would have to install a new richburn engine with a slightly less expensive catalyst compared to the catalyst needed to 

meet 11 ppmv. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-138 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Table C-27 Annual Cost for Installing a New AO Rich-Burn Engine with a 3-way 

Catalyst 

Item Assumptions/Methodology Cost 

Average Engine Power 

Rating 256 bhp n/a 

Annual Operation 2500 hr n/a 

Total Capital Costs 

New Engine Cost Includes: engine with 3-way catalyst, freight,

installation, and tax $95,000 

Annualized Engine 

Capital Costs (10 years, 

10%) 

0.163 x New Engine Cost $15,485 

Annual Operating and Maintenance Costs (SCR)

Annual Added Fuel Cost 

(due to drop in fuel 

efficiency with catalyst) 

Fuel usage = 1,859.7 scf/hr 

Fuel cost (per 1,000 scf) = $7.36 

Fuel cost (per hour) = (1,859.7 x $7.36) / 1000 

Fuel cost (per year) = hourly cost x 2500 hr 

Assume 2.5% drop in fuel efficiency 

Added Fuel cost = Annual fuel cost x 2.5% 

$855 

Annual Catalyst Cost Life of catalyst = 5 years 

Cost per catalyst = $4,000 

Catalyst costs for 10 years = $4,000 x 2 

Annualized Catalyst Cost = $8,000 x 0.163 

$1,304 

Annual Maintenance Cost Maintenance = $0.02 per bhp per hour of operation 

Annual Maintenance Cost = $0.02 x 256 bhp x 

2500 hr 

$12,800 

Annual Operating & 

Maintenance (O&M) 

Costs

Annual O&M = Annual Added Fuel Cost + Annual 

Catalyst Cost + Annual Maintenance Cost $14,959

Annual Cost for New 

RB Engine with 3-way

Annualized Engine Capital Cost + Annual 

O&M Cost $30,444

*The values within the above table are rounded. 

The emissions reductions are calculated below: 

BHP = 256 bhp 

HR = 2,500 hours/year 

EF1 = 1.255 g-NOx/bhp-hr (equivalent to 90 ppmv) 

EF2 = 0.30 g-NOx/bhp-hr (equivalent to 25 ppmv) 

LF = 0.65 

CF = 453.6 grams/pound 

Current NOx = (BHP x HR x EF1 x LF) / (CF) 

 = (256 bhp x 2500 hr/yr x 1.255 g-NOx/bhp-hr x 0.65) / 453.6 

 = 1,151 lb-NOx/year 

Potential NOx = (BHP x HR x EF2 x LF) / (CF) 

 = (256 bhp x 2500 hr/yr x 0.30 g-NOx/bhp-hr x 0.65) / 453.6 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-139 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

 = 275 lb-NOx/year 

Potential Emissions Reduction = Current NOx – Potential NOx 

Potential Emissions Reduction = (1,151-275 lb) x (1 ton / 2,000 lb) 

Potential Emissions Reduction = 0.44 tons/year 

Cost Effectiveness (AO Rich-Burn, 25 ppmv) 

The cost effectiveness is the added cost, in dollars per year, of the control technology, 

divided by the emissions reductions achieved, in tons per year. Based on the 

calculations above, the cost effectiveness of replacing current AO rich-burn engines is 

as follows: 

 New rich-burn engine with a 3-way catalyst to meet 25 ppmv: $69,521/ton of 

NOx reduced 

In addition to the unique feasibility issues that AOs face with regards to the installation 

and maintenance of IC engines (see below), the cost effectiveness values above 

demonstrate that it is not cost effective to replace existing AO spark-ignited engines with 

new controlled engines. 

Other Feasibility Considerations AO Spark-Ignited Engines 

In addition to the high cost-effectiveness and potential infeasibility associated with 

retrofitting or replacing existing AO spark-ignited engines currently regulated under Rule 

4702, requiring additional costly controls on AO engines is economically challenging 

and potentially infeasible. Unlike most other industries, AOs cannot pass increased 

production costs on to consumers, thereby forcing AOs to absorb the compliance costs 

associated with costly additional retrofits and replacements. Over the past decade, AOs 

have invested significant capital to retrofit and replace thousands of irrigation pump and 

other engines reducing emissions by over 80% in this category, and continue to do so 

as emission limitations and associated compliance deadlines materialize under Rule 

4702. 

Additionally, AO spark-ignited engines are generally located in rural, hard to access 

areas with minimal oversight due to limited resources and staffing. With seasonal labor 

and minimal year-round staffing, it is difficult for AOs to provide the frequent and 

complex maintenance required for retrofitted or new engines equipped with advanced 

emission controls. The oil production industry is the only other major industry in the 

Valley that has IC engines located in remote locations; however, with the highly 

technical nature of oil production and refining as compared to agricultural production 

and additional economic resources, it is feasible for the oil and gas production industry 

to hire qualified staff dedicated to maintaining and operating IC engines and other 

equipment on-site. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-140 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Additional Emission Reduction Opportunities 

SOx and PM limitations 

Rule 4702 contains stringent requirements requiring the combustion of Public Utilities 

Commission (PUC) quality natural gas, or other equivalent ultra-low sulfur fuels, and 

diesel engines subject to Rule 4702 are required to be EPA Tier 3 or Tier 4 certified, 

depending on the size of the engine and the annual operating hours. EPA Tier 3 and 4 

certifications require the units to meet low PM limits and Tier 4 engines are required to 

meet even lower PM emissions through the use of particulate filters. Given the low 

PM2.5 and SOx emissions from IC engines and existing rule requirements, the District 

determined that no further requirements were needed to address PM2.5 and SOx 

emissions. 

Emission limitation exemptions for emergency standby engines and low-use 

engines 

The existing requirements are consistent with Air Resources Board (ARB) 

RACT/BARCT Determination for Spark-Ignited Engines and ARB Airborne Toxics 

Control Measures (ATCM). Since these units are used only for emergencies or in very 

limited capacities, emissions from these units are relatively minor, and requiring 

additional emissions controls would likely not be cost effective. 

Non-Regulatory Actions 

The District implements a stationary agricultural irrigation pump engine program as a 

component of the Heavy-Duty Engine Program. This program provides incentives for 

both the conversion of Tier 1 and Tier 2 engines to lower NOx and PM-emitting Tier 4 

engines and for the electrification of diesel engines, as the District highly prioritizes 

electrification efforts to achieve zero and near-zero emissions from engines. The 

District’s legislative platform76 includes support for incentive funding through the Carl 

Moyer Program. Continued support of this funding stream will continue to provide 

incentives for accelerated reductions from IC engines. 

Meeting air quality standards requires transformative measures and technologies to 

achieve near zero emissions. In order to further develop technology to close the gap in 

required emissions reductions, the District operates a Technology Advancement 

Program (TAP). Along with its own resources, the District seeks state and federal 

assistance through its legislative platform to advance technologies to reduce emissions 

in the Valley. District TAP projects seek innovations in several areas of technology 

including IC engines. While no technologies to reduce emissions from IC engines have 

been achieved in practice yet, these projects may provide the basis for future feasible, 

SIP-creditable emission reductions. 

 

76 SJVAPCD. (January 2015). Legislative Platform 2015. 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2015/January/final/10.pdf 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-141 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Evaluation Findings 

Even though IC engines are not a significant source of PM2.5 or SOx in the Valley, the 

District has evaluated all potential control technologies and all control technologies 

achieved in practice in other areas or included in other state implementation plans. As 

demonstrated above, Rule 4702 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 this source category. As the District continues to develop new 

attainment plans that address more stringent National Ambient Air Quality Standards, 

the District will continue to evaluate potential opportunities to reduce NOx emissions 

from IC engines in the Valley. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-142 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.18 RULE 4703 STATIONARY GAS TURBINES 

Discussion 

The provisions of this rule are applicable to all stationary gas turbine systems, which are 

subject to District permitting requirements, and with electrical generation ratings equal 

to or greater than 0.3 megawatt (MW) or a maximum heat input rating of more than 3 

million British Thermal Units per hour (MMBtu/hr), and that are used for the generation 

of electrical power. The purpose of this rule is to limit NOx emissions from these 

stationary gas turbines. 

Rule 4703 was adopted on August 18, 1994. Since its adoption, the rule has been 

amended six times. The latest rule amendment in September 2007 strengthened the 

rule by establishing more stringent NOx limits for existing stationary gas turbines. EPA 

finalized approval for Rule 4703 on October 21, 2009 and deemed this rule as being at 

least as stringent as established RACT requirements. NOx emissions have been 

controlled by over 86% for this source category. 

Source Category 

The requirements of Rule 4703 affect owners and operators of stationary gas turbine 

systems used to pump, compress, generate electricity, or perform other tasks. The four 

major industry groups are oil and gas production, utilities, manufacturing, and 

government. 

In complying with the rule, all affected entities are required to control NOx and CO 

emissions by installing approved emissions control devices. Early in the rule 

development process, the District identified five different emissions control technologies 

that could be used to achieve proposed limits for stationary gas turbines. Of the five 

options, four mainly control NOx emissions, while the other one controls CO emissions. 

The four NOx control technologies are: 

 Dilutant (water or steam) injection systems, 

 Dry, low-NOx, 

 Selective catalytic reduction, and 

 SCONOx 

Costs associated with different compliance options vary a great deal depending on 

technologies and available products. Depending on the size of the existing turbine 

systems, engine model and make, type of existing emissions control equipment, and 

many other factors, owners and operators of stationary gas turbine systems face 

different compliance costs. The impacts of Rule 4703 have been concentrated in the oil 

and gas production sector and utilities sector of the Valley, as they own and operate the 

vast majority of stationary gas turbines subject to the rule. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-143 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 1.22 1.28 1.14 1.09 1.11 1.14 1.14 1.14 1.10 

NOx 3.09 3.23 2.89 2.77 2.83 2.89 2.90 2.92 2.81 

SOx 0.22 0.23 0.20 0.19 0.19 0.20 0.20 0.20 0.19 

Winter Average - Tons per day 

PM2.5 1.21 1.27 1.13 1.08 1.10 1.13 1.13 1.14 1.09 

NOx 3.00 3.14 2.82 2.70 2.76 2.82 2.83 2.84 2.74 

SOx 0.21 0.23 0.20 0.19 0.19 0.20 0.20 0.20 0.19 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from stationary gas turbines are lower than the BACM/MSM 

significance thresholds. Therefore, the Clean Air Act does not require a control 

measure evaluation for this source category for the purpose of satisfying BACM/MSM 

requirements; however, the District has still conducted a full control measure evaluation 

for stationary gas turbines. 

How does District Rule 4703 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG requirements for this source category. 

ACT 

 EPA–435/R-93-007 (Alternative Control Techniques Document—NOx Emissions 

from Stationary Gas Turbines) 

The District evaluated the requirements contained within the ACT for NOx Emissions 

from Stationary Gas Turbines and found no requirements that were more stringent than 

those already in Rule 4703. 

NSPS 

 40 CFR 60 Subpart GG (Standards of Performance for Stationary Gas Turbines) 

The District evaluated the requirements contained within 40 CFR 60 Subpart GG and 

found no requirements that were more stringent than those already in Rule 4703. 

 40 CFR 60 Subpart KKKK (Standards of Performance for Stationary Combustion 

Turbines) 

The District evaluated the requirements contained within above NSPS and found no 

requirements that were more stringent than those already in Rule 4703. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-144 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

NESHAP/ MACT 

 40 CFR 63 Subpart YYYY (NESHAP for Stationary Combustion Turbines) 

The District evaluated the requirements contained within 40 CFR 63 Subpart YYYY and 

found no requirements that were more stringent than those already in Rule 4703. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 4703 compare to rules in other air districts? 

SCAQMD 

 Rule 1134 (Emissions of Oxides of Nitrogen from Stationary Gas Turbines) 

The District evaluated the requirements contained within SCAQMD’s Rule 1134 and 

found no requirements that were more stringent than those already in Rule 4703. 

BAAQMD 

 Regulation 9 Rule 9 (Nitrogen Oxides from Stationary Gas Turbines) 

The District evaluated the requirements contained within BAAQMD’s Regulation 9 Rule 

9 and found no requirements that were more stringent than those already in Rule 4703. 

SMAQMD 

 Rule 413 (Stationary Gas Turbines) 

The District evaluated the requirements contained within SMAQMD’s Rule 413 and 

found no requirements that were more stringent than those already in Rule 4703. 

VCAPCD 

 Rule 74.23 (Stationary Gas Turbines) 

The District evaluated the requirements contained within VCAPCD’s Rule 74.23 and 

found no requirements that were more stringent than those already in Rule 4703. 

Additional Emission Reduction Opportunities 

The District has adopted numerous rule amendments to the turbine rule that have 

successfully and significantly reduced emissions from this source category. The 

emissions inventory for NOx from turbines has been reduced from 31.9 tpd in 1994 to 

2.77 tpd in 2015. Significant emission reductions have been achieved through the 

implementation of the most stringent regulations in the nation for this source category 

and significant investments by stakeholders to implement effective and innovative 

emission control technologies. Given the significant efforts and investments already 

made to reduce emissions from this source category, there are little remaining feasible 

opportunities for obtaining additional emissions reductions. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-145 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

BACT Comparisons 

Comparisons of this rule with the District, BAAQMD, and SCAQMD BACT requirements 

showed that some BACT emissions limits are more stringent than Rule 4703 limits. For 

units greater than 3 MW, some of the District’s NOx limits ranged from 3-5 ppmv, 

whereas the BACT limits ranged from 2-3 ppmv. For units less than 3 MW, the District’s 

NOx limit was 9 ppmv, whereas the BACT limit was 5 ppmv. The BACT guidelines list 

SCR and SCONOx as the emissions control technologies used to achieve emission 

limits in the range of 2-5 ppmv. Although lower emission limits are potentially 

achievable for this source category, BACT requirements are imposed on new or 

modified turbine installations where ultra-low NOx controls can be installed and the 

equipment and the facility can be designed to function with this new technology. Rule 

4703 is a prohibitory rule that has undergone several generations of NOx limits for 

existing units in the Valley; facilities comply with these limits by retrofitting their existing 

equipment. Requiring the installation of entirely new turbine systems is extremely 

expensive and not cost effective, and therefore not required of facilities. 

Selective Catalytic Reduction 

Many of the larger units (> 3MW) have already employed SCR to achieve the 5 ppmv 

limits in place. Therefore, the District evaluated the potential opportunity to employ 

SCR for units less than 3 MW. 

A SCR system reduces NOx emissions by converting the emissions to water and 

elemental nitrogen. Ammonia is generally injected into the exhaust stream and reacts 

with the nitrogen. Due to the high cost of SCR systems, they are typically used for 

controlling emissions from larger units, greater than 3 MW that generally create more 

emissions. The cost effectiveness of an SCR system for a 1 MW unit was calculated 

based on the cost effectiveness methodologies in the 2007 Staff Report for Rule 4703 

and some of the newer methodologies used to calculate the cost effectiveness of SCR 

in the August 2011 Staff Report for Rule 4702. The tables below present the total 

annual costs for a new SCR system and a retrofit system. 

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

C-146 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Table C-28 SCR Annual Costs for a New Installation on a 1 MW Turbine 

Item Source Cost 

Turbine Rating 1 MW 

SCR Cost/KW $125/KW 

Mid-point between 

high and low 

estimate from 

R4703 analysis 

 

Operating Hours 7884 hrs/year 

Direct Capital Costs 

Total Purchased Equip 

Cost $125/KW x 1000 KW $125,000 

Freight 5% Purchased Equip. Cost 

(PEC) Rule 4702 $6,250 

Sales Tax 8.25% PEC Rule 4702 $10,313 

Direct Installation Costs 25% PEC Rule 4702 $31,250 

Total Direct Capital Costs $172,813 

Indirect Capital Costs 

Facilities 5% PEC Rule 4702 $6,250 

Engineering 10% PEC Rule 4702 $12,500 

Process Contingency 5% PEC Rule 4702 $6,250 

Total Indirect Capital Costs $25,000 

Project Contingency 20% PEC Rule 4702 $25,000 

Total Capital Costs (TCC) Direct Capital + Indirect Capital 

+ Project Contingency Rule 4702 $222,813 

Annualized Capital Costs 

(10 years @ 10%) 0.1627*TCC Rule 4702 $36,252 

Direct Annual Costs 

Operating Costs 

Operator 0.5 hr/shift, $25/hr OAQPS $13,688 

Supervisor 15% of operator OAQPS $2,053 

Maintenance Costs 

Labor 0.5 hr/shift, $25/hr OAQPS $13,688 

Material 100% of labor cost OAQPS $13,688 

Utility Costs 

Electricity Costs Variable $5,747 

Cat. Replacement MHIA $5,621 

Cat. Disposal OAQPS $211 

Ammonia Variable $1,008 

NH3 Inject Skid MHIA $2,916 

Total Direct Annual Costs $58,620 

Indirect Annual Costs 

Overhead 60% of Operating and 

Maintenance OAQPS $25,870 

Administrative 0.02 x PEC OAQPS $2,500 

Insurance 0.01 x PEC OAQPS $1,250 

Property Tax 0.01 x PEC OAQPS $1,250 

Capital Recovery 0.13 x PEC OAQPS $16,250 (10% int. rate, 15 yr period) 

Total Indirect Annual 

Costs $47,120 

Total Annual Costs Annualized capital + Direct 

Annual + Indirect Annual $141,992 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-147 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Table C-29 SCR Annual Costs for a Retrofit on a 1 MW Turbine 

Item Source Cost 

Turbine Rating 1 MW 

SCR Cost/KW $325/KW 

Middle point 

between high and 

low estimate from 

R4703 analysis 

 

Operating Hours 7884 hrs/year 

Direct Capital Costs

Total Purchased Equip 

Cost $325/KW x 1000 KW $325,000 

Freight 5% Purchased Equip. Cost 

(PEC) Rule 4702 $16,250 

Sales Tax 8.25% PEC Rule 4702 $26,813 

Direct Installation Costs 25% PEC Rule 4702 $81,250 

Total Direct Capital Costs $449,313 

Indirect Capital Costs 

Facilities 5% PEC Rule 4702 $16,250 

Engineering 10% PEC Rule 4702 $32,500 

Process Contingency 5% PEC Rule 4702 $16,250 

Total Indirect Capital Costs $65,000 

Project Contingency 20% PEC Rule 4702 $65,000 

Total Capital Costs (TCC) Direct Capital + Indirect Capital 

+ Project Contingency Rule 4702 $579,313 

Annualized Capital Costs 

(10 years @ 10%) 0.1627*TCC Rule 4702 $94,254 

Direct Annual Costs

Operating Costs 

Operator 0.5 hr/shift, $25/hr OAQPS $13,688 

Supervisor 15% of operator OAQPS $2,053 

Maintenance Costs 

Labor 0.5 hr/shift, $25/hr OAQPS $13,688 

Material 100% of labor cost OAQPS $13,688 

Utility Costs 

Electricity Costs Variable $5,747 

Cat. Replacement MHIA $5,621 

Cat. Disposal OAQPS $211 

Ammonia Variable $1,008 

NH3 Inject Skid MHIA $2,916 

Total Direct Annual Costs $58,620 

Indirect Annual Costs

Overhead 60% of Operating and 

Maintenance OAQPS $25,870 

Administrative 0.02 x PEC OAQPS $6,500 

Insurance 0.01 x PEC OAQPS $3,250 

Property Tax 0.01 x PEC OAQPS $3,250 

Capital Recovery 0.13 x PEC OAQPS $42,250 (10% int. rate, 15 yr period) 

Total Indirect Annual 

Costs $81,120 

Total Annual Costs Annualized capital + Direct 

Annual + Indirect Annual $233,994 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-148 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Potential Emissions Reduction Methodology 

The estimated current annual NOx emissions and the estimated potential annual NOx 

emissions were calculated using the following equation: 

NOx = LF x MMBtu/hr x HR x EF/ 2,000 lb/ton 

Where: 

NOx = Current annual NOx emissions or potential annual NOx emissions (tpy) 

LF = turbine load factor 

MMBtu/HR= heat input rating 

HR = annual hours of operation 

EF = NOx emission factor in pounds per MMBtu 

Where: 

EF = NOx emission factor in ppmv x 0.00366 

ppmv = NOx emissions in parts per million corrected to 15% oxygen 

0.00366 = Conversion factor used: 0.00366 lb/MMBtu per ppmv NOx

The estimated annual NOx emissions reduction was calculated using the following 

equation: 

NOx Emissions Reduction = Current NOx emissions - Potential NOx emissions 

Potential Emissions Reduction Calculation 

The emissions reduction calculations below utilized the following information: 

Loading factor = 0.75 

Heat input rating for a 1 MW unit = 15 MMBtu/hr 

Annual Hours of Operation = 7884 hours 

Current Emission Factor in Rule 4703 = 9 ppmv 

Potential Emissions Factor through the use of SCR = 5 ppmv 

Current NOx = LF x MMBtu/hr x HR x EF / 2,000 lb/ton 

 = 0.75 x 15 x 7884 x (9 x 0.00366) / 2000 

 = 1.46 tons/year 

Potential NOx = LF x MMBtu/hr x HR x EF / 2,000 lb/ton 

 = 0.75 x 15 x 7884 x (5 x 0.00366) / 2000 

 = 0.81 tons/year 

Emissions Reductions = Current NOx emissions - Potential NOx emissions 

 = 0.65 tons/year 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-149 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Table C-30 SCR Cost Effectiveness 

Type of 

Installation MW MMBtu/hr 

Current 

NOx 

Emission 

Factor 

(EF), 

ppmv 

Potential 

NOx EF, 

ppmv 

NOx 

Reduction 

(Tons/Year) 

Total 

Annual 

Cost ($) 

Cost 

Effectiveness 

($/ton) 

New 1 15 9 5 0.65 $141,992 $218,449 

Retrofit 1 15 9 5 0.65 $233,994 $359,991 

As demonstrated above, SCR is not a cost effective option as a retrofit or replacement 

for units less than 3 MW. 

EMx 

Certain BACT limits for simple cycle plants were achieved through the use of SCONOx. 

This multifaceted technology reduces NOx, SOx, carbon monoxide (CO), and volatile 

organic compound (VOC) emissions and is stated as achieving NOx levels less than 1.5 

ppmv by its manufacturer. One issue with the use of SCONOx is that it requires steam 

to operate and simple cycle plants do not generate steam. Therefore, a simple cycle 

facility would have to add a boiler to their facility to generate steam for the SCONOx 

system, making the addition of this technology more costly. The District is not aware of 

any SCONOx applications on simple cycle plants.77 While SCONOx is better suited for 

combined cycle turbines, this technology has not been achieved in practice (AIP) yet in 

the District. 

BAAQMD evaluated SCONOx, now known as the EMx system, for turbines in a recent 

Final Determination of Compliance (FDOC) for the Oakley Generating Station. The 

FDOC states that EMx could potentially be an improvement over SCR as an add-on 

control device for achieving NOx reductions – assuming it can achieve the same level of 

NOx control – because it does not use ammonia. Ammonia has the potential, under 

certain atmospheric conditions, to react with nitric acid in the atmosphere to form 

ammonium nitrate, which can be a form of PM2.5. However, based on the 

implementation of EMx at a facility in Shasta County, BAAQMD voiced some concerns 

for its use. 

EMx has never been used on a large utility-scale turbine and so there is no data on 

which to make a direct evaluation of how well the technology would work on larger 

turbines. EMx has been used on a smaller aeroderivitive turbine at the Redding Power 

Plant Unit No. 5, a 45-MW combined-cycle facility in Shasta County, CA. The Shasta 

County Air Quality Management District evaluated EMx at the Redding facility under a 

demonstration NOx limit of 2.0 ppm, which SCR can consistently achieve. After three 

years of operation, the Shasta County AQMD evaluated whether the facility was 

meeting this demonstration limit with EMx, and concluded that “Redding Power is not 

 

77 Brian K. Lusher, Bay Area Air Quality Management District. (June 2010). Final Determination of Compliance: 

Marsh Landing Generating Station.
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-150 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

able to reliably and continuously operate while maintaining the NOx demonstration limit 

of 2.0 ppmvd @ 15% O2.”

78 

The FDOC states that although the EMx manufacturer maintains that such problems 

have been overcome, concerns remain about how consistently the technology would be 

able to perform. Communications between BAAQMD and Shasta County Air District 

confirmed that the earlier conclusions about the achievability of a lower limit remain 

valid.79 In addition, monthly reports of Continuous Emissions Monitoring System 

(CEMS) data submitted by Redding Power Plant to Shasta County Air District during 

2007 and 2008 indicated that emissions have often been substantially higher.80 

Furthermore, the data from Redding is from a smaller aeroderivitive turbine, and there is 

no guarantee that if it were scaled up for uses on utility-size turbines that it would even 

be able to achieve the performance required from larger turbines. For these reasons, 

BAAQMD concluded that EMx is not as developed as SCR and cannot achieve the 

same level of emissions performance that SCR is capable of. 

SCAQMD is funding a research project that will study and demonstrate the feasibility of 

control technologies to reduce PM2.5 and ultrafine particulate emissions from natural 

gas-fired turbine power plants. EMx is one of the two technologies that were selected 

for demonstration. The findings of this report could potentially be beneficial for 

evaluating the feasibility of EMx applications for turbines in the future. 

SOx 

The District considered implementing sulfur dioxide (SO2) limits at least as stringent as 

the requirements in 40 CFR 60 Subpart KKKK (Standards of Performance for Stationary 

Combustion Turbines). Fuel treatment sulfur removal systems were recognized as 

being able to reduce SOx emissions from turbines, other than those fired on Public 

Utilities Commission (PUC) quality natural gas. One Valley facility installed SCR onto 

their digester gas-fired turbine to meet the Rule 4703 limit. To do this, they installed a 

fuel pretreatment system that removes H2S and siloxanes, as they can damage the 

SCR catalyst if not removed. Other landfill and digester-gas turbines outside the District 

are also using these systems. 

There are only seven units at six facilities in the Valley that utilize a fuel other than 

natural gas. Four units are fired on diesel gas, while the other three units utilize 

digester gas. However, the facilities with diesel-fired units utilize natural gas the 

majority of the time and utilize diesel fuel only during emergencies. Due to California 

Diesel Fuel requirements, the diesel facilities in the Valley are limited to a sulfur content 

of 0.0016 lb-SO2/MMBtu. PUC-quality natural gas typically has a sulfur content of 

0.00285 lb-SO2/MMBtu and digester turbines are limited to 0.016 lb-SO2/MMBtu per 

 

78 Letter from R. Bell, Air Quality District Manager, Shasta County Air Quality Management District, to R. Bennett, 

Safety & Environmental Coordinator, Redding Electric Utility, June 23, 2005. 79 Kathleen Truesdell, Bay Area Air Quality Management District. (January 2011). Final Determination of Compliance: 

Oakley Generating Station.

80 Kathleen Truesdell, Bay Area Air Quality Management District. (January 2011). Final Determination of Compliance: 

Oakley Generating Station.
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-151 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

District permits’ requirements. By comparison, the Subpart KKKK limit is much higher 

at 0.060 lb-SO2/MMBtu and all of the units in the Valley are achieving much lower SO2 

limits. Adding a SO2 limit similar to Subpart KKKK to the rule will not foster additional 

emissions reductions for Valley facilities. 

PM2.5 

PM2.5 reduction technologies for turbines were also researched. Post-combustion 

controls, including baghouses, electrostatic precipitators, and scrubbers were examined 

since these technologies can be used to remove PM2.5 emissions from exhaust gas 

streams. 

As previously mentioned, every unit in the Valley subject to Rule 4703 operates on 

strictly natural gas, with the exception of seven facilities that operated on an alternate 

fuel part-time or during emergencies. Based on District Permits records and information 

in the BAAQMD FDOC for the Oakley Generating Station, electrostatic precipitators, 

baghouses, and scrubbers have not been achieved-in-practice for natural gas-fired 

turbines. These devices are normally used on solid fuel fired sources or others with 

high PM emissions, and are not used in natural gas-fired applications, which have 

inherently low PM emissions. The District is not aware of any gas turbine that has ever 

been required to use add-on controls such as these. BAAQMD reviewed the EPA 

BACT/LAER Clearinghouse and confirmed that EPA has no record of any postcombustion particulate controls that have been required for natural gas-fired gas 

turbines.81 

Furthermore, these devices would not be technologically feasible to implement for 

certain facilities. As noted in the BAAQMD FDOC, if add-on control equipment were 

installed, it would create significant backpressure that would significantly reduce the 

efficiency of a power plant and would cause more emissions per unit power produced. 

Moreover, these devices are designed to be applied to emissions streams with far 

higher particulate emissions, and they would have very little effect on the low-PM 

emissions streams from natural gas-fired facilities in further reducing PM emissions.82 It 

takes an emissions stream with a much higher grain loading for these types of 

abatement devices to operate efficiently. This low level of abatement efficiency (if any) 

also means that these types of control devices would not be cost effective, even if they 

could feasibly be applied to this type of source. For these reasons, post-combustion 

particulate control equipment is not technologically feasible for units subject to Rule 

4703. 

As previously mentioned, SCAQMD is funding a research project that will study and 

demonstrate the feasibility of control technologies to reduce PM2.5 and ultrafine 

particulate emissions from natural gas-fired turbine power plants. Sulfur removal and 

the EMx multi-pollutant control system are the two technologies which were selected for 

 

81 Kathleen Truesdell, Bay Area Air Quality Management District. (January 2011). Final Determination of Compliance: 

Oakley Generating Station.

82 Kathleen Truesdell, Bay Area Air Quality Management District. (January 2011). Final Determination of Compliance: 

Oakley Generating Station.
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-152 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

demonstration. The findings of this report could potentially be beneficial for evaluating 

the cost effectiveness and feasibility of applying these emerging technologies to 

turbines in the future. 

Evaluation Findings

Even though stationary gas turbines are not a significant source of PM2.5, NOx, or SOx 

in the Valley, the District has evaluated all potential control technologies and all control 

technologies achieved in practice in other areas or included in other state 

implementation plans. As demonstrated above, Rule 4703 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 this source category. As the District 

continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from stationary gas turbines in the Valley. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-153 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.19 RULE 4802 SULFURIC ACID MIST 

Discussion 

The purpose of Rule 4802 is to limit sulfuric acid emissions from any sulfuric acid 

production unit that was constructed or modified before August 17, 1971. The rule was 

adopted on May 21, 1992 to limit sulfuric acid mist to 0.30 pounds per short ton of acid 

produced and only applies to one facility in the Valley. EPA approved Rule 4802 into 

the SIP on June 8, 1999. 

Source Category 

A sulfuric acid production unit is any facility producing sulfuric acid by the contact 

process by burning elemental sulfur, alkylation acid, hydrogen sulfide, organic sulfides, 

or acid sludge. It does not include acid plants used as sulfur dioxide (SO2) control 

systems, chamber process plants, acid concentrators, or petroleum storage and transfer 

facilities. 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.75 0.76 0.77 0.78 0.79 0.80 0.81 0.83 0.85 

Winter Average - Tons per day 

PM2.5 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.75 0.76 0.77 0.78 0.79 0.80 0.81 0.83 0.85 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from sulfuric acid mist are lower than the BACM/MSM 

significance thresholds. Therefore, the Clean Air Act does not require a control 

measure evaluation for this source category for the purpose of satisfying BACM/MSM 

requirements; however, the District has still conducted a full control measure evaluation 

for sulfuric acid mist. 

How does District Rule 4802 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NESHAP, or MACT requirements for this source 

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

C-154 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

NSPS 

 40 CFR 60 Subpart Cd (Emissions Guidelines and Compliance Times for Sulfuric 

Acid Production Units) 

The District evaluated the requirements contained within 40 CFR 60 Subpart Cd and 

found no requirements that were more stringent than those already in Rule 4802. 

 40 CFR 60 Subpart H (Standards of Performance for Sulfuric Acid Plants)—last 

amended on February 27, 2014, but the revisions only included corrections for 

source testing procedures. 

The District evaluated the requirements contained within 40 CFR 60 Subpart H and 

found no requirements that were more stringent than those already in Rule 4802. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 4802 compare to rules in other air districts? 

There are no analogous rules for this source category in SMAQMD or VCAPCD. 

SCAQMD 

 Rule 469 (Sulfuric Acid Units) 

The District evaluated the requirements contained within SCAQMD Rule 469 and found 

no requirements that were more stringent than those already in Rule 4802. 

BAAQMD 

 Regulation 9, Rule 1 (Sulfur Dioxide) 

The District evaluated the requirements contained within BAAQMD Regulation 9 Rule 1 

and found no requirements that were more stringent than those already in Rule 4802. 

 Regulation 12, Rule 6 (Acid Mist from Sulfuric Acid Plants) 

The District evaluated the requirements contained within BAAQMD Regulation 12 Rule 

6 and found no requirements that were more stringent than those already in Rule 4802. 

Additional Emission Reduction Opportunities 

Only one facility in the Valley—a sulfuric acid plant—is subject to Rule 4802 (Sulfuric 

Acid Mist). This facility was in operation before 1971 and is limited by this rule to 0.30 

pounds of acid mist per ton of acid produced. The facility uses a mist eliminator to 

remove fine particles from the acid gas stream, which has been determined to meet 

BACT requirements. By definition of Rule 4802, no new facility within the Valley will be 

subject to this rule. Instead, all new facilities would be subject to Rule 2201 (New and 

Modified Stationary Source Review Rule) and would be required to implement BACT 

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

C-155 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

The District evaluated the potential opportunity to reduce emissions from this source 

category by lowering the limit for sulfur emissions from 0.30 pounds per ton produced to 

0.1 pound per ton produced, consistent with EPA’s BACT determination. Source tests 

conducted in 2010 and 2011 at the single facility permitted under Rule 4802, showed an 

actual sulfuric acid mist emission rate of 0.09 pound per ton using existing technology. 

Hence, the facility is meeting the current national BACT standard with the most 

advanced technology currently available and enforced through existing permit 

requirements, despite the fact that their current permit and Rule 4802 do not set that 

requirement. Therefore, the District has determined that there are no potential 

opportunities to further reduce emissions from this source category. 

Evaluation Findings

Even though sulfuric acid mist is not a significant source of PM2.5, NOx, or SOx in the 

Valley, the District has evaluated all potential control technologies and all control 

technologies achieved in practice in other areas or included in other state 

implementation plans. As demonstrated above, Rule 4802 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 this source category. As the District 

continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from sulfuric acid mist in the Valley. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-156 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.20 RULE 4901 WOOD BURNING FIREPLACES AND WOOD BURNING 

HEATERS 

Discussion 

Rule 4901 limits emissions from wood burning fireplaces, wood burning heaters, and 

outdoor wood burning devices through wood burning curtailments in areas with natural 

gas service. Rule 4901 also restricts the sale and transfers of non-compliant wood 

burning devices, and limits the installation of wood burning devices in new residential 

developments. 

Through the Check Before You Burn program, which is based on Rule 4901, the District 

has declared and enforced episodic wood burning curtailments, also called “No Burn” 

days, since 2003. Check Before You Burn and District Rule 4901 reduce harmful 

species of PM2.5 when and where those reductions are most needed: in impacted 

urbanized areas when the local weather is forecast to hamper PM dispersion. 

Rule 4901 was first adopted in 1993 and has been subsequently amended three times. 

The 1993 adoption of Rule 4901 established a public education program on techniques 

to reduce wood burning emissions. It also enforced EPA Phase II requirements for new 

wood burning heaters, prohibited the sale of used wood burning heaters, established a 

list of prohibited fuel types, and required the District to request voluntary curtailment of 

wood burning on days when the ambient air quality was unhealthy. 

The 2003 rule amendments added episodic wood burning curtailments when air quality 

was forecast to be at 150 or higher on the air quality index (AQI), which is equivalent to 

a PM2.5 concentration of 65 μg/m3, and added restrictions on the installation of wood 

burning devices in new residential developments, based on housing density. The 2008 

rule amendments lowered the mandatory curtailment level to a PM2.5 concentration of 

30 μg/m3, and added a contingency measure to lower the wood burning curtailment 

level to 20 μg/m3 in the event that EPA finds that the Valley does not attain the 1997 

PM2.5 air quality standard in 2014. 

The 2014 amendments to Rule 4901 lowered the No Burn threshold for high polluting 

wood burning heaters and fireplaces from 30 μg/m3

 to 20 μg/m3. The amendments 

doubled the number of No Burn days for high polluting units that are the source of over 

95% of the wintertime residential wood smoke emissions. By contrast, under the newly 

amended rule, clean certified units are subject to a minimal number of No Burn days 

ranging from zero to six days depending on the location in the Valley during the winter 

season because the No Burn thresholds for these units were raised to 65 μg/m3

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

C-157 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 4.48 4.38 4.28 4.28 4.28 4.28 4.28 4.28 4.28 

NOx 0.50 0.49 0.48 0.48 0.48 0.48 0.48 0.48 0.48 

SOx 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.08 

Winter Average - Tons per day 

PM2.5 8.73 8.54 8.35 8.35 8.35 8.35 8.35 8.35 8.35 

NOx 0.98 0.96 0.94 0.94 0.94 0.94 0.94 0.94 0.94 

SOx 0.16 0.16 0.15 0.15 0.15 0.15 0.15 0.15 0.15 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from wood burning fireplaces and wood burning heaters are 

lower than the BACM/MSM significance thresholds for NOx and SOx. Therefore, the 

Clean Air Act does not require a NOx and SOx control measure evaluation for this 

source category for the purpose of satisfying BACM/MSM requirements; however, the 

District has still conducted a full control measure evaluation for wood burning fireplaces 

and wood burning heaters. 

How does District Rule 4901 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTGs, ACTs, NESHAPs, or MACT guidelines for this source 

category. 

NSPS 

 40 CFR Part 60 Subpart AAA (Standards of Performance for New Residential Wood 

Heaters) 

On February 3, 2014, EPA published proposed amendments to 40 CFR Part 60 Subpart 

AAA.83 The proposed rule was finalized by EPA on February 3, 2015. District Rule 

4901 points to the NSPS for emission limits and is therefore as stringent as the newly 

promulgated NSPS. 

1988 NSPS 

Under the 1988 NSPS, only those wood or pellet-burning units meeting the following 

criteria require certification and all other units are not required to obtain certification and 

are therefore considered exempt: 

 

83 40 CFR Part 60 Subpart AAA, Standards of Performance for New Residential Wood Heaters (FR 79 6330–6416) 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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1. Units that have an air-to-fuel ratio averaging less than 35-to-1; 

2. Units with a usable firebox volume less than 20 cubic feet; 

3. Units with a minimum burn rate less than 5 kilograms per hour (11 pounds per 

hour); and 

4. Units that weigh 1,760 pounds or less. 

For wood heaters meeting these requirements, the current certification emissions limits 

are 4.1 grams per hour (g/hr) of PM for units equipped with a catalytic combustor and 

7.5 g/hr for units without a catalytic combustor. Units certified to these emission limits 

are said to be Phase-II Certified and will maintain that certification until the certification 

expires, which is up to 5 years from the issuance date. 

Under the current NSPS, pellet stoves are not explicitly exempt from required 

certification; however, most models currently sold fall outside the regulation because 

they operate on an air-to-fuel ratio greater than 35-to-1. Single burn rate wood heaters 

are also not explicitly exempt from the current NSPS, but are not regulated by it 

because they operate below the burn rate criteria of 5 kilograms per hour. 

2015 NSPS 

The 2015 NSPS significantly lowers the certification emission limits for wood-burning 

heaters that are currently required to be certified and sets certification limits for a 

broader range of wood-burning heaters by removing the existing certification criteria (1 

through 4 above). New standards will apply not only to adjustable burn rate wood 

heaters (the focus of the original regulation), but also to single burn rate wood 

heaters/stoves, pellet heaters/stoves, and any other affected appliance as defined in 

revised Subpart AAA as a “room heater.” 

Although they do not require EPA certification under the 1988 NSPS, 96% of pellet 

heaters meet the proposed Step 1 PM emissions limit of 4.5 grams per hour. Single 

burn rate wood heaters are incapable of operating at the lowest burn rates, and it is the 

lower burn rates that result in the highest level of PM emissions; therefore, most single 

burn rate wood heaters will also meet the proposed Step 1 PM emissions limit. 

Manufacturers of such units will not initially be required to modify their design if they 

already meet the emissions standard and will automatically be deemed as certified to 

meet the Step 1 emission limits. 

EPA promulgated a two-step compliance approach that applies to all new adjustable 

burn rate wood heaters, single burn rate wood heaters and pellet heaters/stoves. Under 

this approach, Step 1 emission limits for these sources will apply to each source 

manufactured on or after the effective date of the final rule or sold at retail on or after 

December 31, 2015. Step 2 emission limits for these sources will apply to each heater 

manufactured or sold at retail on or after the date five years after the effective date of 

the final rule. EPA is allowing an alternative compliance option for manufacturers who 

choose to certify using cord wood (rather than crib wood) to meet the Step 2 limits. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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Table C-31 Subpart AAA PM Emissions Limits 

2-Step, 5-Year Phase-In 

Step PM limit Compliance deadline 

1 4.5 g/hr Upon the effective date of the final rule 

2

2.0 g/hr 

2.5 g/hr 5 years after effective date of final rule 

(Cord wood alternative compliance option) 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 4901 compare to rules in other air districts? 

There are no analogous rules for this source category in VCAPCD. 

SCAQMD 

 Rule 445 (Wood Burning Devices) 

Rule 445 was last amended on May 3, 2013 to lower the curtailment threshold from 35 

to 30 μg/m3. District Rule 4901 is more stringent than Rule 445, as the District lowered 

the No Burn threshold for high polluting wood burning heaters and fireplaces from the 

30 μg/m3

 to 20 μg/m3 in 2014. The District evaluated the requirements contained within 

SCAQMD Rule 445 and found no requirements that were more stringent than those 

already in Rule 4901. 

BAAQMD 

 Regulation 6 Rule 3 (Wood-Burning Devices) 

The District evaluated the requirements contained within BAAQMD Regulation 6 Rule 3 

and found no requirements that were more stringent than those already in Rule 4901. 

SMAQMD 

 Rule 417 (Wood Burning Appliances) 

The District evaluated the requirements contained within SMAQMD Rule 417 and found 

no requirements that were more stringent than those already in Rule 4901. 

 Rule 421 (Mandatory Episodic Curtailment of Wood and other Solid Fuel Burning) 

The District evaluated the requirements contained within SMAQMD Rule 421 and found 

no requirements that were more stringent than those already in Rule 4901. 

Other Analogous Rules 

 Washington State’s Department of Ecology Regulation Chapter 173-433 WAC (Solid 

Fuel Burning Devices) 

The District evaluated the requirements contained within the above regulation and found 

no requirements that were more stringent than those already in Rule 4901. 
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 Colorado Air Quality Control Commissions Regulation No. 4 

The District evaluated the requirements contained within Colorado’s rule and found no 

requirements that were more stringent than those already in Rule 4901. 

 Spokane Regional Clean Air Agency Regulation I Article VIII 

The District evaluated the requirements contained within the Spokane rule and found no 

requirements that were more stringent than those already in Rule 4901. 

 Oregon Department of Environmental Quality Division 262 (Heat Smart Program for 

Residential Woodstoves and Other Solid Fuel Heating Devices) 

The District evaluated the requirements contained within Oregon’s rule and found no 

requirements that were more stringent than those already in Rule 4901. 

 Yolo-Solano AQMD Rule 2.40 (Wood Burning Appliances) 

The District evaluated the requirements contained within Rule 2.40 and found no 

requirements that were more stringent than those already in Rule 4901. 

Additional Emission Reduction Opportunities 

2014 Amendments to the District’s Residential Wood Burning Program 

The District takes a multidimensional and proactive approach to reducing emissions in 

the Valley. This philosophy is especially true for reducing emissions from residential 

wood burning with a combination of regulatory controls through Rule 4901, public 

outreach and education, and the District’s Burn Cleaner Wood Stove Change-out 

Program (Burn Cleaner Program). The District’s approach to reducing emissions from 

residential wood burning empowers Valley residents to play a major role in reducing 

emissions at almost no cost, and, in many cases, with savings in heating-related energy 

costs. Valley residents are encouraged to transition from older more polluting wood 

burning heaters and wood burning fireplaces (also commonly called open hearth 

fireplaces) to cleaner alternatives, by decreasing the number of allowable burn days for 

high polluting wood burning heaters and fireplaces while at the same time increasing 

the number of burn days allowed for registered clean wood burning heaters through a 

tiered episodic wood burning curtailment program. Emissions reduced through the 

2014 amendments to the program are significantly greater than those achieved by 

reducing the curtailment threshold alone. 

Curtailment Level 

A potential opportunity for further emissions reductions was to lower the curtailment 

level, which would reduce emissions by increasing the number of “No Burn” days. 

Lowering the curtailment level below the 30 μg/m3

 level has reduced the build-up of 

emissions during the long stagnation periods experienced in the Valley during the 2014-

15 winter season, and helped avoid exceedances of the PM2.5 standard. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

During the September 2014 rule amendment project, the District estimated the average 

number of additional No Burn days likely to occur in future years as a result of lowering 

the curtailment level from the previous threshold level of 30 μg/m3 to the threshold level 

of 20 μg/m3. The average increase in No Burn days in future years in each county was 

calculated by averaging the historical data from the past five wood burning seasons of 

the number of days P M2.5 concentrations were forecasted to be equal to or exceed 30 

μg/m3 versus 20 μg/m3. This analysis is summarized in the table below. The estimated 

average increase in No Burn days in future years was determined to be 34 days per 

county (an average of the last column in the table below) per wood burning season. 

However, the estimation of 34 additional No Burn days per wood burning season in the 

future will vary. No Burn days are called based on the air quality forecast for each day 

and are dependent on several variables. As a result of this analysis, the District 

amended Rule 4901 to lower the curtailment threshold to 20 μg/m3

 in September 2014. 

Table C-32 Average Number of Days Forecast Above Curtailment Thresholds* 

County 

Previous 

Threshold (≥30 

μg/m3) 

2014 Adopted 

Threshold 

(≥20 μg/m3) 

Additional 

No Burn 

days 

San Joaquin 24 53 29 

Stanislaus 36 72 36 

Merced 19 55 36 

Madera 29 67 38 

Fresno 49 85 36 

Kings 39 70 31 

Tulare 36 69 33 

Kern 44 79 35 

*Based on Forecast values from the 2009-10, 2010-11, 2011-12, 2012-13, 2013-14 wood-burning seasons

Although a No Burn day can potentially increase a resident’s natural gas costs from 

using a central heating system in lieu of a wood burning heater, this potential cost is 

offset by the central heating system since a central heating system more efficiently 

heats the whole home, resulting in less money being spent on firewood based on the 

increase in No Burn days. Compared to other District rules, curtailing residential wood 

burning under Rule 4901 is the most cost effective rule for reducing directly emitted 

PM2.5 emissions. 

Wood Burning Season 

During the 2014 amendment, the District evaluated the potential opportunity for further 

reducing emissions from the residential wood burning source category by extending the 

wood burning curtailment season. The current wood-burning season runs from the 

beginning of November until the end of February. Expanding the wood-burning season 

to include October and/or March could have potentially increased the number of No 

Burn days in each wood-burning season. 

Measured Valley concentrations of levoglucosan, a primary indicator for wood burning, 

are not nearly as high in October or March as found to be during the current wood 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

burning season of November through February. Additionally, a six-year average was 

calculated for the number of No Burn days in each county from 2008 through 2013 for 

the months of October and March as illustrated in the following table. The resulting 

estimated number of increased No Burn days based on historical data is in the range of 

less than one day up to six days. Extending the wood burning season would not 

significantly benefit air quality in the Valley due to the combination of less extensive 

burning activity and the minute number of additional No Burn days. 

Table C-33 Days with PM2.5 ≥ 30μg/m3

County Month 2008 2009 2010 2011 2012 2013 Average 

Fresno March 3 0 0 0 0 0 0.5 

Kern March 2 0 0 1 0 2 0.8 

Kings March 1 0 1 0 0 4 1 

Madera March NA NA NA 0 0 0 0 

Merced March 0 0 0 0 0 0 0 

San Joaquin March 0 0 0 0 0 0 0 

Stanislaus March 0 0 0 0 0 0 0 

Tulare March 2 0 0 0 0 3 0.8 

 

Fresno October 6 2 2 7 1 1 3.2 

Kern October 6 6 3 3 2 NA 4 

Kings October 10 9 7 10 2 1 6.5 

Madera October NA NA NA 3 0 0 1 

Merced October 3 0 2 0 0 0 0.8 

San Joaquin October 2 0 0 0 0 0 0.3 

Stanislaus October 5 1 2 5 0 0 2.2 

Tulare October 4 5 1 6 0 3 3.2 

New Residential Developments 

The District also considered further limiting the installation of wood burning fireplaces 

and heaters in new residential developments by strengthening Section 5.3 of Rule 4901, 

which sets limits for the quantity of wood burning fireplaces or wood burning heaters 

that can be installed in new residential developments. South Coast Rule 445 prohibits 

the installation of wood burning devices in any development that has natural gas 

service. However, since most of the Valley’s new developments are already subject to 

restrictions based on their housing densities, the emissions reduction potential is 

minimal. 

As a part of the 2014 amendments to Rule 4901, the District amended Section 5.3. 

Previous rule language was not completely clear as to the number of heaters allowed to 

be installed if that number falls between two whole numbers. The rule language was 

strengthened by clarifying the number of heaters allowed for installation in a given area, 

in addition to the language being clarified with regards to the applicability of the density 

requirements by the removal of the term “new” from rule language. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

Section 5.3.1 (Effective until December 31, 2014) 

Previous language provided for: 

 5.3.1.1: >2 dwellings/acre: no wood burning fireplaces 

 5.3.1.2: ≥3 dwellings/acre: max of two certified units 

 5.3.1.3: ≤2 dwellings/acre: max of one wood burning fireplace or wood burning 

heater per dwelling 

Figure C-7 Illustration of Section 5.3.1 Requirements 

Density/ 

Acre 0 1 2 3 

Section 5.3.2 (Effective on and after January 1, 2015) 

Amended language provides for: 

 5.3.2.1: >2 dwellings/acre: no wood burning fireplaces 

 5.3.2.2: >2 dwellings/acre: max of two certified units 

 5.3.2.3: ≤2 dwellings/acre: max of one wood burning fireplace or certified wood 

burning heater per dwelling 

Figure C-8 Illustration of Section 5.3.2 Requirements 

Density/ 

Acre 0 1 2 3 

Section 5.3.2.1 prohibits the installation of a wood burning fireplace in a residential 

development with a density greater than two dwelling units per acre. While this could 

be misinterpreted as being less stringent than a similar requirement in SCAQMD Rule 

445, in reality it is more stringent because Rule 4901 does not afford the same 

flexibilities as the SCAQMD rule does. While SCAQMD Rule 445 has language 

prohibiting the installation of a permanently installed wood burning device into any new 

development, this requirement is not applicable to new developments where there is no 

existing infrastructure for natural gas service within 150 feet of the property line or those 

3,000 or more feet above mean sea level. District Rule 4901 is more stringent in that 

for the extremely limited cases where wood burning devices are allowed to be installed, 

the number of units allowed is limited to no more than two per acre. Additionally, Rule 

4901 does not exempt any homes from any aspect of rule requirements based on 

elevation. 

Encouraging the Transition to Clean Burning Heaters through Non-Regulatory 

Measures 

Upgrading a home’s wood burning device reduces air pollutant emissions on days when 

wood burning is allowed. By operating more efficiently, these devices can also lower 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-164 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

the overall home heating cost. District Rule 4901 neither prohibits nor requires wood 

burning device upgrades. However, the District encourages such upgrades through its 

public outreach and through its Burn Cleaner Program, which provides funding to Valley 

residents to upgrade their current wood-burning devices and open fireplaces to natural 

gas or propane gas devices, to certified wood stoves or inserts, or to pellet devices. 

The District’s webpage84 has more information on program eligibility and qualified 

devices. 

There are several types of wood burning devices and device inserts available. Wood 

stoves, especially newer models, are generally safe and efficient devices for home 

heating. There are two types of wood stoves: catalytic and non-catalytic. EPA’s Phase 

II certified wood stoves produce only 2 to 7 grams of smoke per hour, compared to 15 to 

30 grams of smoke per hour from older, uncertified devices, and in future years the EPA 

certified devices will emit even less. 

Pellet stoves are similar in appearance to wood stoves, but burn compressed pellets 

made of ground, dried wood and other biomass wastes. Pellet stoves are generally 

more expensive than wood stoves and require electricity for operation; however, they 

are typically more efficient than wood stoves due to the better fuel-to-air ratio in the 

combustion chamber. 

Wood burning fireplaces include traditional masonry fireplaces built into brick or stone, 

constructed in the home, and “low mass” fireplaces that are pre-fabricated prior to 

installation. Most fireplaces are not used as a primary source of heat, but serve as a 

secondary heating source or for ambiance. Fireplaces generate much more emissions 

than wood stoves or pellet stoves, but fireplace inserts are available to reduce 

emissions. EPA does not certify fireplaces or fireplace inserts, but does have a 

voluntary program for devices that meet qualifications to be considered cleaner burning 

than typical fireplaces and fireplace inserts. While these devices reduce emissions 

relative to uncontrolled fireplaces, their emissions are still relatively higher than certified 

wood stoves and pellet stoves. 

Gas stoves and gas fireplaces burn natural gas or propane, emit very little air pollution, 

and require little maintenance. Gas devices are not subject to the requirements of Rule 

4901, so they can be used on “No Burn” days. For more information about the various 

types of wood burning devices available, see EPA’s Burn Wise program webpages85. 

The following figure illustrates the average PM2.5 emissions based on various heat 

sources. 

 

84 www.valleyair.org/Grant_Programs/GrantPrograms.htm#WoodStoveChangeOut 85 www.epa.gov/burnwise 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

Figure C-9 Average PM2.5 Emissions Based on Wood Burning Heater Type86

A third party survey of Valley residents (see Appendix E) revealed that the majority of 

Valley residents do not have wood burning heaters or wood burning fireplaces. 

However, of those that do have wood burning heaters and wood burning fireplaces, the 

majority have wood burning fireplaces, refer to Figure C-10 (Proportion of Residents 

with a Wood-Burning Fireplace, Wood Stove or Pellet Stove) for a graphical 

representation of the proportion of Valley residents with wood burning heaters, pelletfueled wood burning heaters, and wood burning fireplaces. 

 

86EPA. (2012, November 14). Consumers – Energy Efficiency and Wood-Burning Stoves and Fireplaces. Retrieved 

from http://www.epa.gov/burnwise/energyefficiency.html. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

Figure C-10 Proportion of Residents with a Wood-Burning Fireplace, 

Wood Stove or Pellet Stove 

EPA reports that 75% of wood stoves (also called wood burning heaters) in the United 

States are non EPA-certified stoves. EPA certified wood burning heaters produce 70% 

less particle pollution then their older dirtier counterparts. 

Survey results indicate the most effective ways to encourage transition to clean burning 

heaters is to allow more wood burning days for less polluting wood burning heaters and 

update the District’s Burn Cleaner Program to increase incentive amounts. By 

encouraging Valley residents to transition to clean wood burning heaters, emissions will 

not only be reduced on No Burn days but also on days when burning is allowed. This 

health and air quality benefit will occur because cleaner alternatives such as EPA 

Phase II Certified wood burning heaters and pellet-fueled wood burning heaters, and 

gaseous-fueled heaters will be in use instead of the older more polluting wood burning 

heaters and wood burning fireplaces. 

Many Valley residents have upgraded their homes with these newer devices, including 

through programs such as the District’s Burn Cleaner Program and federal tax 

incentives. Given their much lower relative emissions, allowed use of these devices 

during a lower curtailment level still achieves the goal of significantly reducing the 

overall emissions that ultimately lead to violations of the standard. Enforcing this added 

flexibility is difficult given the challenge in distinguishing wood smoke emissions from 

various wood burning devices, and the District explored various options during the rule 

development process for ensuring that this issue is addressed. Along with this 

allowance, the District will continue to provide incentives to encourage the replacement 

of existing older devices with newer clean devices. 

No Wood-Burning 

Device, 68%

Pellet Stove, 3%

Wood Stove, 4%

Wood-Burning 

Fireplace, 25%
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 2015 Plan for the 1997 PM2.5 Standard 

Burn Cleaner Incentive Program 

The District’s Burn Cleaner Wood Stove Change-out Program (Burn Cleaner Program) 

plays a key role in the success of the transition from older more polluting wood burning 

heaters and fireplaces to cleaner wood burning heaters. Since 2006, the Burn Cleaner 

Program has been helping residents overcome some of the financial obstacles in 

purchasing cleaner alternatives. There are currently more than 30 hearth retailers in the 

Valley that have partnered with the District to successfully implement the Burn Cleaner 

Program. 

The Burn Cleaner Program offers multiple levels of incentive funding, increased as of 

the 2014-2015 wood burning season: 

 Up to $1,000 to replace a qualifying unit with a certified wood insert/freestanding 

stove, certified pellet insert/freestanding stove, or natural gas insert/freestanding 

stove 

 Up to $2,500 of any eligible device if the applicant is eligible for Low-Income 

 Up to $500 as an additional incentive towards gas devices (for both standard and 

low-income) 

The District continuously reevaluates the Burn Cleaner Program and implements 

enhancements to the program. In addition to increased incentive amounts, the District 

has also recently implemented the following enhancements: 

 Reducing a substantial portion of the upfront, out-of-pocket cost of a new 

qualifying unit for low-income qualified applicants. The District has partnered 

with contracted hearth retailers to allow low-income qualified applicants to make 

the purchase at a reduced price by deducting the incentive amount from the 

invoice at the point of purchase. Allowing the incentive funding to be directly 

applied when purchase is made makes it more feasible for additional low-income 

applicants to take advantage of the program. 

 Refining the low-income eligibility form to streamline the determination process 

and identifying the hearth retailers that provide the reduced upfront cost option. 

 Program documents are now available in Spanish to further extend the outreach 

efforts to the local community. 

 Updates to program documents to make them more user-friendly and to improve 

the process during the application, installation, and claim for payment request 

phases. 

 The document submittal process has been updated to allow applications and 

claim for payment requests to now be emailed to the District for faster 

processing. Also, supplemental forms have been developed further streamline 

the review process and help keep the retailers and applicants informed on the 

status of projects. 

The upgrades to processing, applications, and incentive amounts, combined with 

effective and proactive public outreach and education campaign and the assistance of 

District retail partners, the initial funding for the Burn Cleaner Program was quickly 
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 2015 Plan for the 1997 PM2.5 Standard 

exhausted. At the November 13, 2014 Governing Board meeting, the District Governing 

Board approved an additional $2 million in funding to meet the increased demand for 

this highly successful program. Immediately after the November Board meeting, District 

staff worked expeditiously to ensure that the additional funding was allocated quickly 

and efficiently to the residents in the Valley. Given this program’s critical role in 

supporting the District’s efforts to reduce the impact of residential wood burning and 

continued high demand in the program the District went back to the Governing Board at 

the December 18, 2014 public hearing to request additional funding and other 

amendments to the program, and an additional $3.6 million in funding was allocated 

along with programmatic changes proposed by staff including lowering the voucher 

incentive amount for non-low income applicants from the then $1,500 to $1,000, limiting 

the number of vouchers per household, and directing funding based upon demand for 

any surplus remaining in each county. 

Collaboration with participating hearth retailers

The District has renewed its contracts with the hearth retailers and hosted informational 

meetings to discuss program changes in order to ensure a smooth roll out of the 

enhancements. As part of the District’s initiative to increase the effectiveness of the 

program, District staff has worked closely with the participating hearth retailers on 

outreach efforts and provided them with promotional tools, such as flyers and quick 

screens with information about the Burn Cleaner Program. 

Public Outreach and Education 

The District has an extremely successful outreach and education program with regards 

to residential wood burning and educating Valley residents about air quality, the effects 

of air pollution on the population’s health, and on options they can take to reduce 

emissions. In the 2013-14 wood-burning season the District took part in 51 media 

interviews about extreme weather and wood burning. 

The District’s informational Check Before You Burn program minimizes elevated PM2.5 

concentrations throughout the winter. The PM2.5 air quality improvements that the 

Valley has experienced since the adoption of Rule 4901 have been assisted by strong 

multimedia outreach by the District and a resultant increase in public awareness and 

participation in winter District programs. 

During the wood-burning season of 2013-14, the District Outreach staff received 

hundreds of public calls and emails specific to residential wood burning. An interesting 

new trend has surfaced regarding public opinion, an increased number of the phone 

calls were in support of an outright ban on residential wood burning year-round (with the 

exception of residents for whom wood burning is the sole source of heat). This is 

attributed to heightened awareness among the general population of the deleterious 

effects of wood burning on public health. 

Since the inception of Check Before You Burn, the District’s complementary tools, such 

as the Real-time Air Advisory Network (RAAN) and the “Valley Air” smart phone app, 

have continued to gain in popularity. Annual public call and website “hit” statistics, plus 

growth in the District’s Facebook page activity, also illustrate continued growth in wood-
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 2015 Plan for the 1997 PM2.5 Standard 

burning awareness. Survey results also showed an increased public awareness with 

eight out of ten respondents being aware of the District’s Check Before You Burn

program, 78% of whom confirmed reduced wood-burning activities as a direct result of 

the program. 

The District also incorporates wood-burning messaging into other public outreach 

products, including Healthy Air Living Schools materials, “Blue Sky, Brown Sky ... It’s 

Up to You!” elementary curriculum and other materials. 

Multimedia Advertising Campaign 

The District’s seasonal public outreach advertising campaign is retooled each year to 

include timely and relevant messaging. In the past few seasons, this messaging has 

been delivered by the District’s Governing Board members, with billboards in English 

and Spanish strategically placed throughout the Valley, radio and TV spots, and valueadded messaging delivered through media throughout the Valley. 

Expanding New Media Outreach 

The most significant evolution of Check Before You Burn messaging has occurred with 

the expanded and accelerated use of new media: Facebook and Twitter posts. 

Facebook “likes” have nearly doubled from the 2012-13 season, to more than 1,100 at 

the end of the 2013-14 season. This has proven to be a valuable way to deliver 

immediate messaging regarding wood-burning statuses, in addition to providing a 

platform for direct, two-way interaction with the public. 

Strengthening Media Partnerships 

The District maintains partnerships with television, newspaper, radio, outdoor and print, 

as well as more non-traditional media, such as on-screen messaging in local movie 

theaters, internet advertising and video loops in medical offices. During seasonal 

Check Before You Burn campaigns, the District runs media on 11 broadcast television 

stations in the Fresno and Bakersfield markets, including four Spanish stations, as well 

as 10 cable networks in four cable markets including zoned cable in Stockton, Modesto, 

Turlock and Manteca. In the Sacramento market, which includes the District’s northern 

counties, the wood-burning message runs on two English language broadcast television 

stations and one Spanish language broadcast television station. 

The District also typically runs messaging on 42 radio stations and 18 newspapers (six 

of them Spanish) throughout the eight-county area. Check Before You Burn outdoor 

messaging appears on more than 100 outdoor billboards (including large-format vinyl 

billboards) and smaller “one-sheets” in Environmental Justice communities throughout 

the Valley. With these purchases come added value in the form of bonus spots, news 

sponsorships, and extra billboards and overages in outdoor messaging. Outdoor 

messaging is strategically placed in high-traffic areas as well as neighborhood and rural 

communities to ensure a wide reach in those areas where residential wood burning 

might be common. 

The District’s print campaign includes major papers such as the Bakersfield Californian, 

Fresno and Modesto Bees and Stockton Record, but also rural newspapers such as the 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

Arvin Tiller, Manteca Bulletin and Shafter Press. The District also appears in each issue 

of the Bakersfield Business Journal, which offers the opportunity to promote seasonal 

campaigns. Media buys allow leveraging buying power that typically returns an 

additional $100,000+ in media placement. The related Cinemedia campaign is also 

regularly featured on 100 movie screens from Stockton to Bakersfield, with more than 

25,000 spots that reach more than 475,000 people. 

Evaluation Findings

Even though wood burning fireplaces and wood burning heaters are not a significant 

source of NOx or SOx in the Valley, the District has evaluated all potential control 

technologies and all control technologies achieved in practice in other areas or included 

in other state implementation plans. As demonstrated above, Rule 4901 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 this source category. As the 

District continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from wood burning fireplaces and wood burning 

heaters in the Valley. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-171 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.21 RULE 4902 RESIDENTIAL WATER HEATERS 

Discussion 

Rule 4902 is a point-of-sale rule, adopted on July 17, 1993, to limit NOx emissions from 

natural gas-fired residential water heaters with heat input rates less than or equal to 

75,000 Btu/hr. The original rule enforced a NOx emissions limit of 40 nanograms of 

NOx per Joule of heat output (ng/J). Since its adoption, the rule has been amended 

once. The March 2009 amendments strengthened the rule by enforcing a limit of 10 

ng/J for new or replacement water heaters and a limit of 14 ng/J for instantaneous water 

heaters. NOx emissions have been controlled by approximately 88% for this source 

category. EPA finalized approval for Rule 4902 on May 5, 2010. 

Source Category 

As a point-of-sale rule, Rule 4902 affects water heater manufacturers, plumbing 

wholesalers, retail home supply stores, plumbers and contractors, and homeowners. 

This source category encompasses several types of water heaters, including conventional 

storage water heaters, demand water heaters, heat pump water heaters, solar water 

heaters, and tankless coil and indirect water heaters. Water heater options also vary by 

fuel type which includes electricity, fuel oil, geothermal energy, natural gas, propane, and 

solar energy. 

Conventional storage water heaters are the most common. They have an insulated tank 

sized from 20 to 80 gallons and natural gas fired units have a gas burner under the tank 

regulated by a thermostat. Demand water heaters, also known as instantaneous water 

heaters, heat water as it is required and do not use a storage tank. As soon as there is a 

demand for hot water, a gas burner heats cold water as it travels through a pipe in the unit. 

Natural gas fired units provide hot water at a rate upwards of 5 gallons per minute. 

A tankless coil water heater heats water flowing through a heat exchanger installed in a 

furnace or boiler. Similar to the tankless coil water heater an indirect water heater uses 

a furnace or boiler. Fluid heated by the furnace or boiler is circulated through a heat 

exchanger in a storage tank. 

Manufacturers have focused on combustion modification to meet the lower NOx limit as 

required in other California air districts. Combustion modification systems are designed to 

reduce thermal NOx formation by changing the flame characteristics to reduce peak flame 

temperature. Combustion modification for residential water heaters is achieved by 

different burner designs such as low NOx and ultra-low NOx burners. Some of the design 

principles used in low NOx and ultra-low NOx burners include staged air burners, staged 

fuel burners, pre-mix burners, internal recirculation, and radiant burners. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-172 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.21 0.21 0.21 0.22 0.22 0.22 0.22 0.23 0.23 

NOx 2.21 2.19 2.17 2.16 2.14 2.12 2.11 2.09 2.08 

SOx 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 

Winter Average - Tons per day 

PM2.5 0.28 0.28 0.29 0.29 0.29 0.30 0.30 0.31 0.28 

NOx 2.91 2.89 2.87 2.84 2.82 2.80 2.78 2.77 2.91 

SOx 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.09 0.08 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from residential water heaters are lower than the 

BACM/MSM significance thresholds. Therefore, the Clean Air Act does not require a 

control measure evaluation for this source category for the purpose of satisfying 

BACM/MSM requirements; however, the District has still conducted a full control 

measure evaluation for residential water heaters. 

How does District Rule 4902 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 4902 compare to rules in other air districts? 

SCAQMD 

 Rule 1121 (Control of Nitrogen Oxides from Residential Type, Natural Gas-Fired 

Water Heaters) 

The District evaluated the requirements contained within SCAQMD Rule 1121 and 

found no requirements that were more stringent than those already in Rule 4902. 

BAAQMD 

 Regulation 9 Rule 6 (Nitrogen Oxides Emissions from Natural Gas-Fired Boilers and 

Water Heaters) 

The District evaluated the requirements contained within BAAQMD Regulation 9 Rule 6 

and found no requirements that were more stringent than those already in Rule 4902. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-173 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

SMAQMD 

 Rule 414 (Water Heaters, Boilers and Process Heaters Rated Less than 1,000,000 

BTU Per Hour) 

The District evaluated the requirements contained within SMAQMD Rule 414 and found 

no requirements that were more stringent than those already in Rule 4902. 

VCAPCD 

 Rule 74.11 (Natural Gas-Fired Water Heaters) 

The District evaluated the requirements contained within VCAPCD Rule 74.11 and 

found no requirements that were more stringent than those already in Rule 4902. 

Additional Emission Reduction Opportunities 

Units subject to Rule 4902 are fired on PUC quality natural gas, and are inherently lowemitters of SOx and PM2.5 emissions. Given the significant efforts and investments 

already made to reduce emissions from this source category, there are little remaining 

opportunities for obtaining additional emissions reductions. 

Electric Water Heaters 

The District evaluated the potential opportunity to replace natural gas and propane 

water heaters with electric units. A comparison of three water heaters that utilize the 

different fuel types with an emissions reductions and cost effectiveness analysis for 

these units is summarized below. 

Table C-34 Emissions Reductions and Cost Effectiveness of Water Heaters by 

Fuel Type 

Fuel Type Low NOx Propane Electricity Natural Gas 

Capacity1 50 gallons 50 gallons 50 gallons 

Shipping Weight1 180 lbs 151 lbs 109 lbs 

Energy Factor1 0.62 0.59 0.91 

Purchase Price1 $902.00 $899.00 $473.25 

Estimated Life 

Expectancy2 13 years 13 years 13 years 

Lifetime Energy Use2 3,133 therms 2,867 gallons of 

LP 62,439 kWh 

Lifetime Energy Costs3 $3,568 $7,176 $9,834 

Lifetime NOx 

Emissions4 30.60 lbs 48.09 lbs 0.00 lbs 

Annual NOx Emissions 2.35 lbs 3.70 lbs 0.00 lbs 

Comparing Natural Gas and Propane to Electricity 

Annualized capital N/A 

cost5 $76.99 $76.99 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

Fuel Type Low NOx Propane Electricity Natural Gas 

Annual Operating Cost 

Savings Compared to 

Electric 

$482.00 $204.46 

Cost per pound NOx $237.87 $76.07 

Cost per ton NOx $475,736 $152,135 

1

 Unit specifications and prices acquired from Grainger Industrial Supply as of August 7, 2012 2

 Data from US Department of Energy – Energy Cost Calculator for Electric and Gas Water Heaters 

http://www1.eere.energy.gov/femp/technologies/eep_waterheaters_calc.html 3

 Cost data based on the average cost of units of energy in 2010 according to the US Energy Information 

Administration. http://www.eia.gov/ 

4

 Emissions factors derived from Appendix EA-1 of US Department of Energy’s Energy Assessment for Proposed 

Energy Conservation Standards for Residential Clothes Washers 5

 The annualized capital equipment cost is calculated by multiplying the installed equipment cost by the capital 

recovery factor of 0.1627. 

The operating cost for electric water heaters is higher than for propane and natural gas 

units, due to the higher cost of electricity compared to propane and natural gas. 

However, the initial purchase price is lower for electric units. Converting to an electric 

water heater also may require modifications to the residence and have associated 

costs. 

Evaluation Findings

Although residential water heaters are not a significant source of PM2.5, NOx, or SOx in 

the Valley, the District has evaluated all potential control technologies and all control 

technologies achieved in practice in other areas or included in other state 

implementation plans. As demonstrated above, Rule 4902 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 this source category. As the District 

continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from residential water heaters in the Valley. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-175 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.22 RULE 4905 NATURAL GAS-FIRED, FAN-TYPE CENTRAL FURNACES 

Discussion 

Rule 4905 is a point-of-sale rule that applies to any person who sells, offers for sale, 

installs or solicits the installation of natural-gas-fired, fan-type central furnaces, for use 

within the Valley with a rated heat input capacity of less than 175,000 Btu/hour, and for 

combination heating and cooling units with a rated cooling capacity of less than 65,000 

Btu/hour. 

 

The rule was adopted on October 20, 2005 to establish NOx limits for residential central 

furnaces supplied, sold, or installed in the Valley. The rule set a NOx emission limit of 

0.093 pounds per million Btu of heat output (lb/MMBtu). EPA finalized approval for Rule 

4905 on May 30, 2007. Rule 4905 was amended on January 22, 2015 to: 

 Lower the NOx emission limit for residential units from 40 ng/J (0.093 lb/MMBtu) 

to 14 ng/J 

 Expand the rule applicability to include non-residential units with a NOx emission 

limit of 14 ng/J and units installed in manufactured homes with a NOx limit of 40 

ng/J, to be lowered to 14 ng/J in 2018 

 Additional labeling requirements 

The January 2015 amendments exceeded SCAQMD Rule 1111 requirements and 

made Rule 4905 the most stringent rule in the nation for this source category. 

Source Category 

Affected parties include furnace manufacturers, residential heating wholesalers, supply 

stores, contractors and end-users. The point-of-sale approach has allowed the District 

to achieve NOx reductions without placing an undue financial burden on the residents, 

operators and businesses that sell these units in the Valley. 

Applicable units are used in approximately 71% of Valley residences and are not 

labeled for retail as “residential” or “commercial” furnaces. Units used in commercial 

buildings, which are subject to the requirements of Rule 4905 as of the January 2015 

amendments, are essentially the same as residential units with the exception of 

possible differences in usage patterns and indoor/outdoor location. Research for the 

analyses in the January 2015 amendments estimated 1,252,190 residential and 

commercial units will be operating in the Valley in 2017. Replacement will occur 

gradually as these units reach the end of the 20-year useful life. 

The most common residential and commercial heat sources are boilers and furnaces; 

other heating options include heat pumps, active solar heating, electric heating, wood or 

pellet stoves, portable and direct vent wall heaters, and fireplaces.87 Heat distribution 

systems are either central heating, where heat is generated in a central location and 

 

87 Department of Energy. (2013, December 16). Energy Saver 101: Everything You Need to Know About Home 

Heating. Retrieved 12/17/13 from http://energy.gov/articles/energy-saver-101-infographic-home-heating. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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distributed throughout the building, or point-of-use or space heating, meaning 

supplemental heat is provided to a specific room. Types of central heating systems 

include forced air, steam radiant, radiant, hot water baseboards, and electric 

baseboards. Types of space heaters include wood or pellet stoves, portable and direct 

vent wall heaters, and fireplaces. Fuel types include natural gas, propane, heating oil, 

electricity, and solid fuels such as wood or pellets. 

All heating systems have three basic components: a heat source, a heat distribution 

system, and a control system. The control system is usually a programmable 

thermostat. The heat source, which generally determines the type of distribution system 

used, is selected based on many factors. The most important factor is geographical 

location, which determines the climate and types of available fuel. Most commercial 

and residential buildings in the Valley have access to natural gas, which is typically the 

cheapest and most convenient fuel source in areas where it is available. 

Rule 4905 applies to furnaces fueled by natural gas that use forced air distribution, the 

most common type of heating system for residential and commercial buildings. Central 

furnaces are controlled by a thermostat, which sends signals to turn the device on or off 

when the building temperature does not match a chosen set point. A valve then opens 

to send natural gas to the burners, which combust the gas directly into the heat 

exchangers. A blower pulls air from outside the building through a filter, across the heat 

exchanger, and through a series of ducts and vents to different areas of the building. 

Exhaust from the combustion exits the building through a separate duct. Condensing 

units use an additional heat exchanger to extract the latent heat in the flue (exhaust) 

gas by cooling the combustion gasses to near ambient temperature and thereby 

increase the heating efficiency by up to 10%. The water vapor in the flue gas is 

condensed, collected, and drained. 

Units installed in manufactured homes utilize the same types of materials and operating 

principles as commercial and residential units; however, significant differences exist. 

Furnaces installed in manufactured homes use sealed combustion, meaning all of the 

combustion air is taken from outside the building. These units also pre-heat the air, 

typically to 50-60°F, using a concentric vent where the combustion air is drawn in 

through the outer ring, while exhaust gases are vented through the inside core of the 

vent pipe. The air is pre-heated because the cold outside air does not mix well with the 

fuel, while pre-heated air blends well and allows for quieter ignition and combustion. 

Furnaces installed in manufactured homes also have to comply with strict space 

restrictions.88 

 

88 U.S. Department of Energy. (2014, July 7). Energy Conservation Program for Consumer Products: Energy 

Conservation Standards for Residential Furnace Fans. Retrieved 9/23/14 from 

https://www.federalregister.gov/articles/2014/07/03/2014-15387/energy-conservation-program-for-consumerproducts-energy-conservation-standards-for-residential. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.20 0.20 0.20 0.21 0.21 0.21 0.21 0.22 0.22 

NOx 2.46 2.49 2.52 2.55 2.58 2.61 2.64 2.68 2.72 

SOx 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 0.06 

Winter Average - Tons per day 

PM2.5 0.27 0.27 0.27 0.27 0.28 0.28 0.28 0.29 0.27 

NOx 3.28 3.31 3.35 3.39 3.43 3.47 3.51 3.56 3.28 

SOx 0.07 0.08 0.08 0.08 0.08 0.08 0.08 0.08 0.07 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from natural gas-fired, fan-type central furnaces are lower 

than the BACM/MSM significance thresholds. Therefore, the Clean Air Act does not 

require a control measure evaluation for this source category for the purpose of 

satisfying BACM/MSM requirements; however, the District has still conducted a full 

control measure evaluation for natural gas-fired, fan-type central furnaces. 

How does District Rule 4905 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 4905 compare to rules in other air districts? 

SCAQMD 

 Rule 1111 (Reduction of NOx Emissions from Natural Gas-Fired, Fan-Type Central 

Furnaces) 

The District evaluated the requirements contained within SCAQMD Rule 1111 and 

found no requirements that were more stringent than those already in Rule 4905. 

BAAQMD 

 Regulation 9 Rule 4 (Nitrogen Oxides from Fan Type Residential Central Furnaces) 

The District evaluated the requirements contained within BAAQMD Regulation 9 Rule 4 

and found no requirements that were more stringent than those already in Rule 4905. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

SMAQMD 

 Rule 414 (Water Heaters, Boilers and Process Heaters Rated Less than 1,000,000 

BTU Per Hour) 

The District evaluated the requirements contained within SMAQMD Rule 414 and found 

no requirements that were more stringent than those already in Rule 4905. 

VCAPCD 

 Rule 74.22 (Natural Gas-Fired, Fan-Type Central Furnaces) 

The District evaluated the requirements contained within VCAPCD Rule 74.22 and 

found no requirements that were more stringent than those already in Rule 4905. 

 

Evaluation Findings

Even though natural gas-fired, fan-type central furnaces are not a significant source of 

PM2.5, NOx, or SOx in the Valley, the District has evaluated all potential control 

technologies and all control technologies achieved in practice in other areas or included 

in other state implementation plans. As demonstrated above, Rule 4905 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 this source category. As the 

District continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from natural gas-fired, fan-type central furnaces in the 

Valley. 

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

C-179 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.23 RULE 8011 GENERAL REQUIREMENTS 

Discussion 

The provisions of Rule 8011 are applicable to specified outdoor fugitive dust sources. 

The definitions, exemptions, requirements, administrative requirements, recordkeeping 

requirements, and test methods set forth in this rule are applicable to all rules under 

District Regulation VIII (Fugitive PM10 Prohibitions). The Regulation VIII series was 

adopted in November 2001, and subsequently amended in 2004. The rules were 

developed pursuant to EPA guidelines for serious PM10 nonattainment areas. In 2004, 

the District adopted amendments to Regulation VIII to upgrade existing RACM level 

rules to meet the more stringent BACM level required in serious PM10 nonattainment 

areas. 

Emissions Inventory 

There is no specific emissions inventory associated with Rule 8011. 

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 N/A N/A N/A N/A N/A N/A N/A N/A N/A

NOx N/A N/A N/A N/A N/A N/A N/A N/A N/A

SOx N/A N/A N/A N/A N/A N/A N/A N/A N/A

Winter Average - Tons per day 

PM2.5 N/A N/A N/A N/A N/A N/A N/A N/A N/A

NOx N/A N/A N/A N/A N/A N/A N/A N/A N/A

SOx N/A N/A N/A N/A N/A N/A N/A N/A N/A

How does District Rule 8011 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT guidelines for this source 

category. The following federal regulations apply to sources covered under Rule 8011: 

 Rule 57 FR 13498 (General Preamble for Title I of CAA) 

The District evaluated the requirements contained within the General Preamble and 

found no requirements that were more stringent than those already in Rule 8011. 

 EPA-450/2-92-004 (Fugitive Dust Background Document and Technical 

Information Document for Best Available Control Measures (BACM)) 

The District evaluated the requirements contained within the Fugitive Dust Background 

Document and Technical Information Document for BACM and found no requirements 

that were more stringent than those already in Rule 8011. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-180 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 8011 compare to rules in other air districts? 

There are no analogous rules for this source category in BAAQMD. 

SCAQMD 

 Rule 1156 (Further Reductions of Particulate Emissions from Cement Manufacturing 

Facilities) 

The District evaluated the requirements contained within SCAQMD Rule 1156 and 

found no requirements that were more stringent than those already in Rule 8011. 

 Rule 1157 (PM10 Emission Reductions form Aggregate and Related Operations) 

The District evaluated the requirements contained within SCAQMD 1157 and found no 

requirements that were more stringent than those already in Rule 8011. 

SMAQMD 

 Rule 403 (Fugitive Dust)

The District evaluated the requirements contained within SMAQMD Rule 403 and found 

no requirements that were more stringent than those already in Rule 8011. 

VCAPCD 

 Rule 55 (Fugitive Dust) 

The District evaluated the requirements contained within VCAPCD Rule 55 and found 

no requirements that were more stringent than those already in Rule 8011. 

Clark County Department of Air Quality (CCDAQ) 

 Section 41 (Fugitive Dust) 

The District evaluated the requirements contained within CCDAQ Section 41 and found 

no requirements that were more stringent than those already in Rule 8011. 

Additional Emission Reduction Opportunities 

This rule is administrative in nature, and is intended to be a supplementary rule to the 

other District Regulation VIII rules. Opportunities for emission reductions would be 

found with each of the other Regulation VIII rules and would not be identified as a 

possibility for this rule. As such, there are no emission reduction opportunities for Rule 

8011. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

Evaluation Findings

The District has evaluated all potential requirements achieved in practice in other areas 

or included in other state implementation plans. As demonstrated above, Rule 8011 

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 this source 

category. As the District continues to develop new attainment plans that address more 

stringent National Ambient Air Quality Standards, the District will continue to evaluate 

potential opportunities to reduce emissions from outdoor fugitive dust sources in the 

Valley. 

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

C-182 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.24 RULE 8021 CONSTRUCTION, DEMOLITION, EXCAVATION, EXTRACTION, 

AND OTHER EARTHMOVING ACTIVITIES 

Discussion 

Rule 8021 applies to construction or demolition related disturbances of soil, including 

land clearing, grubbing, scraping, excavation, extraction, land leveling, grading, cut and 

fill operations, travel on the site, travel access roads to and from the site, and demolition 

activities. The rule also applies to construction of new landfill disposal sites or 

modifications to existing landfill disposal sites prior to commencement of landfilling 

activities. 

In 2004, the District adopted amendments to Regulation VIII to upgrade existing RACM 

level rules to meet the more stringent BACM level required in serious PM10 

nonattainment areas. Rule 8021 was amended to add dust suppression requirements, 

and to require submittal of Dust Control Plans on residential construction sites 10.0 

acres or more in size and on non-residential construction sites 5.0 acres or more in size. 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 1.46 1.47 1.48 1.48 1.49 1.50 1.51 1.52 1.53 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Winter Average - Tons per day 

PM2.5 1.34 1.34 1.35 1.36 1.37 1.38 1.39 1.39 1.40 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 4.0 tons per 

day (tpd) for PM2.5 dust, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in the 

above table, emissions from construction, demolition, excavation, extraction, and other 

earthmoving activities are lower than the BACM/MSM significance thresholds. 

Therefore, the Clean Air Act does not require a control measure evaluation for this 

source category for the purpose of satisfying BACM/MSM requirements; however, the 

District has still conducted a full control measure evaluation for construction, demolition, 

excavation, extraction, and other earthmoving activities. 

While District Regulation VIII was critical in the District’s attainment of the PM10 

standards, a variety of studies have been conducted which may indicate that the PM2.5 

fraction of the PM emissions from this source category 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 under Rule 8021 and to 

indicate the level of significance of those PM2.5 emissions. At this time, PM2.5 

emission control factors are not well defined and it is not known if PM10 controls are 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

effective for reducing PM2.5 for earthmoving activities. Modeling results show that the 

geologic fraction of PM2.5 found in the Valley makes a relatively small contribution to 

overall PM2.5 mass. In addition, studies have shown that geologic dust alone has 

relatively low toxicity. 

How does District Rule 8021 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. The following federal regulations apply to sources covered under Rule 8021: 

 Rule 57 FR 13498 (General Preamble for Title I of CAA) 

The District evaluated the requirements contained within the General Preamble and 

found no requirements that were more stringent than those already in Rule 8021. 

 EPA-450/2-92-004 (Fugitive Dust Background Document and Technical Information 

Document for BACM) 

The District evaluated the requirements contained within the Fugitive Dust Background 

Document and Technical Information Document for BACM and found no requirements 

that were more stringent than those already in Rule 8021. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 8021 compare to rules in other air districts? 

There are no analogous rules for this source category in BAAQMD. 

SCAQMD 

 Rule 1156 (Further Reductions of Particulate Emissions from Cement Manufacturing 

Facilities) 

The District evaluated the requirements contained within SCAQMD Rule 1156 and 

found no requirements that were more stringent than those already in Rule 8021. 

 Rule 1157 (PM10 Emission Reductions form Aggregate and Related Operations) 

The District evaluated the requirements contained within SCAQMD Rule 1157 and 

found no requirements that were more stringent than those already in Rule 8021. 

SMAQMD 

 Rule 403 (Fugitive Dust)

The District evaluated the requirements contained within SMAQMD Rule 403 and found 

no requirements that were more stringent than those already in Rule 8021. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-184 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

VCAPCD 

 Rule 55 (Fugitive Dust) 

The District evaluated the requirements contained within VCAPCD Rule 55 and found 

no requirements that were more stringent than those already in Rule 8021. 

Clark County Department of Air Quality (CCDAQ) 

 Section 94 (Permitting and Dust Control for Construction Activities) 

The District evaluated the requirements contained within CCDAQ Section 94 and found 

no requirements that were more stringent than those already in Rule 8021. 

Additional Emission Reduction Opportunities 

District analysis identified one potential opportunity for this source category; to require 

signs to be posted at certain size work sites, asking the public to contact the District if 

the work site is producing significant dust emissions. While this potential opportunity 

would increase the awareness of the workers and the public, there is no conclusion that 

it would result in reduced emissions. If emissions are reduced, it is not likely to result in 

quantifiable emission reductions. 

Evaluation Findings

Even though construction, demolition, excavation, extraction, and other earthmoving 

activities are not a significant source of PM2.5, NOx, or SOx in the Valley, the District 

has evaluated all potential control technologies and all control technologies achieved in 

practice in other areas or included in other state implementation plans. As 

demonstrated above, Rule 8021 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 this source category. As the District continues to develop new 

attainment plans that address more stringent National Ambient Air Quality Standards, 

the District will continue to evaluate potential opportunities to reduce emissions from 

construction, demolition, excavation, extraction, and other earthmoving activities in the 

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

C-185 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.25 RULE 8031 BULK MATERIALS 

Source Category 

Rule 8031 applies to the outside storage and handling of any unpackaged material, 

which emits or has the potential to emit dust when stored or handled. Rule 8031 

requires bulk handling and storage facilities to restrict dust from material transfer, and 

reduce emissions from transport material and storage piles that emit dust. Facilities 

subject to Rule 8031 are required use control measures to ensure that visible dust 

emissions are limited to 20% opacity or less. These control measures can include 

application of water or other dust stabilizers, covering of bulk materials, construction of 

wind barriers, covering of haul trucks, and other measures. 

In 2004, the District adopted amendments to Regulation VIII to upgrade existing RACM 

level rules to meet the more stringent BACM level required in serious PM10 

nonattainment areas. Rule 8031 was amended to require construction and 

maintenance of wind barriers when handling bulk materials. 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.04 0.04 0.05 0.05 0.05 0.05 0.05 0.05 0.05 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Winter Average - Tons per day 

PM2.5 0.04 0.04 0.05 0.05 0.05 0.05 0.05 0.05 0.05 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 4.0 tons per 

day (tpd) for PM2.5 dust, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in the 

above table, emissions from bulk materials are lower than the BACM/MSM significance 

thresholds. Therefore, the Clean Air Act does not require a control measure evaluation 

for this source category for the purpose of satisfying BACM/MSM requirements; 

however, the District has still conducted a full control measure evaluation for bulk 

materials. 

Also, while District Regulation VIII was critical in the District’s attainment of the PM10 

standards, a variety of studies have been conducted which may indicate that the PM2.5 

fraction of the PM emissions from this source category 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 under Rule 8031 and to 

indicate the level of significance of those PM2.5 emissions. At this time, PM2.5 

emission control factors are not well defined and it is not known if PM10 controls are 

effective for reducing PM2.5 for bulk materials. Modeling results show that the geologic 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-186 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

fraction of PM2.5 found in the Valley makes a relatively small contribution to overall 

PM2.5 mass. In addition, studies have shown that geologic dust alone has a relatively 

low toxicity. 

How does District Rule 8031 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. The following federal regulations apply to sources covered under Rule 8031: 

 Rule 57 FR 13498 (General Preamble for Title I of CAA) 

The District evaluated the requirements contained within the General Preamble and 

found no requirements that were more stringent than those already in Rule 8031. 

 EPA-450/2-92-004 (Fugitive Dust Background Document and Technical Information 

Document for BACM) 

The District evaluated the requirements contained within the Fugitive Dust Background 

Document and Technical Information Document for BACM and found no requirements 

that were more stringent than those already in Rule 8031. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 8031 compare to rules in other air districts? 

There are no analogous rules for this source category in BAAQMD. 

SCAQMD 

 Rule 1156 (Further Reductions of Particulate Emissions from Cement Manufacturing 

Facilities) 

The District evaluated the requirements contained within SCAQMD Rule 1156 and 

found no requirements that were more stringent than those already in Rule 8031. 

 Rule 1157 (PM10 Emission Reductions form Aggregate and Related Operations) 

The District evaluated the requirements contained within SCAQMD Rule 1157 and 

found no requirements that were more stringent than those already in Rule 8031. 

SMAQMD 

 Rule 403 (Fugitive Dust)

The District evaluated the requirements contained within SMAQMD Rule 403 and found 

no requirements that were more stringent than those already in Rule 8031. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-187 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

VCAPCD 

 Rule 55 (Fugitive Dust) 

The District evaluated the requirements contained within VCAPCD Rule 55 and found 

no requirements that were more stringent than those already in Rule 8031. 

Clark County Department of Air Quality (CCDAQ) 

 Section 41 (Fugitive Dust) 

The District evaluated the requirements contained within CCDAQ Section 41 and found 

no requirements that were more stringent than those already in Rule 8031. 

Additional Emission Reduction Opportunities 

Rule 8031 currently employs the best dust mitigation techniques; there are no additional 

potential opportunities for further emissions reductions from this source category. Rule 

8031’s requirement of limiting opacity to 20% is as or more stringent than any other 

district’s rule and compliance with the standard requires significant mitigation efforts 

from sites that store bulk materials. 

Evaluation Findings

Even though storage and handling of bulk materials are not a significant source of 

PM2.5, NOx, or SOx in the Valley, the District has evaluated all potential control 

technologies and all control technologies achieved in practice in other areas or included 

in other state implementation plans. As demonstrated above, Rule 8031 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 this source category. As the 

District continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from bulk materials handling in the Valley. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-188 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.26 RULE 8041 CARRYOUT AND TRACKOUT 

Source Category 

Rule 8041 applies to the prevention and cleanup of mud and dirt whenever it is 

deposited (carryout and trackout) onto public paved roads from activities subject to the 

requirements of Rules 8021, 8031, 8061, and 8071. The rule contains requirements for: 

removing carryout and trackout at the end of each workday; thresholds for any site with 

150 daily vehicle trips; addressing carryout and trackout in Dust Control Plans; 

removing carryout and trackout in urban areas; paved interior roads; and prevention of 

carryout and trackout. 

In 2004, the District adopted amendments to Regulation VIII to upgrade existing RACM 

level rules to meet the more stringent BACM level required in serious PM10 

nonattainment areas. Rule 8041 was amended to require a threshold for vehicles with 

three or more axles to takes actions for carryout/trackout. Amendments included a 

threshold for projects located in rural areas, a provision requiring actions within half an 

hour if specified measures are insufficient to prevent carryout/trackout, and 

specifications for dust collectors, gravel pads, and paved surfaces. 

Emissions Inventory 

The emissions from this source category are included in Rule 8061 (Paved and 

Unpaved Roads). 

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 N/A N/A N/A N/A N/A N/A N/A N/A N/A

NOx N/A N/A N/A N/A N/A N/A N/A N/A N/A

SOx N/A N/A N/A N/A N/A N/A N/A N/A N/A

Winter Average - Tons per day 

PM2.5 N/A N/A N/A N/A N/A N/A N/A N/A N/A

NOx N/A N/A N/A N/A N/A N/A N/A N/A N/A

SOx N/A N/A N/A N/A N/A N/A N/A N/A N/A

While District Regulation VIII was critical in the District’s attainment of the PM10 

standard, a variety of studies have been conducted which may indicate that the PM2.5 

fraction of the PM emissions from this source category 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 under Rule 8041 and to 

indicate the level of significance of those PM2.5 emissions. At this time, PM2.5 

emission control factors are not well defined and it is not known if PM10 controls are 

effective for reducing PM2.5 for carryout and trackout. Modeling results show that the 

geologic fraction of PM2.5 found in the Valley makes a relatively small contribution to 

overall PM2.5 mass. In addition, studies have shown that geologic dust alone has 

relatively low toxicity. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-189 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

How does District Rule 8041 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. The following federal regulations apply to sources covered under Rule 8041: 

 Rule 57 FR 13498 (General Preamble for Title I of CAA) 

The District evaluated the requirements contained within the General Preamble and 

found no requirements that were more stringent than those already in Rule 8041: 

 EPA-450/2-92-004 (Fugitive Dust Background Document and Technical Information 

Document for BACM) 

The District evaluated the requirements contained within the Fugitive Dust Background 

Document and Technical Information Document for BACM and found no requirements 

that were more stringent than those already in Rule 8041. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 8041 compare to rules in other air districts? 

There are no analogous rules for this source category in BAAQMD. 

SCAQMD 

 Rule 1156 (Further Reductions of Particulate Emissions from Cement Manufacturing 

Facilities) 

The District evaluated the requirements contained within SCAQMD Rule 1156 and 

found no requirements that were more stringent than those already in Rule 8041. 

 Rule 1157 (PM10 Emission Reductions form Aggregate and Related Operations) 

The District evaluated the requirements contained within SCAQMD Rule 1157 and 

found no requirements that were more stringent than those already in Rule 8041. 

SMAQMD 

 Rule 403 (Fugitive Dust)

The District evaluated the requirements contained within SMAQMD Rule 403 and found 

no requirements that were more stringent than those already in Rule 8041. 

VCAPCD 

 Rule 55 (Fugitive Dust) 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-190 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

The District evaluated the requirements contained within VCAPCD Rule 55 and found 

no requirements that were more stringent than those already in Rule 8041. 

Clark County Department of Air Quality (CCDAQ) 

 Section 94 (Permitting and Dust Control for Construction Activities) 

The District evaluated the requirements contained within CCDAQ Section 94 and found 

no requirements that were more stringent than those already in Rule 8041. 

Additional Emission Reduction Opportunities 

Two potential opportunities to reduce emissions were identified, evaluated, and 

determined to not be feasible. 

The first potential emission reduction opportunity would be to reduce the threshold for 

daily trips per worksite that requires a carryout and trackout prevention system 

(currently 150 trips). Reducing this threshold would require smaller worksites to install 

costly trackout prevention equipment like wheel washers, metal grates, and gravel pads. 

At these smaller worksites the emission reductions that would be achieved would be 

minimal and not cost effective because of the small size of the sites. 

The second potential opportunity would be to shorten the distance from the nearest 

unpaved exit point of a site at which trackout must be immediately cleaned (currently 50 

feet). Lowering this threshold would significantly increase the use of street sweepers 

and their associated emissions, which are more toxic to human health (see Chapter 3). 

Therefore, this opportunity has been determined to not be feasible. 

Evaluation Findings

The District has evaluated all potential control technologies and all control technologies 

achieved in practice in other areas or included in other state implementation plans. As 

demonstrated above, Rule 8041 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 this source category. As the District continues to develop new 

attainment plans that address more stringent National Ambient Air Quality Standards, 

the District will continue to evaluate potential opportunities to reduce emissions from 

carryout and trackout of mud and dirt onto public paved roads in the Valley. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-191 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.27 RULE 8051 OPEN AREAS 

Source Category 

Rule 8051 applies to any open area 0.5 acres or more within urban areas, or 3.0 acres 

or more within rural areas that contains at least 1,000 square feet of disturbed surface 

area. The rule has requirements for limiting visible dust emissions (VDE) to 20% 

opacity, to comply with the conditions of a stabilized surface, and to install barriers to 

prevent unauthorized vehicles from accessing the stabilized areas. 

In 2004, the District adopted amendments to Regulation VIII that upgraded existing 

RACM level rules to meet the more stringent BACM level required in serious PM10 

nonattainment areas. Rule 8051 was amended to add applicability thresholds for rural 

and urban areas. 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.34 0.34 0.34 0.34 0.34 0.34 0.34 0.34 0.34 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Winter Average - Tons per day 

PM2.5 0.21 0.21 0.21 0.21 0.21 0.21 0.21 0.21 0.21 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 4.0 tons per 

day (tpd) for PM2.5 dust, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in the 

above table, emissions from open areas are lower than the BACM/MSM significance 

thresholds. Therefore, the Clean Air Act does not require a control measure evaluation 

for this source category for the purpose of satisfying BACM/MSM requirements; 

however, the District has still conducted a full control measure evaluation for open 

areas. 

Also, while District Regulation VIII was critical in the District’s attainment of the PM10 

standard, a variety of studies have been conducted which may indicate that the PM2.5 

fraction of the PM emissions from this source category 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 under Rule 8051 and to 

indicate the level of significance of those PM2.5 emissions. At this time, PM2.5 

emission control factors are not well defined and it is not known if PM10 controls are 

effective for reducing PM2.5 for open areas. Modeling results show that the geologic 

fraction of PM2.5 found in the San Joaquin Valley makes a relatively small contribution 

to overall PM2.5 mass. In addition, studies have shown that geologic dust alone has 

relatively low toxicity. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-192 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

How does District Rule 8051 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. The following federal regulations apply to sources covered under Rule 8051: 

 Rule 57 FR 13498 (General Preamble for Title I of CAA) 

The District evaluated the requirements contained within the General Preamble and 

found no requirements that were more stringent than those already in Rule 8051. 

 EPA-450/2-92-004 (Fugitive Dust Background Document and Technical 

Information Document for BACM) 

The District evaluated the requirements contained within the Fugitive Dust Background 

Document and Technical Information Document for BACM and found no requirements 

that were more stringent than those already in Rule 8051. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 8051 compare to rules in other air districts? 

There are no analogous rules for this source category in BAAQMD. 

SCAQMD 

 Rule 1156 (Further Reductions of Particulate Emissions from Cement Manufacturing 

Facilities) 

The District evaluated the requirements contained within SCAQMD Rule 1156 and 

found no requirements that were more stringent than those already in Rule 8051. 

 Rule 1157 (PM10 Emission Reductions form Aggregate and Related Operations) 

The District evaluated the requirements contained within SCAQMD Rule 1157 and 

found no requirements that were more stringent than those already in Rule 8051. 

SMAQMD 

 Rule 403 (Fugitive Dust)

The District evaluated the requirements contained within SMAQMD Rule 403 and found 

no requirements that were more stringent than those already in Rule 8051. 

VCAPCD 

 Rule 55 (Fugitive Dust) 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-193 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

The District evaluated the requirements contained within VCAPCD Rule 55 and found 

no requirements that were more stringent than those already in Rule 8051. 

Clark County Department of Air Quality (CCDAQ) 

 Section 90 (Fugitive Dust from Open Areas and Vacant Lots) 

The District evaluated the requirements contained within CCDAQ Section 90 and found 

no requirements that were more stringent than those already in Rule 8051. 

Additional Emission Reduction Opportunities 

The District’s analysis did not identify any potential opportunities to further reduce 

emissions from this source category beyond those emissions that are already being 

reduced by rule requirements. As a part of due diligence efforts in seeking addition 

emission reduction opportunities, the following two potential opportunities have been 

identified to improve rule clarity. Language could be added to the rule to clarify that it 

applies to off-road recreational vehicle use areas. Also, the rule provides an exemption 

for weed abatement activity utilizing mowing and/or cutting. Adding language to specify 

that weed abatement by tilling is not exempt would also add clarity to the rule. While 

these opportunities could clarify rule language, neither would likely generate emissions 

reductions from this source category. 

Evaluation Findings

Even though open areas are not a significant source of PM2.5, NOx, or SOx in the 

Valley, the District has evaluated all potential control technologies and all control 

technologies achieved in practice in other areas or included in other state 

implementation plans. As demonstrated above, Rule 8051 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 this source category. As the District 

continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from open areas in the Valley. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-194 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.28 RULE 8061 PAVED AND UNPAVED ROADS 

Source Category 

Rule 8061 establishes standards for the construction of new and modified paved roads 

in accordance with published guidelines by the American Association of State Highway 

and Transportation Officials for road construction and applies to any paved, unpaved, or 

modified public or private road, street highway, freeway, alley way, access drive, access 

easement, or driveway. The rule also allows alternative means of achieving the same 

level of dust reduction. Rule 8061 also establishes thresholds that when exceeded 

require that roads are treated to reduce visible dust emissions. 

In 2004, the District adopted amendments to Regulation VIII to upgrade existing RACM 

level rules to meet the more stringent BACM level required in serious PM10 

nonattainment areas. Rule 8061 was amended to replace the existing 75 maximum 

daily vehicle trip threshold with a 26 annual average daily vehicle trips (AADT) threshold 

on unpaved roads, and require all new unpaved roads within urban areas be paved. 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 7.59 7.71 7.83 7.98 8.13 8.28 8.41 8.55 8.69 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Winter Average - Tons per day 

PM2.5 6.63 6.75 6.87 7.00 7.14 7.28 7.41 7.55 7.67 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

While District Regulation VIII was critical in the District’s attainment of the PM10 

standard, a variety of studies have been conducted which may indicate that the PM2.5 

fraction of the PM emissions from this source category 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 under Rule 8061 and to 

indicate the level of significance of those PM2.5 emissions. At this time, PM2.5 

emission control factors are not well defined and it is not known if PM10 controls are 

effective for reducing PM2.5 for paved and unpaved roads. Modeling results show that 

the geologic fraction of PM2.5 found in the San Joaquin Valley makes a relatively small 

contribution to overall PM2.5 mass. In addition, studies have shown that geologic dust 

alone has relatively low toxicity. 

How does District Rule 8061 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-195 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

category. The following federal regulations apply to sources covered under Rule 8061: 

 Rule 57 FR 13498 (General Preamble for Title I of CAA) 

The District evaluated the requirements contained within the General Preamble and 

found no requirements that were more stringent than those already in Rule 8061. 

 EPA-450/2-92-004 (Fugitive Dust Background Document and Technical 

Information Document for BACM) 

The District evaluated the requirements contained within the Fugitive Dust Background 

Document and Technical Information Document for BACM and found no requirements 

that were more stringent than those already in Rule 8061. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 8061 compare to rules in other air districts? 

There are no analogous rules for this source category in BAAQMD. 

SCAQMD 

 Rule 1156 (Further Reductions of Particulate Emissions from Cement Manufacturing 

Facilities) 

The District evaluated the requirements contained within SCAQMD Rule 1156 and 

found no requirements that were more stringent than those already in Rule 8061. 

 Rule 1157 (PM10 Emission Reductions form Aggregate and Related Operations) 

The District evaluated the requirements contained within SCAQMD Rule 1157 and 

found no requirements that were more stringent than those already in Rule 8061. 

SMAQMD 

 Rule 403 (Fugitive Dust)

The District evaluated the requirements contained within SMAQMD Rule 403 and found 

no requirements that were more stringent than those already in Rule 8061. 

VCAPCD 

 Rule 55 (Fugitive Dust) 

The District evaluated the requirements contained within VCAPCD Rule 55 and found 

no requirements that were more stringent than those already in Rule 8061. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-196 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Clark County Department of Air Quality (CCDAQ) 

 Section 91 (Fugitive Dust from Unpaved Roads, Unpaved Alleys, and Unpaved 

Easement Roads) 

The District evaluated the requirements contained within CCDAQ Section 91 and found 

no requirements that were more stringent than those already in Rule 8061. 

 Section 93 (Fugitive Dust from Paved Roads and Street Sweeping Equipment) 

The District evaluated the requirements contained within CCDAQ Section 93 and found 

no requirements that were more stringent than those already in Rule 8061. 

Additional Emission Reduction Opportunities 

The following potential opportunity to reduce emissions from paved and unpaved roads 

was determined to be infeasible. Section 5.2.1 of the rule requires dust control 

measures for any unpaved road segments with 26 or more annual average daily trips. 

A potential opportunity to reduce emissions would be to lower this threshold. This 

would require more owners/operators to implement at least one control measure to 

reduce fugitive emissions. 

Analysis of the emission inventory indicates that the majority of the particulate 

emissions attributable to unpaved roads are generated from unpaved roads already 

subject to the mitigation requirements of Rule 8061. Therefore, the remaining portion of 

emissions associated with unpaved roads (less than 26 AADT) does not provide an 

opportunity for additional emissions reductions. 

Additionally, emissions from unpaved roads are lowest in the winter months, when the 

District’s PM2.5 24-hour exceedances occur. District staff believes the winter average 

PM2.5 emission inventory is overestimated for the following reasons: 

 ARB methodology assumes that rainfall of at least 0.01 inch on any day mitigates 

unpaved road dust for 24 hours 

 71% of the days with precipitation occur during the winter months. 

 Many US Forest and Park Roads are inaccessible during winter months due to 

increased amounts of rain and snow, yet emissions from these roads make up a 

larger percentage of the total unpaved road emissions in winter (42.8%) than in 

the annual average (40.7%) 

For these reasons, lowering the trip threshold is not a viable emission reduction 

opportunity. 

Evaluation Findings

The District has evaluated all potential control technologies and all control technologies 

achieved in practice in other areas or included in other state implementation plans. As 

demonstrated above, Rule 8061 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 this source category. As the District continues to develop new 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-197 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

attainment plans that address more stringent National Ambient Air Quality Standards, 

the District will continue to evaluate potential opportunities to reduce emissions from 

paved and unpaved roads in the Valley. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-198 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.29 RULE 8071 UNPAVED VEHICLE/EQUIPMENT TRAFFIC AREAS 

Source Category 

Rule 8071 is applicable to unpaved vehicle/equipment areas, parking, fueling and 

service areas, and shipping, receiving, and transfer areas. The rule contains 

requirements for when vehicle traffic reaches or exceeds specified thresholds, 

limitations on visible dust emissions (VDE), compliance requirements with the 

conditions of a stabilized surface, and lists control techniques, which could be 

implemented to limit VDE and to comply with the conditions of a stabilized surface. 

In 2004, the District adopted amendments to Regulation VIII to upgrade existing RACM 

level rules to meet the more stringent BACM level required in serious PM10 

nonattainment areas. Rule 8071 was amended to remove the 1.0 acre or larger 

threshold; change the vehicle threshold from 75 vehicle daily trips to 50 annual average 

daily trips; add a single day peak threshold of 150 VDT or require control for sources 

that exceed the 150 VDT threshold limit on at least 30 days per year; and add a 

requirement whenever 25 or more three-axle vehicle trips will occur on an unpaved 

vehicle/equipment traffic area. 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 0.59 0.59 0.59 0.59 0.59 0.59 0.59 0.59 0.59 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Winter Average - Tons per day 

PM2.5 0.60 0.60 0.60 0.60 0.60 0.60 0.60 0.60 0.60 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 4.0 tons per 

day (tpd) for PM2.5 dust, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in the 

above table, emissions from unpaved vehicle/equipment traffic areas are lower than the 

BACM/MSM significance thresholds. Therefore, the Clean Air Act does not require a 

control measure evaluation for this source category for the purpose of satisfying 

BACM/MSM requirements; however, the District has still conducted a full control 

measure evaluation for unpaved vehicle/equipment traffic areas.

Also, while District Regulation VIII was critical in the District’s attainment of the PM10 

standard, a variety of studies have been conducted which may indicate that the PM2.5 

fraction of the PM emissions from this source category 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 under Rule 8071 and to 

indicate the level of significance of those PM2.5 emissions. At this time, PM2.5 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

emission control factors are not well defined and it is not known if PM10 controls are 

effective for reducing PM2.5 for unpaved vehicle/equipment traffic areas. Modeling 

results show that the geologic fraction of PM2.5 found in the San Joaquin Valley makes 

a relatively small contribution to overall PM2.5 mass. In addition, studies have shown 

that geologic dust alone has relatively low toxicity. 

How does District Rule 8071 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. The following federal regulations apply to sources covered under Rule 8071: 

 Rule 57 FR 13498 (General Preamble for Title I of CAA) 

The District evaluated the requirements contained within the General Preamble and 

found no requirements that were more stringent than those already in Rule 8071. 

 EPA-450/2-92-004 (Fugitive Dust Background Document and Technical 

Information Document for BACM) 

The District evaluated the requirements contained within the Fugitive Dust Background 

Document and Technical Information Document for BACM and found no requirements 

that were more stringent than those already in Rule 8071. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 8071 compare to rules in other air districts? 

There are no analogous rules for this source category in BAAQMD. 

SCAQMD 

 Rule 1156 (Further Reductions of Particulate Emissions from Cement Manufacturing 

Facilities) 

The District evaluated the requirements contained within SCAQMD Rule 1156 and 

found no requirements that were more stringent than those already in Rule 8071. 

 Rule 1157 (PM10 Emission Reductions form Aggregate and Related Operations) 

The District evaluated the requirements contained within SCAQMD Rule 1157 and 

found no requirements that were more stringent than those already in Rule 8071. 

SMAQMD 

 Rule 403 (Fugitive Dust)
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-200 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

The District evaluated the requirements contained within SMAQMD Rule 403 and found 

no requirements that were more stringent than those already in Rule 8071. 

VCAPCD 

 Rule 55 (Fugitive Dust) 

The District evaluated the requirements contained within VCAPCD Rule 55 and found 

no requirements that were more stringent than those already in Rule 8071. 

Clark County Department of Air Quality (CCDAQ) 

 Section 92 (Fugitive Dust from Unpaved Parking Lots and Storage Areas) 

The District evaluated the requirements contained within CCDAQ Section 92 and found 

no requirements that were more stringent than those already in Rule 8071. 

Additional Emission Reduction Opportunities 

Section 5.2.1 of current rule language requires dust control measures for any unpaved 

traffic area with 50 or more annual average daily trips. Analysis of lowering this 

threshold to determine if it is a feasible option to reduce emissions determined that this 

is not a cost effective opportunity. Lowering the trip threshold of Rule 8071 would result 

in direct PM emission reductions, but would also result in the requirement that owners 

and/or operators implement a dust control measure. The most common control 

measures are watering and covering with gravel. Local cost estimates indicate that 

installing a 2 inch gravel base with another 2 inches of top gravel would cost 

approximately $1.90 per square foot, or around $83,000 per acre. Based on the small 

size of the emissions from this source category, and the estimated mitigation costs, 

requiring control measures for areas with such minimal activity is not a cost effective 

option. 

Evaluation Findings

Even though unpaved vehicle/equipment traffic areas are not a significant source of 

PM2.5, NOx, or SOx in the Valley, the District has evaluated all potential control 

technologies and all control technologies achieved in practice in other areas or included 

in other state implementation plans. As demonstrated above, Rule 8071 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 this source category. As the 

District continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from unpaved vehicle/equipment traffic areas in the 

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

C-201 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.30 RULE 8081 AGRICULTURAL SOURCES 

Source Category 

Rule 8081 applies to “off-field” agricultural sources including, but not limited to, unpaved 

roads, unpaved vehicle/equipment traffic areas, and bulk materials. The rule contains 

requirements to limit visible dust emissions (VDE) and/or to comply with the conditions 

of a stabilized surface, and lists control techniques which could be implemented to limit 

VDE and to comply with the conditions of a stabilized surface. 

In 2004, the District adopted amendments to Regulation VIII to upgrade existing RACM 

level rules to meet the more stringent BACM level required in serious PM10 

nonattainment areas. The amendments added an exemption to the rule for 

vehicle/equipment traffic areas if they are less than one acre in size and more than one 

mile from an urban area; expanded rule applicability by updating the vehicle threshold 

from 75 vehicle daily trips to 50 annual average vehicle trips; and added a requirement 

specific to whenever 26 or more three-axle vehicle trips will occur on an unpaved 

vehicle/equipment traffic area. 

Emissions Inventory

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day 

PM2.5 1.21 1.21 1.20 1.20 1.19 1.19 1.18 1.18 1.17 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

Winter Average - Tons per day 

PM2.5 0.75 0.75 0.75 0.74 0.74 0.74 0.73 0.73 0.73 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 4.0 tons per 

day (tpd) for PM2.5 dust, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in the 

above table, emissions from agricultural sources are lower than the BACM/MSM 

significance thresholds. Therefore, the Clean Air Act does not require a control 

measure evaluation for this source category for the purpose of satisfying BACM/MSM 

requirements; however, the District has still conducted a full control measure evaluation 

for agricultural sources. 

Also, while District Regulation VIII was critical in the District’s attainment of the PM10 

standard, a variety of studies have been conducted which may indicate that the PM2.5 

fraction of the PM emissions from this source category 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 under Rule 8081 and to 

indicate the level of significance of those PM2.5 emissions. At this time, PM2.5 

emission control factors are not well defined and it is not known if PM10 controls are 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-202 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

effective for reducing PM2.5 for agricultural sources. Modeling results show that the 

geologic fraction of PM2.5 found in the San Joaquin Valley makes a relatively small 

contribution to overall PM2.5 mass. In addition, studies have shown that geologic dust 

alone has relatively low toxicity. 

How does District Rule 8081 compare with federal and state rules and 

regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. The following federal regulations apply to sources covered under Rule 8081: 

 Rule 57 FR 13498 (General Preamble for Title I of CAA) 

The District evaluated the requirements contained within the General Preamble and 

found no requirements that were more stringent than those already in Rule 8081. 

 EPA-450/2-92-004 (Fugitive Dust Background Document and Technical Information 

Document for BACM) 

The District evaluated the requirements contained within the Fugitive Dust Background 

Document and Technical Information Document for BACM and found no requirements 

that were more stringent than those already in Rule 8081. 

State Regulations 

There are no state regulations applicable to this source category. 

How does District Rule 8081 compare to rules in other air districts? 

There are no analogous rules for this source category in BAAQMD. 

SCAQMD 

 Rule 1156 (Further Reductions of Particulate Emissions from Cement Manufacturing 

Facilities) 

The District evaluated the requirements contained within SCAQMD Rule 1156 and 

found no requirements that were more stringent than those already in Rule 8081. 

 Rule 1157 (PM10 Emission Reductions form Aggregate and Related Operations) 

The District evaluated the requirements contained within SCAQMD Rule 1157 and 

found no requirements that were more stringent than those already in Rule 8081. 

SMAQMD 

 Rule 403 (Fugitive Dust)

The District evaluated the requirements contained within SMAQMD Rule 403 and found 

no requirements that were more stringent than those already in Rule 8081. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-203 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

VCAPCD 

 Rule 55 (Fugitive Dust) 

The District evaluated the requirements contained within VCAPCD Rule 55 and found 

no requirements that were more stringent than those already in Rule 8081. 

Clark County Department of Air Quality (CCDAQ) 

 Section 91 (Fugitive Dust from Unpaved Roads, Unpaved Alleys, and Unpaved 

Easement Roads) 

The District evaluated the requirements contained within CCDAQ Section 91 and found 

no requirements that were more stringent than those already in Rule 8081. 

Additional Emission Reduction Opportunities 

The District’s analysis did not identify any potential opportunities to further reduce 

emissions from this source category. However, a potential opportunity to improve 

enforceability of this for this source category has been identified. Section 5.4 of the rule 

references California Vehicle Code section 23112-23113 for prevention of carryout and 

trackout. This section could be removed and replaced with specific language from the 

vehicle code, however, as previously stated, this amendment would not result in 

emissions reductions. 

Evaluation Findings

Even though off-field agricultural sources are not a significant source of PM2.5, NOx, or 

SOx in the Valley, the District has evaluated all potential control technologies and all 

control technologies achieved in practice in other areas or included in other state 

implementation plans. As demonstrated above, Rule 8081 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 this source category. As the District 

continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from off-field agricultural sources in the Valley. 

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

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 2015 Plan for the 1997 PM2.5 Standard 

C.31 SC 001 LAWN AND GARDEN EQUIPMENT 

Source Category 

This source category includes the commercial and residential lawn and garden sectors. 

The commercial sector includes larger businesses that employ licensed contractors, 

public agencies and organizations that maintain their own properties or provide 

landscape services, and small businesses serving residential properties. The 

residential sector of lawn and garden equipment includes equipment purchased by the 

public for personal use. A survey conducted in 2003 by the California Air Resources 

Board (ARB) estimated that there are approximately 13 million pieces of lawn and 

garden equipment statewide: 12% in the commercial sector and 88% in the residential 

sector. Although there are more pieces of equipment used by the residential sector, the 

survey showed that the commercial sector accounts for 68% of annual use of all lawn 

care equipment. 

Lawn and garden equipment includes the following: chainsaws, chippers, commercial 

turf equipment, front mowers, lawn and garden tractors, lawn mowers, leaf blowers and 

vacuums, rear-engine riding mowers, shredders, snow blowers, tillers, trimmers, 

edgers, brush cutters, wood splitters, and other lawn and garden equipment. 

Handheld lawn and garden tools (such as leaf blowers) typically use two-stroke 

engines, while larger machines (such as lawn and garden tractors) use four-stroke 

engines. Lawn mowers are available with either type of engine. Two-stroke engines 

rely on oil mixed with the gasoline to lubricate the engine components. Much of this oil 

is not completely combusted by the engine thus creating high exhaust emissions. The 

major pollutants from a two-stroke engine, for example, are oil-based particulates, 

PM2.5, NOx, and a mixture of hydrocarbons, which combine with other gases in the 

atmosphere to form ozone, carbon monoxide, and other toxic air contaminants. Overall, 

four-stroke engines emit significantly lower emissions than their two-stroke 

counterparts, with significantly lower levels of hydrocarbons and particulate matter. 

Lawn care equipment, particularly leaf blowers, can also cause a significant amount of 

fugitive dust depending on the work practices employed such as blowing on bare dirt or 

very dusty paved surfaces. These types of activities would increase fugitive emissions 

including PM, toxic air contaminants (TAC) and ultrafine particles (UFP) resulting in a 

negative health impact on those in proximity to the activity. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-205 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Emissions Inventory 

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day

PM2.5 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 

NOx 0.58 0.57 0.57 0.56 0.55 0.55 0.54 0.54 0.53 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

PM2.5 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 

NOx 0.54 0.53 0.53 0.52 0.51 0.50 0.50 0.49 0.49 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from lawn care equipment are lower than the BACM/MSM 

significance thresholds. Therefore, the Clean Air Act does not require a control 

measure evaluation for this source category for the purpose of satisfying BACM/MSM 

requirements; however, the District has still conducted a full control measure evaluation 

for lawn care equipment. 

How would District SC 001 compare with federal and state rules and regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. The following federal regulations apply to sources covered under SC 001: 

 EPA Rule 40 CFR Part 90 (Small Non-Road Spark-Ignition Engine Rule) 

The EPA regulation required exhaust emission standards by 2011 and 2012, depending 

on the class of the engine. 

State Regulations 

The following state regulations apply to sources covered under SC 001: 

(Small Off-Road Engines) 

 13 CCR 2403 (Exhaust Emission Standards) 

 13 CCR 2404 (Emission Control Labels) 

 13 CCR 2405 (New Engine Compliance) 

How would District SC 001 compare to rules in other air districts? 

There are no analogous rules for this source category in BAAQMD, SMAQMD, or 

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

C-206 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

SCAQMD 

 Rule 1623 (Credits for Clean Lawn and Garden Equipment) 

The District evaluated the requirements contained within SCAQMD’s Rule 1623 and 

found it was not approved by EPA and is not currently being implemented. 

Additional Emission Reduction Opportunities 

ARB and EPA have regulatory authority over engine standards. ARB and EPA rules 

rely on natural turnover and do not push zero emissions technology; therefore, there are 

still opportunities to reduce emissions by closing the emissions gap and accelerating the 

use of zero emissions technology. While the District cannot establish new engine 

standards, it could regulate the use of lawn and garden equipment. Given the Valley’s 

air quality challenges and the potential benefits, the District may explore in-use 

regulatory options as a long-term strategy. The District’s analysis of potential 

opportunities to reduce emissions includes evaluations of emerging technologies and 

potential control strategies such as an in-use rule, best management practices, episodic 

controls, and zoning. 

Emerging Technologies 

There have been recent improvements in the availability and applications of zero 

emissions lawn care technology. Manufacturers are producing more electric lawn care 

equipment options and are developing ways to allow for this equipment to be used in 

the commercial sector, such as carrying additional battery packs. Examples of more 

recent advances in new electric options include the following: 

 Lawn mowers 

o Riding mowers 

o Robotic mowers 

o Self-propelled walk behind mowers 

o Cordless electric lawn mowers 

 Battery powered leaf blowers 

 Electric sweepers and backpack vacuums 

 Battery powered chainsaws 

 Electric line trimmers/edgers 

 Electric hedge trimmers 

 Stronger batteries and battery chargers 

Though zero-emitting or battery operated lawn equipment has significantly improved in 

recent years, the viability of cordless electric technology has not been proven in the 

commercial sector. This is largely due to the need for a longer battery life and durability 

to allow for more frequent and prolonged equipment use. On March 21, 2012, the 

District hosted a conference on lawn care, landscaping, and air quality. The conference 

highlighted challenges operators face when using lower emitting equipment and 

commercial viability. Local operators expressed concerns about the cost and reliability 

of cordless electric equipment, and how this equipment might affect productivity and 

competition with other operators. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-207 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

In 2013, the District completed the Cordless Zero-Emission Commercial Lawn and 

Garden Equipment Demonstration Program. The program was funded with State Air 

Quality Improvement Program and District program funds and provided eligible cordless 

zero-emission commercial lawn and garden equipment to commercial landscape 

professionals who conduct business within the boundaries of the San Joaquin Valley. 

The final report was submitted to ARB in 2013 with plans to allocate future incentive 

funds for cordless zero-emission lawn and garden equipment. 

Potential Strategies to Reduce Emissions 

In evaluating potential control strategies, the District’s analysis identified a number of 

potential regulatory and outreach opportunities. However, there are no recommended 

regulatory actions at this time due to the need to revise the emissions inventory. The 

District will continue evaluating which of the following regulatory approaches are 

feasible from a regulatory standpoint as well as from a public health standpoint. 

In-Use Rule 

One potential control strategy would be to require the use of the cleanest available 

equipment by prohibiting the use of gas combustion equipment. This could be achieved 

through a point-of-sale rule implementing a tiered approach or by phasing in restrictions 

as lower or zero-emissions technology becomes more available in the future. This type 

of control measure could potentially eliminate the portion of emissions resulting from the 

combustion of fuel. There might also be a need to bifurcate this type of regulation due 

to the varying availability of low or zero-emitting equipment in the residential sector 

versus commercial sector. 

Best Management Practices 

Another potential control strategy would be to require operators to implement Best 

Management Practices (BMPs) using a menu approach for the use of lawn and garden 

equipment in the commercial sector. Some examples of potential BMPs include: 

 Restrictions near schools and other heavily populated areas 

 Courtesy practices (e.g. don’t point at people or open windows, don’t blow 

material onto public roads, sidewalks, or neighboring properties) 

 Particulate prevention practices (e.g. no leaf blower use on bare dirt surfaces or 

very dusty paved surfaces, etc.) 

This BMP option would focus on providing education on safety and more efficient use of 

equipment. Enforcing this type of rule could be challenging due to the large number of 

operators, variation in size of businesses, and the widespread distribution of operator 

activities. Operators could be required to complete a certification course so that they 

can be educated on proper work practices. The District could also require operators to 

show a certificate of completion to purchase gas equipment after a certain date, to 

ensure contractors operating gas equipment are using the most effective work practices 

to protect public health and decrease emissions. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-208 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Episodic Control 

Episodic control provides another potential control strategy where use of gas equipment 

could be limited or prohibited during high-pollution days. There has also been 

precedence set throughout California with numerous cities and counties adopting 

ordinances banning or prohibiting the use of leaf blowers on specified days, times, 

distances from residential areas, or noise levels. The District could create a model 

ordinance for cities and counties to adopt throughout the Valley to limit or prohibit the 

use of gas equipment and/or leaf blowers. One example was found where the City of 

Menlo Park prohibited the use of gas equipment on Spare the Air days in the BAAQMD. 

This could be an option for future regulatory control in the Valley to reduce emissions, 

especially on high pollution days. 

Table C-35 City Bans of Leaf Blowers 

Cities Ban Type 

Dana Point 

San Diego 

Decibel and hours of operations restrictions 

Foster City 

Los Angeles 

Palo Alto 

Restrictions on distance from residential unit and hours 

allowed to operate 

Sacramento 

Sunnyvale 

Restrictions on decibels, hours of operations, and distance 

from residential areas 

Berkeley 

Beverly Hills 

Claremont 

Lawndale 

Los Altos 

Santa Barbara 

Bans gas blowers 

Burlingame Restrict commercial use to one day per week dependent on 

determined city districts; Residential areas restricted by days

and hours of operation 

Menlo Park Prohibited on Sundays, observed federal holidays, and on 

"Spare the Air" days as declared by the BAAQMD 

Laguna Beach 

Santa Monica 

Bans all blowers 

Zoning 

Another potential opportunity to reduce emissions could be through the promotion of 

“zones,” where gas equipment would be prohibited or limited in designated zones, such 

as those close to schools, parks, etc. This approach, known as “greenzoning,” is 

currently being pioneered in Los Angeles County. Greenzoning could potentially be 

included as a part of the Healthy Air Living outreach program to individual businesses, 

schools, cities, and counties. A related option could be limiting gas powered equipment 

use in certain zones to designated days of the week, similar to days allowed to water 

residential yards. This approach was recently adopted by the city of Burlingame for leaf 

blower use only. Cleaner electric equipment would have an advantage by still being 

able to be operated on the days or areas that gas powered equipment is limited. This 

strategy would also be a win-win by reducing noise nuisances in neighborhoods and 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

near schools. The District could provide model ordinances to cities and counties to 

adopt to assist them in implementing this type of measure. 

Non-Regulatory Actions 

There are no recommendations for new incentive or technology advancement programs 

at this time. The recommendation is to continue to run the Clean Green Yard Machine 

Residential Lawn Mower Incentive Program, as well as evaluate the commercial lawn 

care equipment technologies capable of reducing emissions in the Valley that were 

demonstrated as a part of the Cordless Zero-Emission Commercial Lawn and Garden 

Equipment Demonstration Program. The District, along with the technology 

demonstrators, submitted their Cordless Zero-Emission Commercial Lawn and Garden 

Equipment evaluation to ARB in June 2013. 

Evaluation Findings

Even though lawn and garden equipment are not a significant source of PM2.5, NOx, or 

SOx in the Valley, the District has evaluated all potential control technologies and all 

control technologies achieved in practice in other areas or included in other state 

implementation plans. The District cannot establish new engine standards; therefore, it 

is recommended the District continue current incentive programs in order to close the 

emissions gap and accelerate the use of zero emissions technology, ultimately 

exceeding both BACM and MSM requirements for this source category. As the District 

continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from lawn and garden equipment in the Valley. 

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

C-210 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

C.32 SC 002 ENERGY EFFICIENCY 

Source Category 

This category does not include specific emissions inventory sources in the Valley, but 

rather the opportunity to reduce emissions from all Valley sectors through the promotion 

of energy efficiency and conservation measures. Generally, emissions reductions could 

be obtained from reductions in electrical power generation or fuel through the 

implementation of such measures. Potential areas of focus include residential and 

commercial buildings, manufacturing and industrial facilities, agricultural operations, and 

oil/gas production and processing facilities. 

Additional Emission Reduction Opportunities 

Energy use is not a regulated activity; however, emissions from the generation of 

electricity are regulated at power plants. Overall, electricity generation in California is 

relatively clean when compared to emission factors (criteria pollutants and greenhouse 

gases (GHG)) from other states. California has been on the forefront of developing 

renewable energy sources, and has implemented regulations to ensure cleaner nonrenewable energy. Whereas coal-fired electricity generation provides a significant 

percentage of electricity in other parts of the country, especially the eastern states, 

California relies more heavily on natural gas-fired power plants, which have lower 

emission rates for criteria pollutants and GHGs. 

California imports 30% of its electricity from surrounding states (2010 data from 

California Energy Commission (CEC)). The state’s four major utility companies use this 

electricity, as well as resources from around the state to supply continuous, reliable 

electricity to its customers. The inter-related nature of California’s electricity 

transmission leads to a complex relationship between local energy efficiency programs 

and emissions reductions. Energy dispatch for needed demand is time and market 

dependent; the closest plant does not necessarily supply energy to the closest demand. 

In some cases, peak energy demand is met for areas outside the Valley, including Los 

Angeles and San Diego, with marginal (peaker) power plants within the Valley. 

Likewise, Valley demand may be met with electricity from marginal power plants outside 

the Valley. To complicate matters, which marginal plant is used can depend on the time 

of day, the minute-by-minute energy market, or other highly variable factors. 

In 2010, the CEC commissioned an evaluation of energy usage and potential reductions 

from energy efficiency and renewable energy measures. Using sophisticated dispatch 

modeling, Synapse Energy Economics Inc. (Synapse) was able to estimate NOx 

emissions reductions for renewable energy and energy efficiency projects within 

California and within each of the four major utility companies.89 In preliminary model 

runs, Synapse showed that approximately 45 pounds of NOx could be reduced for each 

gigawatt of displaced base load electricity. Likewise, 76 pounds of NOx could be 

 

89 Synapse Energy Economics, Inc. for CEC Public Interest Energy Research (PIER) Program. CEC-500-2011-XXX. 

(2011, May). Emission Reductions from Renewable Energy and Energy Efficiency in California Air Quality 

Management Districts: Final Project Report (Draft). 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

reduced for each gigawatt of displaced peak load electricity displaced by targeted 

energy efficiency efforts during peak demand hours. 

In 2012, EPA released a roadmap manual90 to assist state, tribal, and local air agencies 

with quantifying and including emissions reductions from energy efficiency and 

renewable energy in State Implementation Plans (SIPs). The document focuses on 

emission benefits from energy policies and programs in the electric power sector. The 

complex nature of electricity transmission and dispatch, combined with import and 

export of electricity into and out of the District and California, will require sophisticated 

energy modeling to pinpoint emissions reductions attributable to potential energy 

efficiency and renewable energy control measures. 

The District’s involvement in energy efficiency and renewable energy is guided by its 

Regional Energy Efficiency Strategy (REES), which was adopted in January 2010.91

This policy document identifies the District’s commitment to fostering energy efficiency 

and clean energy alternatives as opportunities for emissions reductions. The District 

has initiated several projects that exemplify this policy guidance. 

Non-Regulatory Actions 

The District currently has incentive and technology advancement programs aimed at 

reduced energy use in the Valley. To date, the projects include the following: 

 The administration of approximately $4 million in federal and state Energy 

Efficiency and Conservation Block Grant funds made available to 37 small 

jurisdictions in the Valley. The majority of the funding was used to retrofit 

municipal facilities with lighting and other cost effective energy efficiency retrofits, 

resulting in about 1.8 MkWh of electricity savings per year. 

 The funding of an innovative pilot program to assess the potential to operate 

more efficiently, thus saving money and using less energy. 

 The funding of an outreach program showing governmental and service 

organizations the benefits of “going green.” This program started in Stockton 

through the Stockton Chamber of Commerce, and with the District’s help has 

expanded to the central and southern San Joaquin Valley. 

 The allocation of $4 million for the District’s Technology Advancement Program. 

Two of the three focus areas for FY 2014–2015 are renewable energy and waste 

solutions, which take into account energy efficiency. 

While there are no recommendations for new incentive programs at this time, the 

District will continue supporting existing incentive and technology advancement 

programs. 

 

90 EPA. (2012) Incorporating Energy Efficiency/Renewable Energy in State and Tribal Implementation Plans. 

Retrieved July 10, 2012 from http://www.epa.gov/airquality/eere/. 91 SJVAPCD. (2010). Approval of the District’s Regional Energy Efficiency Strategy. Memorandum to the SJVAPCD 

Governing Board. Public Hearing, January 21, 2010. Retrieved from 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2010/January/Agenda_Item_7_Jan_21_2010.

pdf. 
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Evaluation Findings

The District has evaluated all potential control technologies and all control technologies 

achieved in practice in other areas or included in other state implementation plans. The 

District cannot regulate energy use; therefore, it is recommended the District continue 

current incentives and technology advancement programs in order to close the 

emissions gap and accelerate the use of energy efficient technologies. As the District 

continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities for improving energy efficiency to reduce emissions in the Valley. 

 
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C.33 SC 003 FIREWORKS 

Source Category 

This category consists of fireworks sold and/or used in the Valley. This includes 

consumer fireworks for home displays, as well as professional products for use by 

licensed operators in public displays. 

Emissions Inventory 

The emissions inventory for this category has not been quantified. 

How would District SC 003 compare with federal and state rules and regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. 

State Regulations 

The following state regulations apply to sources covered under SC 003: 

 California Health and Safety Code, Section 12500 – 12759 (Law)

 Title 19, California Code of Regulations, Chapter 6 (Regulation) 

How would District SC 003 compare to rules in other air districts? 

There are no references to the use of fireworks or pyrotechnics for entertainment 

purposes in BAAQMD, SMAQMD, or VCAPCD.

SCAQMD

 Rule 219 (Equipment not Requiring a Written Permit Pursuant to Regulation II) 

Rule 219 exempts pyrotechnic equipment, special effects, or fireworks paraphernalia 

equipment used for entertainment purposes from permit requirements. 

 Rule 444 (Open Burning) 

Fireworks and fireworks displays and pyrotechnics used for creation of special effects at 

theme parks are excluded from the open burning requirements of Rule 444. 

 Rule 401 (Visible Emissions)

 Rule 402 (Nuisance)

Rules 401 and 402 do not explicitly exempt fireworks displays. 

Additional Emission Reduction Opportunities 

Fireworks usage in the Valley is limited to occasional displays at a small number of 

entertainment venues (minor league sporting events, for example) and Independence 

Day (July 4th). On July 4th, with widespread consumer fireworks use, the Valley’s air 
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monitors typically show peak PM2.5 concentrations for several hours on the evening of 

July 4th and into July 5th. These hourly PM2.5 concentrations are much higher than 

normal PM2.5 concentrations during the summer, although 24-hour average PM2.5 

concentrations on July 4th and 5th do not always go above the level of EPA’s standard. 

In addition, exceedances of the air quality standard due to fireworks qualify as an 

exceptional event under federal regulations and, with proper documentation and EPA 

concurrence, do not count against an area’s attainment status.92 However, the clear 

relationship between fireworks activity and ambient PM2.5 levels; the location of 

emissions in populated areas; and the fact that the PM2.5 species associated with 

fireworks are health-impacting metals and carbons all demonstrate the value of 

reducing emissions from fireworks as part of the District’s Health-Risk Reduction 

Strategy. Fireworks emissions are reduced by limiting the use of fireworks. For several 

years, the District has utilized public education to inform residents of the risks 

associated with firework emissions, and the dangers to sensitive populations. 

Enhancements to future outreach efforts may include partnering with other state and 

local agencies’ outreach efforts. 

Despite the strong public affinity for July 4th fireworks, many parts of the country are 

moving away from pyrotechnic fireworks displays and towards laser light-based shows – 

particularly in regions with severe drought conditions and extreme fire danger. 

According to the International Laser Display Association, laser-light-based shows are 

gaining popularity steadily as more and more communities are moving in this direction. 

Several companies in California and throughout the country are engaged in the 

business of incorporating laser-light based shows into 4th of July celebrations. 

Some fireworks are lower-emitting than others. Disneyland Theme Park started using a 

patented air launch pyrotechnics system in 2004 to reduce noise and pollution. Use of 

such a system appears to be limited, and is likely most effective in situations where 

fireworks displays are frequent enough to justify the cost and permanent installation. 

Non-Regulatory Action 

In 2012, the District launched an incentive program for municipal laser-light shows to 

replace fireworks displays. Due to timing, the District was unable to fund shows that 

year, and has yet to reevaluate the program for implementation in future years. 

On August 16, 2012, the District’s Governing Board voted to adopt a position in 

opposition of California Senate Bill (SB) 1468 (Calderon), which would have allowed for 

the sale of safe and sane fireworks during the period of December 6th to January 2nd for 

two years, as a pilot for considering whether such an expanded use of fireworks should 

continue. This legislation would have thus expanded the use of fireworks to winter 

months when the Valley experiences stagnant conditions that trap particulates for 

extended periods of time. Given the potential for extreme adverse impact to public 

health, the District opposed SB 1468. Ultimately, the bill was not enacted, likely for 

 

92 40 CFR 50.14 (b)(2), (2011). Treatment of Air Quality Monitoring Data Influenced by Exceptional Events. 
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financial reasons associated with the data collection and analysis associated with the 

bill. 

Evaluation Findings

The District has evaluated all potential emission reduction opportunities for fireworks 

achieved in practice in other areas or included in other SIPs. As the District continues 

to develop new attainment plans that address more stringent National Ambient Air 

Quality Standards, the District will continue to evaluate potential opportunities to reduce 

emissions from fireworks in the Valley. 

 
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C.34 SC 004 SAND AND GRAVEL OPERATIONS 

Source Category 

Particulate matter emissions from sand and gravel operations occur as excavated 

aggregate material is conveyed, screened, crushed, and stored. 

Emissions Inventory 

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day

PM2.5 0.09 0.10 0.10 0.10 0.10 0.11 0.11 0.11 0.11 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

PM2.5 0.09 0.09 0.10 0.10 0.10 0.11 0.11 0.11 0.11 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 4.0 tons per 

day (tpd) for PM2.5 dust, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in the 

above table, emissions from sand and gravel operations are lower than the BACM/MSM 

significance thresholds. Therefore, the Clean Air Act does not require a control 

measure evaluation for this source category for the purpose of satisfying BACM/MSM 

requirements; however, the District has still conducted a full control measure evaluation 

for sand and gravel operations. 

How would District SC 004 compare with federal and state rules and regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NESHAP, and MACT requirements for this source 

category. 

NSPS 

 40 CFR Part 60, Section 111 of the Clean Air Act (40 FR 58416)

State Regulations 

There are no state regulations applicable to this source category. 

How would District SC 004 compare to rules in other air districts? 

There are no analogous rules for this source category in in BAAQMD, SMAQMD, or 

VCAPCD. 

SCAQMD 

 Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations) 

 Rule 403 (Fugitive Dust) 
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The District evaluated the requirements contained within SCAQMD’s Rules 1157 and 

403 and found no requirements that were more stringent than those already in District 

Rules 8011, 2201, and 4101. 

Additional Emission Reduction Opportunities 

Generally, sand and aggregate materials are wet or moist when handled and emissions 

are often negligible. For processes where water is not an appropriate method for 

minimizing emissions, baghouse and filter technology and achieved-in-practice controls 

are generally sufficient to limit visible dust emissions to less than 20 percent opacity, as 

required by District Rule 8011 (General Requirements for Regulation VIII) and District 

Rule 4101 (Visible Emissions). 

While other districts have specific rules for aggregate and related operations (SCAQMD 

Rule 1157), the ultimate limits for dust emissions is the same as opacity and visible 

emissions standards used for District operations. SCAQMD provides guidance for 

specific activities (e.g. loading, conveying, crushing, screening, and storage), but the 

emissions limits are the same as the District’s limits. The District reviews any new or 

modified stationary source under Rule 2201 (New and Modified Stationary Source 

Review), which in most cases will trigger BACT requirements, thus requiring operators 

to apply the best controls to reduce emissions during operational activities including 

crushing, screening, and conveying. 

Evaluation Findings

Even though sand and gravel operations are not a significant source of PM2.5, NOx, or 

SOx in the Valley, the District has evaluated all potential control technologies and all 

control technologies achieved in practice in other areas or included in other state 

implementation plans. As demonstrated above, Rules 2201, 8011 and 4101 currently 

have in place the most stringent measures feasible to implement in the Valley and 

therefore meet or exceed both BACM and MSM requirements for this source category. 

As the District continues to develop new attainment plans that address more stringent 

National Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from sand and gravel operations in the Valley. 

 
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C.35 SC 005 ASPHALT/CONCRETE OPERATIONS 

Source Category 

This source category includes emissions from asphalt and concrete production 

operations. Cement concrete production includes cement manufacturing and concrete 

production. There are only a few cement plants in California, but none within the Valley. 

However, many operations contribute to potential emissions associated with concrete 

production, which include the blending of cement powder, water, sand, and coarse 

aggregate. Similarly, there are operations producing asphalt concrete, which is 

primarily used for paving parking lots and on-road surfaces and is commonly made by 

hot-mixing asphalt with size-graded aggregate in drums or batches. If a cement 

production plant were to be built within the Valley, it would be reviewed and evaluated 

under District Rule 2201 (New and Modified Stationary Source Review) and would 

trigger BACT requirements for equipment and processes associated with the production 

of cement. 

Emissions Inventory 

Source 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day

Mineral Processes – PM2.5 0.82 0.84 0.86 0.89 0.92 0.94 0.97 0.99 1.01

Mineral Processes – NOx 0.20 0.20 0.21 0.22 0.22 0.23 0.24 0.24 0.25

Mineral Processes – SOx 0.36 0.37 0.38 0.40 0.41 0.42 0.43 0.44 0.45

Mineral Processes – VOC 0.22 0.22 0.23 0.24 0.24 0.25 0.26 0.26 0.27

Asphalt Mixing and 

Application – VOC only 0.76 0.76 0.76 0.76 0.77 0.77 0.77 0.77 0.78

Winter Average - Tons per day

Mineral Processes – PM2.5 0.79 0.81 0.84 0.86 0.89 0.91 0.94 0.96 0.98

Mineral Processes – NOx 0.18 0.18 0.19 0.19 0.20 0.20 0.21 0.21 0.22

Mineral Processes – SOx 0.35 0.36 0.37 0.38 0.39 0.40 0.42 0.42 0.43

Mineral Processes – VOC 0.20 0.20 0.21 0.21 0.22 0.23 0.23 0.24 0.24

Asphalt Mixing and 

Application – VOC only 0.76 0.76 0.76 0.76 0.77 0.77 0.77 0.77 0.77

The emissions inventory table above illustrates that the PM2.5, NOx, and SOx 

emissions from asphalt/concrete operations occur during the mineral processes for 

asphalt/concrete production. Asphalt mixing and application processes only generate 

VOC emissions, which occur via off-gassing. There would be NOx emissions from the 

combustion equipment used for asphalt mixing and application; however, those 

emissions are accounted for in District Rule 4309 (Dryers, Dehydrators, and Ovens) and 

off-road equipment. 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 1.4 tons per 

day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in 

the above table, emissions from asphalt/concrete operations are lower than the 

BACM/MSM significance thresholds. Therefore, the Clean Air Act does not require a 
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control measure evaluation for this source category for the purpose of satisfying 

BACM/MSM requirements; however, the District has still conducted a full control 

measure evaluation for asphalt/concrete operations. 

How would SC 005 compare with federal and state rules and regulations? 

Federal Regulations 

There are no EPA CTG, ACT, or MACT requirements for this source category. 

NSPS 

 40 CFR 60 Subpart OOO (Standards of Performance for Nonmetallic Mineral 

Processing Plants)

 40 CFR 60 Subpart I (Standards of Performance for Hot Mix Asphalt Facilities) 

 40 CFR 60 Subpart UU (Standards of Performance for Asphalt Processing and 

Asphalt Roofing Manufacturing) 

The District evaluated the requirements contained within the above NSPSs and found 

no requirements that were more stringent than those already in Rules 4101 (Visible 

Emissions), 2201 (New and Modified Stationary Source Review), and 4309 (Dryers, 

Dehydrators, and Ovens). 

NESHAP 

 40 CFR 63 Subpart LLLLL (Asphalt Processing and Asphalt Roofing Manufacturing 

for Major Sources) 

 40 CFR 63 Subpart AAAAAAA (Asphalt Processing and Asphalt Roofing 

Manufacturing for Area Sources) 

The District evaluated the requirements contained within the above NESHAPs and 

found no requirements that were more stringent than those already in Rule 4101 

(Visible Emissions), Rule 2201 (New and Modified Stationary Source Review), and Rule 

4309 (Dryers, Dehydrators, and Ovens). 

State Regulations 

There are no state regulations applicable to this source category. 

How would SC 005 compare to rules in other air districts? 

There are no analogous rules for this source category in BAAQMD, SMAQMD, and 

VCAPCD. 

SCAQMD 

 Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations) 

The District evaluated the requirements contained within SCAQMD Rule 1157 and 

found no requirements that were more stringent than those already in District Rule 4101 

(Visible Emissions), Rule 2201 (New and Modified Stationary Source Review), and Rule 

4309 (Dryers, Dehydrators, and Ovens). 
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 Rule 403 (Fugitive Dust) 

The District evaluated the requirements contained within SCAQMD Rule 403 and found 

no requirements that were more stringent than those already in District Rules 4101 

(Visible Emissions), 2201 (New and Modified Stationary Source Review), and 4309 

(Dryers, Dehydrators, and Ovens). 

Additional Emission Reduction Opportunities 

Liquid asphalt is unworkable at ambient temperatures, so most asphalt mixtures are 

manufactured, spread, and compacted at temperatures higher than 300°F (>150°C) to 

temporarily reduce the viscosity, thereby making the mixture workable. Working at 

these high temperatures produces greenhouse gases and other criteria and hazardous 

air pollutant emissions, in addition to creating an undesirable working environment. 

These emissions are minimized by achieved-in-practice controls meeting the opacity 

requirements of District Rule 4101 (Visible Emissions) and Rule 2201 (New and 

Modified Stationary Source Review). Additionally, new technologies allowing for warmmix asphalt techniques provide better emissions control at lower temperatures. 

Achieved-in-Practice Controls for Concrete and Asphalt Processes 

For concrete production operations, achieved-in-practice controls include baghouses for 

screens, crushers, and concrete weight batchers; bin vent filters for concrete and fly ash 

silos; and water spray for other emissions points. For asphalt operations, achieved-inpractice controls include oil mist collectors and “blue smoke” control with electrostatic 

precipitators or filter packs. Dryers used for drying aggregate in the asphalt production 

process are regulated under District Rule 4309 (Dryers, Dehydrators, and Ovens), 

which limits NOx and CO to 4.3 and 42 ppmv, respectively, for gaseous-fuel fired units. 

Warm-mix Asphalt (WMA)

Asphaltic concrete, or pavement, is used worldwide for road construction. An asphaltic 

concrete mix consists of aggregate and liquid asphalt. Liquid asphalt, also termed 

asphalt cement, is a natural hydrocarbon substance primarily derived from the heaviest 

part of petroleum crude oil. The aggregate, which is basically rocks of different size, 

angularity, and hardness, is bound with the liquid asphalt to make the strongest and 

most durable pavement combination for expected road conditions.

The performance of liquid asphalt depends on the chemistry of the crude oil source and 

how it was refined. The physical properties of the liquid asphalt can also be adjusted 

with various additives, such as polymers or hydrated lime. The performance of the 

aggregate depends on the physical chemistry of the rock as well as its shape and size. 

The performance of the final asphalt mixture depends on the quality and proportions of 

the components and the quality of the construction. Asphalt pavements are typically 

95% by weight aggregate and 5% asphalt binder.93

 

93 MyAsphaltPavingProject.Com. (2011). “What are the Specifications?” Retrieved from 

http://www.myasphaltpavingproject.com/whatisasphalt/what-are-the-specifications/. 
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The high viscosity94 inherent to liquid asphalt makes it suitable for paving projects, but 

requires added heat during mixing and application. Liquid asphalt is unworkable at 

ambient temperatures, so most asphalt mixtures are manufactured, spread, and 

compacted at temperatures higher than 300°F (>150°C) to temporarily reduce the 

viscosity, thereby making the mixture workable. Working at these high temperatures 

produces greenhouse gases and other criteria and hazardous air pollutant emissions, in 

addition to creating an undesirable working environment.95

Heating and mixing takes place at a batch or drum plant where dry, and sometimes 

heated, aggregate is mixed with heated liquid asphalt. Once mixed, the asphalt is 

loaded into trucks and transported to a job site where a paver lays the asphalt mix. The 

laid asphalt mix is then compacted with rollers to reduce air voids. 

European and American companies have developed several techniques, collectively 

known as warm-mix asphalt (WMA), to increase the workability of asphalt by lowering 

the viscosity at temperatures as much as 100°F below that of hot-mix asphalt (HMA). 

WMA was introduced in Europe in 1997 and in the United States (U.S.) in 2002. 

Techniques for WMA include the use of mechanical methods, specifically foaming and 

water injection, and the use of organic or chemical additives. Mechanical methods may 

require some plant modifications, but the use of additives can, in most cases, be 

accommodated using existing plant and production technology. In all cases however, 

WMA technologies may require more finesse in controlling moisture in the aggregate 

and in the overall system operation, such as tuning of the burner to run efficiently at 

lower temperatures. Improper burner adjustment can cause the burner to not add 

enough air to burn all the fuel and may cause mix contamination. 

Mechanical methods for WMA have been shown to reduce the production temperature 

by 25-90°F. These methods include, but are not limited to, adding water-containing 

products, water-based foaming processes, and using hot coarse aggregate mixed with 

wet sand. Chemical additives for WMA have been shown to reduce the production 

temperature by 59-86°F. The additives include, but are not limited to, organic wax, 

chemical packages, cationic surfactants, surface-active agents, processing aids, and 

polymers. Additive dosages range from 0.2% to 3% by mass or weight.96

WMA has shown potential for reducing emissions associated with the production of 

asphalt for paving projects when compared to HMA. Lower temperatures required for 

production, storage, transport, and application translates to lower fuel consumption, 

which in turn reduces the criteria air pollutant emissions associated with combustion. In 

a 2013 California Department of Transportation (Caltrans) report

97, WMA was 

 

94 Viscosity is a material’s resistance to gradual deformation when stress is applied. 95 Rubio et al. (2013). “Comparative Analysis of Emissions from the Manufacture and Use of Hot and Half-Warm Mix 

Asphalt.” Journal of Cleaner Production, 41, 1-6. 96 Rubio et. al. (2012). “Warm-mix Asphalt: An Overview”. Journal of Cleaner Production, 24, 76-84. 97 Caltrans. (2013, April). Caltrans Activities to Address Climate Change: Reducing Greenhouse Gas Emissions and 

Adapting to Impacts. Retrieved from:

http://www.dot.ca.gov/hq/tpp/offices/orip/climate_change/documents/Caltrans_ClimateChangeRprtFinal_April_2013.pdf
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recognized as potentially yielding 25–35% fuel savings and thus contributing to a 

significant level of emissions reductions from manufacturing, mixing, and laying the 

asphalt. 

Asphaltic concrete production plants are regulated by District Rule 2201 (New and 

Modified Stationary Source Review Rule), Rule 4301 (Fuel Burning Equipment), Rule 

4309 (Dryers, Dehydrators, and Ovens), and Rule 4641 (Cutback, Slow Cure, and 

Emulsified Asphalt, Paving and Maintenance Operations), which have all been 

approved by EPA to meet or exceed RACT requirements. 

Benefits of WMA 

The use of WMA was initially promoted as a means of reducing emissions from road 

projects, especially in nonattainment areas98. However, after extensive research and 

numerous case studies, the potential benefits of WMA have expanded beyond reduced 

emissions. Benefits include, but are not limited to the following: 

 Improved performance: WMA improves workability and ease of compaction, 

which is critical to long-term performance of the mixture. 99

 Energy Savings: By lowering the production, storage, transport, and application 

temperatures, manufacturers require less energy to heat aggregate and liquid 

asphalt. Energy savings could potentially offset the added cost of additives or 

needed modifications to plants, especially where energy costs are high. 

Reduced plant temperatures may also cause less wear on plant equipment, thus 

reducing plant maintenance costs. 100

 Increased Capacity for Reclaimed Asphalt Pavement: WMA allows for higher 

percentages of reclaimed asphalt pavement (RAP) to be used in the mixture with 

no effect on ultimate pavement performance. The use of RAP is less expensive 

than producing an asphalt mixture from raw materials, and additional savings can 

be generated from avoiding landfill disposal or recycling fees. 

 Potential Cost Savings: Fuel savings, increase in reclaimed asphalt pavement 

content, and reductions in fuel and labor during the process of installing WMA 

translate to reduced costs for WMA projects. One cost assessment indicated 

$3,000-$6,000 in savings per lane mile.101 Life cycle assessments have shown 

reduced agency costs, user costs, and environmental costs. 

 

98 St. Martin P.E., J., California Asphalt Pavement Association. (2013, March 28). “Warm-mix Asphalt. Presentation 

to the League of California Cities Public Works Officers Institute. Sacramento, California.” Retrieved from 

http://www.cacities.org/UploadedFiles/LeagueInternet/f2/f257a42c-2d27-47d1-a641-068a32289b71.pdf. 99 MyAsphaltPavingProject.Com. (2011). “What are the Specifications?” Retrieved from 

http://www.myasphaltpavingproject.com/whatisasphalt/what-are-the-specifications/. 100 Caltrans. (2013, April). Caltrans Activities to Address Climate Change: Reducing Greenhouse Gas Emissions and 

Adapting to Impacts. Retrieved from:

http://www.dot.ca.gov/hq/tpp/offices/orip/climate_change/documents/Caltrans_ClimateChangeRprtFinal_April_2013.pdf

101 Leng & Al-Qadi. Illinois Center for Transportation, University of Illinois at Urbana-Champaign, Champaign, Illinois. 

(2011). “Comparative Life Cycle Assessment between Warm SMA and Conventional SMA.” 
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 Extended paving season: A smaller difference between the asphalt 

temperature and ambient temperature reduces the rate of cooling, which means 

paving can take place during colder weather. 

 Longer transport time: Lower temperatures required for storage allow the 

asphalt to be transported to more remote locations and introduces more flexibility 

in transportation schedules. 

 Shorter cooling time: The lower temperature allows cooling to take place in a 

shorter time, increasing the project completion rate and opening roads to traffic 

more quickly. 

 Safer working conditions: VOC and other hazardous emissions are 

significantly reduced with WMA, as is a potential burn hazard. 

Potential Emissions Reductions from WMA 

As previously mentioned, WMA production has the potential to reduce combustion 

emissions by reducing the amount of energy (fuel) needed to heat aggregate and liquid 

asphalt. While fuel savings have been reported to be from 20% to over 50% for some 

WMA technologies, U.S. studies have reported burner fuel savings of zero to 30%, with 

15% to 25% being typical.102 These fuel savings translate into reductions in criteria 

pollutants, such as NOx. 

European studies have documented the reduction of NOx emissions associated with the 

use of WMA. The table below summarizes the range of NOx emission reductions 

expected from the use of WMA; however, actual emissions reductions for U.S. 

production of WMA will vary depending on the fuel used for combustion, control 

technology, and local regulations. 

Table C-36 NOx Emission Reductions for Warm-mix Asphalt 

Vaitkus et 

al.103,104 Larsen, O.R.105 D’Angelo et al. 106 Evotherm107

NOx Reduction 60–70% 62% 60–70% 58% 

The emissions inventory for asphaltic concrete production in the Valley includes 

emissions from asphalt plants, dryers, storage piles, and vehicle traffic. As evidenced 

by the emissions inventory table for this source category, the NOx emissions from this 

source category are extremely small. In addition, only 88% of these NOx emissions are 

 

102 California Asphalt Pavement Association. (2013, March 28). “Warm-mix Asphalt. Presentation to the League of 

California Cities Public Works Officers Institute. Sacramento, California.” Retrieved from 

http://www.cacities.org/UploadedFiles/LeagueInternet/f2/f257a42c-2d27-47d1-a641-068a32289b71.pdf. 103 Vaitkus, A., Cygas, A., Laurinavicius, A. Perveneckas, Z. (2009a). Analysis and Evaluation of possibilities for the 

use of Warm Mix Asphalt in Lithuania. The Baltic Journal of Road and Bridge Engineering, 4(2), 80–86. 104 Vaitkus, A., Vorobjovas, V. Ziliut, L. (2009b). The Research on the Use of Warm Mix Asphalt for Asphalt 

Pavement Structures. Road Department, Vilnius Gediminas Technical University, Vilnius, Lithuania. 105 Larson, O.R. (2001). Warm Asphalt Mix with Foam—WAMTMFOAM. International Road Federation, 2001 Partie 

B: Themes Techniques, S.00469. Kolo Veidekke, Norway. 

106 Vaitkus et al., 2009a,b. 107 Evotherm® (2010, March). Stack Emissions & Jobsite Fumes Reductions using Evotherm® Warm Mix Asphalt. 

Available at: http://www.meadwestvaco.com/mwv/groups/content/documents/document/mwv017395.pdf 
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from production processes, as about 12% of these emissions account for associated 

vehicle traffic.108 

Feasibility of WMA 

As more tests and case studies are run in the U.S., WMA is proving to perform as 

effective as or better than HMA. Caltrans and the University of California Pavement 

Research Center have been evaluating WMA technology and its performance by testing 

rutting and cracking performance, moisture sensitivity, durability, aging, emissions, and 

stability of multiple types of WMA production.109 WMA has so far been shown to have 

equal or better overall performance compared to HMA, less smoke and odor, and 

increased workability. 110

The use of WMA in the U.S. has been growing steadily since the first test section was 

completed in 2004. Caltrans use of WMA has grown from laying about 67,000 tons of 

WMA between 2006 and 2009, to just over 2 million tons by 2012.111 To further 

encourage the use of WMA, in June 2012 Caltrans issued a directive that provided 

guidance for implementing a contractor-requested option to use an approved WMA 

technology to encourage the use of WMA by contractors.112 On a national scale, there 

are estimates that while 19.2 million tons of WMA had been placed by 2009 that value 

has increased to an estimated 500 million tons per year in 2013.

113 WMA is even being 

used in situations where safety is looked at closely, such as airport runways for Boston 

Logan and Chicago O’Hare airports. 

WMA is on the uptake and will become more widely used over time. The U.S. 

Department of Transportation Federal Highway Administration (FHWA) has chosen 

WMA for rapid deployment under its Every Day Counts (EDC) initiative. In 2013, 30% 

of paving in the U.S. was WMA, and FHWA has a goal that by 2015, half of all the 

asphalt used in the U.S. will be WMA.114 As a result of these efforts, the use of WMA is 

continuing to grow in the Valley with the current backing from state and national 

transportation agencies. 

Despite the technological feasibility of using WMA as a substitute for HMA, the cost of 

converting equipment to produce WMA remains a potential barrier to adoption. Certain 

facilities would incur more costs than others to employ this technology. More research 

into the capital costs of converting production equipment is needed to determine 

 

108 EPA, 2000,Table 1; excludes mobile source emissions; average for batch and drum plants 109 St. Martin P.E., J., California Asphalt Pavement Association. (2013, March 28). “Warm-mix Asphalt. Presentation 

to the League of California Cities Public Works Officers Institute. Sacramento, California.” Retrieved from 

http://www.cacities.org/UploadedFiles/LeagueInternet/f2/f257a42c-2d27-47d1-a641-068a32289b71.pdf. 110 Rubio, M.C., Martínez, G., Baena, L. & Moreno, F. (2012). Warm Mix Asphalt: An Overview. Journal of Cleaner 

Production, 24, 76–84. doi:10.1016/j.jclepro.2011.11.053 111 St. Martin, 2013. 112 California Department of Transportation (Caltrans). (2012, June 7). Contractor Option for Use of Warm Mix 

Asphalt Technologies in Hot Mix Asphalt. Available at: http://www.dot.ca.gov/hq/construc/CPDirectives/CPD12-2.pdf 113 St. Martin, 2013. 114 St. Martin P.E., J., California Asphalt Pavement Association. (2013, March 28). Warm Mix Asphalt. Presentation 

to the League of California Cities Public Works Officers Institute. Sacramento, California. Available at: 

http://www.cacities.org/UploadedFiles/LeagueInternet/f2/f257a42c-2d27-47d1-a641-068a32289b71.pdf
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whether WMA is cost effective for asphalt production facilities in the Valley. In addition, 

some applications may not be suitable for WMA. Just as with HMA use and application, 

WMA use is not a one-size-fits-all product. Continued studies and field tests are 

showing which product, mix, and application are best for specific uses and conditions. 

While the benefits of WMA are far-reaching, more research into the capital costs 

associated with converting production equipment to handle WMA and other feasibility 

issues is still needed to fully determine whether WMA would be feasible and cost 

effective to require for all Valley asphalt production facilities. Therefore, as discussed in 

Chapter 8 (Commitment to Leave No Stone Unturned to Evaluate Additional 

Opportunities), the District is committing to further evaluate warm mix asphalt for 

additional opportunities. 

Cutback Asphalt 

District Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, Paving and 

Maintenance Operations) contains an exemption for the use of cutback (medium cure) 

asphalt where the National Weather Service official forecast of the high temperature for 

the 24-hour period following application is below 50°F. The use of cutback asphalt 

results in VOC emissions, which do not contribute significantly to the formation of 

PM2.5. As such, this is not a potential emission reduction opportunity for this 2015 

PM2.5 Plan. Although the use of cutback asphalt has declined in recent years, Rule 

4641 maintains the exemption based on the following: 

 The exemption for cutback asphalt during colder ambient temperatures, which 

occurs during winter (non-ozone) season, is analogous to EPA’s Blue Book on 

Cutback and Emulsified Asphalt recommended seasonal exemptions (i.e. outside 

of the ozone season). 

 During colder ambient temperatures, VOCs do not evaporate rapidly, especially 

from medium cure asphalt that is limited by Rule 4641 to no more than 5% 

organic compounds that evaporate at 500°F. 

 Road construction and road repairs using asphalt are very minimal during the 

colder winter months, except for emergency road repairs. In addition, during 

winter months, the Valley experiences the majority of rainfall, including long 

periods of fog. In these conditions, asphalt will not properly cure or harden due 

to the increased moisture on the surfaces or areas where asphalt is applied and 

therefore, this type of activity is minimal. 

Evaluation Findings 

Although asphalt/concrete operations are not a significant source of PM2.5, NOx, or 

SOx in the Valley, the District evaluated the feasibility of all potential emissions 

reductions measures for this source category. As demonstrated in the above control 

measure evaluation, existing District regulations for this source category (Rules 4309 

and 4641) currently implement BACM and MSM for these sources. 

In addition, as discussed above, WMA is potentially a viable alternative to HMA and the 

benefits obtained by switching from HMA to WMA have contributed to the fast growing 

use of WMA throughout California and the Valley. FHWA’s goal of achieving 50% of 
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WMA paving by 2015 has further accelerated the widespread adoption of this 

technology throughout the country and will likely further increase the use of WMA in the 

Valley in future years. 

Although current District rules already meet BACM and MSM requirements for this 

source category, as previously mentioned, the District is committing to further evaluate 

warm mix asphalt for additional opportunities. See Chapter 8 for more information. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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C.36 SC 006 ALMOND HULLING/SHELLING OPERATIONS 

Source Category 

This control measure source category would apply to almond hulling and shelling 

operations. Almonds are harvested from orchards and transported to almond 

processing facilities, where the almonds are hulled and shelled leaving the nut, or meat. 

Orchard debris, soil, and pebbles represent 10-25% of the field weight of material 

brought to the almond processing facility. Clean almond meats are obtained as about 

20% of the field weight. Processes for removing the debris and almond hulls and shells 

are potential sources of air emissions. The Valley harvests 86% of the almonds 

produced in California. Production has roughly doubled in the last decade, with the 

2010/2011 crop year reaching 1.4 billion pounds.115

Emissions Inventory 

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day

PM2.5 0.38 0.39 0.40 0.40 0.41 0.42 0.42 0.43 0.44 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

PM2.5 0.24 0.24 0.24 0.25 0.25 0.26 0.26 0.27 0.27 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 4.0 tons per 

day (tpd) for PM2.5 dust, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in the 

above table, emissions from almond hulling/shelling operations are lower than the 

BACM/MSM significance thresholds. Therefore, the Clean Air Act does not require a 

control measure evaluation for this source category for the purpose of satisfying 

BACM/MSM requirements; however, the District has still conducted a full control 

measure evaluation for almond hulling/shelling operations. 

How would District SC 006 compare with federal and state rules and regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, and MACT for this source category. 

State Regulations 

There are no state regulations applicable to this source category. 

 

115 The Tioga Group. (2012). SJV Nut Industry Profile Preliminary Draft. Retrieved from

http://www.sjvcogs.org/pdfs/2012/Nut%20Industry%20030612.pdf. 
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How would SC 006 compare to rules in other air districts? 

There are no analogous rules for this source category in SCAQMD, BAAQMD, 

VCAPCD, or SMAQMD. 

Additional Emission Reduction Opportunities 

Evaluation of emission reduction opportunities for almond hulling and shelling 

operations included a review of ongoing research efforts, and the technologicial 

feasibility and cost effectiveness of polytetrafloroethylene (PTFE) bags. 

Ongoing Research Efforts 

Research is currently being conducted by Texas A&M University in partnership with 

almond harvesting equipment manufacturers, almond farmers, United States 

Department of Agriculture-Natural Resources Conservation Service (USDA-NRCS), and 

the District to compare “low dust” almond harvesters and an exhaust abatement devices 

to conventional harvesters in the harvesting of almonds at a Valley farm. No differences 

were detected in the particle size distribution (PSD) characteristics of PM emitted from 

each harvester, with the exception of the exhaust abatement device, where large 

particles were efficiently captured by the cyclone. Emissions of total suspended 

particulates (TSP) and PM10 trended lower for all new harvesters and were significantly 

lower for most harvesters. There were significant reductions of PM2.5 ranging from 61-

69% observed from the harvesters and a 95% reduction in PM2.5 from the Clean Air 

Concept cyclone. The results of these tests imply that new harvest technologies are 

able to reduce PM emissions without affecting product quality. 

Polytetrafloroethylene Bags 

District BACT guidelines for almond hullers and shellers require the use of a baghouse, 

which controls PM by moving the contaminated flow of air through bag type filters. The 

technology has been achieved in practice in the District. Standard polyester bags are 

the most commonly used type of bag for baghouses in the almond hulling/shelling 

industry. A layer of dust (dust cake) collects on the upstream side of these bags and 

filtering efficiency increases as the layer grows; however, they are not designed to 

provide high PM2.5 control. On the other hand, membrane type bags treated with 

polytetrafloroethlyene (PTFE) contain extremely small pores and filtering occurs on the 

bag surface instead of in a dust cake. These types of filters are capable of controlling 

99.9%116 of PM2.5 emissions, whereas baghouses with polyester bags control PM2.5 

emissions by 95-99%.117

The costs of using baghouses with PTFE bags rather than standard polyester bags 

were calculated. The pressure drop across polyester and PTFE bags is about the same 

so there should not be a significant increase in electrical costs by using one bag over 

another. Additionally, existing baghouses would not require modifications to 

accommodate PTFE bags so the increased cost lies solely in the cost of the bags. A 

 

116 EPA, Control Technology Center, Verified Technologies. (2012) Baghouse: PTFE Filters. Retrieved February 19, 

2015 from http://www.baghouse.com/products/dust-collector-filters/baghouse-filter/ptfe-filters/. 117 Roberts, C. (2009). Information on Air Pollution Control Technology for Woody Biomass Boilers. Northeast States 

for Coordinated Air Use Management and the EPA Office of Air Quality Planning and Standards.
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PTFE bag typically costs $23, whereas a polyester bag costs $12. The lifetime of both 

bags is approximately 2 years. The following cost differential was calculated, with 

knowledge that some facilities in the Valley have up to 2-3 baghouses, each with 500 

bags. District permits also require facilities to have replacement bags accounting for 

10% of the total number of bags; therefore 550 bags will be used for the following 

calculations. 

Additional Costs for Using PTFE Bags 

550 bags x ($23/ PTFE bag - $12/ polyester bag) / 2 years = $3,025/ year (per 

baghouse) 

3 baghouses x $3,025/ year = $9,075/ year (for 3 baghouses) 

Potential PM2.5 Emission Reductions from Using PTFE Bags 

The control efficiency for PM2.5 for polyester bags is assumed to be equivalent to the 

control efficiency for PM10. 

(99.9% control efficiency from PTFE bags – 99% control efficiency of polyester bags) 

= 0.9% additional control efficiency 

2015 emission inventory is 0.40 tons/day 

(0.40 tons/day PM2.5) x (0.9% additional control from using PTFE bags) 

= 0.0036 tons/day reduced 

(0.0036 tons/day reduced from using PTFE bags) x (365 days/year) 

=1.314 tons/year reduced 

Potential Cost Effectiveness of Using PTFE Bags 

101 baghouses in the Valley 

(101 baghouses) x (PTFE bag costs $3,025/ year) = $305,525/year

($305,525/year) / (1.314 tons/year reduced) = $232,515.22/ton 

The cost effectiveness of replacing polyester bags was also calculated at the lower end 

of the emission control efficiency scale (95%) with the PTFE bags to determine what a 

more conservative cost effectiveness analysis would reveal; the cost effectiveness from 

95% polyester bags to 99.9% PTFE bags is $42,706.88/ton PM2.5 reduced. 

Although the initial annual capital cost may seem relatively low; in terms of cost 

effectiveness, PTFE bags are not a cost effective alternative to standard bags. The 

additional control efficiency gains are in the fractions of tons of incremental emissions 

reductions. Additionally, as mentioned above, the emission inventory used in these 

calculations (0.40 tons/day PM2.5) includes the emissions of both almond hulling and 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

pistachio hulling, meaning the actual inventory is smaller, and making the actual cost 

effectiveness even higher than calculated. 

The cyclone is another technology in common use at Valley facilities for PM control in 

almond hulling/shelling; however, like baghouses with polyester bags, the technology 

primarily provides PM10 control. Additionally, cyclones typically achieve 80-85% control 

efficiency. Approximately 37 facilities in the Valley use cyclones to control PM 

emissions. Therefore, if these facilities were required to replace cyclones with 

baghouses, the cost effectiveness would be as follows: 

Potential PM2.5 Emission Reductions for Replacing Cyclones with Baghouses 

with PTFE Bags

The PM2.5 control efficiency for cyclones is assumed to be equivalent to the control 

efficiency for PM10 

(99.9% control efficiency of baghouse – 85% control efficiency of cyclone) 

= 14.9% additional control efficiency 

2015 emission inventory is 0.40 tons/day 

(0.40 tons/day PM2.5) x (14.9% control with use of baghouse) 

= 0.0596 tons/day reduced

(0.0596 tons/day reduced) x (365 days/year) 

= 21.754 tons/year reduced 

Potential Cost Effectiveness for Replacing Cyclones with Baghouses with PTFE 

Bags 

37 facilities to install baghouses at a minimum of $150,000 each 

With a 10 year amortization factor and 10% interest, the annualized cost for a $150,000 

baghouse would be: 

(0.1627 CRF) x ($150,000) = $24,405/year

(37 facilities) x (capital cost of baghouse $24,405/year) = $902,985/year 

($902,985/year) / (21.754 tons/year reduced) = $41,508.92/ton 

Replacing the existing cyclones with baghouses with PTFE bags would cost 

$41,508.92/ton, which does not include additional costs of installation, electrical system 

upgrades, ductwork, demolition or disposal of the cyclone. Therefore, replacing 

cyclones with baghouses is not a cost effective control option. As previously stated, the 

emissions inventory used in these calculations (0.40 tons/day PM2.5) includes the 

emissions of both almond hulling and pistachio hulling, meaning the actual inventory is 

smaller, and making the actual cost effectiveness even higher than stated. 
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 2015 Plan for the 1997 PM2.5 Standard 

Evaluation Findings

Even though almond hulling/shelling operations are not a significant source of PM2.5, 

NOx, or SOx in the Valley, the District has evaluated all potential control technologies 

and all control technologies achieved in practice in other areas or included in other state 

implementation plans. As demonstrated above, current control techniques have in 

place the most stringent measures feasible to implement in the Valley and therefore 

meet or exceed both BACM and MSM requirements for this source category. As the 

District continues to develop new attainment plans that address more stringent National 

Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from almond hulling/shelling operations in the Valley. 

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

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 2015 Plan for the 1997 PM2.5 Standard 

C.37 SC 007 PISTACHIO HULLING/SHELLING OPERATIONS 

Source Category 

This control measure source category would apply to pistachio hulling and shelling 

operations within the Valley. Pistachio hulling operations are permitted under the same 

permit with the pistachio receiving and pre-cleaning portions of the operation. These 

operations use 1D-3D cyclones to control PM emissions from the pre-cleaning portion of 

the process, which is the Best Available Control Technology (BACT) standard. 

Typically pistachio processing equipment, located after the pre-cleaning section and 

prior to the pistachio dryers, is of a wet-process design; PM emissions from this portion 

of the operation are assumed to be negligible. California produces 98.5% of U.S. 

pistachios and production has expanded greatly in the last decade. Pistachio acreage 

doubled between 1997 and 2010, and production looks like it will continue to increase in 

the near future.118 In the interest of identifying every possible strategy to reduce PM2.5 

emissions, pistachio hulling and shelling operations were evaluated for potential 

opportunities to reduce emissions; see the discussion below. 

Emissions Inventory 

The emissions inventory for this category is included as a part of the emissions 

inventory for the control measure source category for almond hulling. Refer to the 

emission inventory table presented in SC 006 for this combined inventory. 

How would District SC 007 compare with federal and state rules and regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. 

State Regulations 

There are no state regulations applicable to this source category. 

How would SC 007 compare to rules in other air districts? 

There are no analogous rules for this source category in SCAQMD, BAAQMD, 

SMAQMD, or VCAPCD. 

Additional Emission Reduction Opportunities 

Pistachio shelling operations are served by a baghouse, which is the industry standard 

for shelling operations. While there is no specific BACT guideline for shelling 

operations, baghouses are typically attributed to a PM2.5 control efficiency of 95-99%. 

As discussed above in SC 006 (Almond Hulling/Shelling Operations), 

polytetrafloroethylene (PTFE) bags have the potential to provide additional PM2.5 

control when used in baghouses but are not cost effective due to the already high 

 

118 The Tioga Group. (2012). SJV Nut Industry Profile Preliminary Draft. Retrieved from

http://www.sjvcogs.org/pdfs/2012/Nut%20Industry%20030612.pdf. 
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control efficiency of existing practices. Refer to SC 006 (Almond Hulling/Shelling 

Operations) for the cost effectiveness analysis. 

Unlike almonds which are shaken on the ground and vacuumed off the soil during 

harvesting, pistachios are caught with a canvas catcher before they hit the ground, 

which allows for a very small amount of dust and debris in addition to the pistachios. 

Much of the PM emissions associated with the processing of pistachios occur during the 

pre-cleaning stage, which is controlled by cyclones. The hulling stage is a wet process 

as the nuts are floated on water; PM emissions from this portion of the operation are 

assumed to be negligible. At this time, the District’s analysis indicates that there are no 

feasible opportunities for additional emission reduction regulatory strategies for this 

source category. 

Evaluation Findings

Even though pistachio shelling operations are not a significant source of PM2.5, NOx, or 

SOx in the Valley, the District has evaluated all potential control technologies and all 

control technologies achieved in practice in other areas or included in other state 

implementation plans. While there is no specific rule or guideline for pistachio shelling, 

the industry-standard baghouse operation described above meets or exceeds both 

BACM and MSM requirements. As the District continues to develop new attainment 

plans that address more stringent National Ambient Air Quality Standards, the District 

will continue to evaluate potential opportunities to reduce emissions from pistachio 

shelling operations in the Valley. 

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

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 2015 Plan for the 1997 PM2.5 Standard 

C.38 SC 008 AGRICULTURAL MATERIAL SCREENING/SHAKING 

OPERATIONS 

Source Category 

This control measure source category would be applicable to the handling and 

processing of agricultural materials in biomass, composting, and other agricultural 

material handling facilities. 

Emissions Inventory 

The emissions inventory for this category is accounted for in other control measure 

source categories. Refer to Appendix B for the emissions inventory. 

How would District SC 008 compare with federal and state rules and regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, and MACT requirements for this source 

category. 

State Regulations 

There are no state regulations applicable to this source category. 

How would District SC 008 compare to rules in other air districts? 

There are no analogous rules for this source category in BAAQMD, SMAQMD, or 

VCAPCD. 

SCAQMD 

 Rule 1131.1 (Chipping and Grinding Activities) 

The District evaluated the requirements contained within SCAQMD 1131.1 and found 

no requirements that were more stringent than those already in New Source Review 

Rule 2201. 

Additional Emission Reduction Opportunities 

District analysis of potential emission reduction opportunities includes an evaluation of 

the efficacy of wet suppression systems and enclosing conveyors and transfer points. 

 

Wet Suppression System 

A wet suppression system can achieve between 40-65% control of PM2.5.119 In a wet 

suppression system, water is generally applied to all emissions units, transfer points, 

and raw material stockpiles to ensure that adequate moisture is provided to the 

operation to successfully reduce PM emissions. No emissions would be reduced by 

requiring a wet suppression system because this control is currently in use at all 

identified facilities in the Valley and would be required at any new facility triggering 

BACT under the New Source Review Rule 2201. 

 

119 Environmental Protection Agency [EPA]. (1995). Compilation of Air Pollutant Emission Factors, Table B.2-3.
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

Enclosed Conveyors and Transfer Points 

Enclosing conveyors and transfer points to limit the emissions of PM is a practice used 

in addition to water spray at seven facilities in the Valley. This control option would 

potentially reduce emissions at the drop or transfer points on the conveyors. However, 

in addition to the control efficiency of enclosed conveyors being unknown, conveyors 

are already operated so that they move very slowly to avoid entraining dust and limit 

visible emissions. Therefore, the potential to reduce emissions is minimal and reduced 

emissions would not be quantifiable. 

Evaluation Findings

The District has evaluated all potential control technologies and all control technologies 

achieved in practice in other areas or included in other state implementation plans. As 

demonstrated above, current business practices have in place the most stringent 

measures feasible to implement in the Valley and therefore meet or exceed both BACM 

and MSM requirements for this source category. As the District continues to develop 

new attainment plans that address more stringent National Ambient Air Quality 

Standards, the District will continue to evaluate potential opportunities to reduce 

emissions from agricultural material screening/shaking operations in the Valley. 

 
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 2015 Plan for the 1997 PM2.5 Standard 

C.39 SC 009 TUB GRINDING 

Source Category 

This control measure source category would apply to operations using a tub grinder for 

agricultural material processing. Tub grinders are used to grind organic materials such 

as wood and agricultural materials for biomass fuel processing facilities, composting 

facilities, landscape material manufacturing (e.g. wood bark, mulch, etc.), or agricultural 

waste grinding (e.g. orchard removal, land clearing, etc.). These units are typically 

powered by diesel-fired internal combustion engines (ranging from 100 horse power 

(hp) to 1,600 hp) and mounted on wheels to be transportable, which allows the units to 

be towed to the jobsite where the piles of material are to be ground. In addition, these 

units may also be self-propelled and track-mounted; in this case the diesel engine 

powering the equipment is also used for motive power and is exempt from District 

permits since it is considered to be mobile equipment. The diesel engines powering the 

transportable units are subject to District Rule 4702 (Internal Combustion Engines) and 

Best Available Control Technology (BACT) Guideline 3.2.11. This control measure 

source category discussion addresses the particulate matter (PM) emissions from the 

loading, grinding, and conveying of the process materials. 

Emissions Inventory 

Emissions generated by the engines of the tub grinders are accounted for as a part of 

the inventory for District Rule 4702 (Internal Combustion Engines). The fugitive 

particulate emissions from these units are accounted for as a part of the stationary and 

area source emissions inventory. See Appendix B. 

How would District SC 009 compare with federal and state rules and regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, and MACT requirements for this source 

category. 

State Regulations 

There are no state regulations applicable to this source category. 

How would SC 009 compare to rules in other air districts? 

There are no analogous rules for this source category in BAAQMD, SMAQMD, or 

VCAPCD. 

SCAQMD 

 Rule 1131.1 (Chipping and Grinding Activities) 

The District evaluated the requirements contained within SCAQMD Rule 1131.1 and 

found no requirements that were more stringent than those already in District Rules 

2201 (New Source Review) and 4101 (Visible Emissions) and BACT guideline 6.4.2. 
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 2015 Plan for the 1997 PM2.5 Standard 

Additional Emission Reduction Opportunities 

Currently, fugitive particulate emissions from transportable and self-propelled tub 

grinders are controlled with a water sprinkler system during loading, grinding, and 

unloading of the process materials to prevent visible emissions in excess of 5% opacity 

per Rule 2201 (New Source Review) and BACT guideline 6.4.2. Water sprinkler 

systems achieve between 40-65% control of PM2.5.120 It is standard practice to use 

water spray on this type of equipment to meet the visible emission requirements of Rule 

4101 (Visible Emissions); therefore, requiring water control for tub grinding operations 

would not result in additional emission reductions from this source category. A potential 

control option considered would be to require a baghouse to be installed onto the trailer 

of the equipment to capture fugitive PM emissions. Due to the large size of the 

additional equipment required to be installed onto the trailer and the limited space 

available, a baghouse is not technologically feasible for a transportable unit. 

No technologically feasible or alternative basic equipment were identified in the District’s 

BACT guidelines. 

Evaluation Findings

The District has evaluated all potential control technologies and all control technologies 

achieved in practice in other areas or included in other state implementation plans. As 

demonstrated above, Rules 2201, 4101, and District BACT guideline 6.4.2 currently 

have in place the most stringent measures feasible to implement in the Valley and 

therefore meet or exceed both BACM and MSM requirements for this source category. 

As the District continues to develop new attainment plans that address more stringent 

National Ambient Air Quality Standards, the District will continue to evaluate potential 

opportunities to reduce emissions from tub grinding in the Valley. 

 

 

120 Environmental Protection Agency [EPA]. (1995). Compilation of Air Pollutant Emission Factors, Table B.2-3.
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 2015 Plan for the 1997 PM2.5 Standard 

C.40 SC 010 ABRASIVE BLASTING 

Source Category 

Abrasive blasting involves the cleaning or preparing of a surface by forcibly propelling a 

stream of abrasive material against such surface. Abrasive blasting can occur in a 

confined or an unconfined area, depending on the type of surface or application. 

Abrasive materials commonly used are walnut shells, various mineral or metal products, 

garnet, sand or aggregate, slag, steel grit abrasive, or steel shot. 

Emissions Inventory 

Pollutant 2012 2013 2014 2015 2016 2017 2018 2019 2020

Annual Average - Tons per day

PM2.5 0.33 0.34 0.35 0.36 0.37 0.38 0.40 0.40 0.41 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

PM2.5 0.33 0.34 0.35 0.36 0.37 0.38 0.39 0.40 0.41 

NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

SOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

As detailed in Chapter 5, the significance thresholds for source categories for the 

purpose of evaluating the application of BACM and MSM requirements are 4.0 tons per 

day (tpd) for PM2.5 dust, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in the 

above table, emissions from abrasive blasting are lower than the BACM/MSM 

significance thresholds. Therefore, the Clean Air Act does not require a control 

measure evaluation for this source category for the purpose of satisfying BACM/MSM 

requirements; however, the District has still conducted a full control measure evaluation 

for abrasive blasting. 

How would District SC 010 compare with federal and state rules and regulations? 

Federal Regulations 

There are no EPA CTG, ACT, NSPS, NESHAP, or MACT requirements for this source 

category. 

NESHAP/ MACT 

 40 CFR 63, Subpart XXXXXX (National Emission Standards for Hazardous Air 

Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source 

Categories)

The District evaluated the requirements contained within 40 CFR 63, Subpart XXXXXX 

and found no requirements that were more stringent than those already in District Rule 

4102 (Nuisance) and 17 CCR 6 92200 (Opacity) through 92500 (Performance 

Standards).
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State Regulations 

The following state regulations apply to sources covered under SC 010: 

 17 CCR 6, Sections 92000-92530 (Abrasive Blasting). 

How would District SC 010 compare to rules in other air districts? 

No rule from another air district has requirements beyond what is already required in 

state standards. BAAQMD Regulation 12, Rule 4 (Sandblasting), SCAQMD Rule 1140 

(Abrasive Blasting), and VCAPCD Rule 74.1 (Abrasive Blasting) regulate abrasive 

blasting operations and activities, but all simply conform to the state standards. 

Additional Emission Reduction Opportunities 

Achieved-in-practice BACT controls for sandblasting include baghouses, filters, or 

cartridge dust collectors. With such technologies, 99% control efficiency can be 

achieved. As emissions sources, sandblasting operations within the District are subject 

to District Rule 4102 (Nuisance) and the standards of 17 California Code of Regulations 

(CCR) Section 92200 (opacity) and 17 CCR Section 92500 (performance standards 

such as CARB-certified abrasives). 

Opportunities for further emissions reductions are limited because of the CH&SC 

stipulation that air districts cannot impose stricter rules on sandblasting operations. The 

District’s analysis has determined that there are no feasible opportunities for additional 

emissions reductions for this source category. 

Evaluation Findings 

Even though abrasive blasting operations are not a significant source of PM2.5, NOx, or 

SOx in the Valley, the District has evaluated all potential control technologies and all 

control technologies achieved in practice in other areas or included in other state 

implementation plans. As demonstrated above, the California Code of Regulations and 

District Rule 4102 currently provide the most stringent measures feasible to implement 

in the Valley and therefore meets or exceeds both BACM and MSM requirements for 

this source category. As the District continues to develop new attainment plans that 

address more stringent National Ambient Air Quality Standards, the District will continue 

to evaluate potential opportunities to reduce emissions from abrasive blasting 

operations in the Valley. 

 
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C.41 AMMONIA CONTROLS 

Under Subpart 4 of the CAA, regions are required to address ammonia as a precursor 

in BACM/MSM analyses and other areas of the plan unless EPA determines that 

ammonia sources do not contribute significantly to PM concentrations. To improve 

public health while also ensuring effective use of resources, additional ammonia 

controls should only be required when there is clear scientific evidence that reasonable 

measures to reduce ammonia emissions would be effective in significantly reducing 

ambient PM2.5 concentrations. 

Extensive scientific research and technical analyses (see Appendix A) demonstrate that 

ammonia reductions do not contribute to the Valley’s PM2.5 attainment; as such, 

ammonia does not need to be addressed in this BACM/MSM analysis for the 1997 

PM2.5 standard. Even though ammonia is an insignificant PM2.5 precursor in the 

Valley, the following analysis shows that the Valley’s ammonia emissions have been 

significantly reduced through stringent regulations, that additional ammonia control 

measures are infeasible, and that Valley sources currently implement BACM and MSM. 

As demonstrated in Appendix B of this 2015 PM2.5 Plan, the three main sources of 

ammonia emissions in the Valley from stationary and area sources that account for 95% 

of the Valley’s ammonia emissions are as follows (based on 2015 estimates): 

 Farming Operations with 198.0 tons per day (tpd), 

 Solvent evaporation from Agricultural Fertilizers at 116.3 tpd, and 

 Composting Solid Waste Operations at 9.0 tpd. 

The following discussion evaluates: 

 Confined Animal Facilities (District Rule 4570) 

 Agricultural Fertilizers 

 Organic Material Composting (District Rule 4566) 

 Biosolids, Animal Manure, and Poultry Litter Operations (District Rule 4565) 

 Major Sources of Ammonia 

Confined Animal Facilities (District Rule 4570)

I. District Rule Description 

District Rule 4570, was originally adopted on June 15, 2006 and was most recently 

amended on October 21, 2010. The purpose of this rule is to limit emissions of volatile 

organic compounds (VOC) from Confined Animal Facilities (CAF). District Rule 4570 

applies to facilities where animals are corralled, penned, or otherwise caused to remain 

in restricted areas and primarily fed by a means other than grazing for at least 45 days 

in any twelve-month period. In addition to limiting VOC emissions, District Rule 4570 

also includes measures that limit ammonia (NH3) emissions from these operations; the 
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required measures have reduced ammonia emissions by over 100 tpd121 (this reduction 

is reflected in the emissions inventory data above). The analysis below focuses on how 

District Rule 4570 limits NH3 emissions in comparison to other rules and regulations. 

A. Types of Confined Animal Facilities 

Confined Animal Facilities are used for the raising of animals including, but not limited 

to, cattle, calves, chickens, ducks, goats, horses, sheep, swine, rabbits, and turkeys, 

which are corralled, penned, or otherwise caused to remain in restricted areas for 

commercial agricultural purposes and fed by a means other than grazing. (CH&SC 

§39011.5 (a)(1)). The major categories of Confined Animal Facilities are listed below. 

 Dairy Operations - Dairy operations are those operations producing milk or animals 

for facilities that produce milk. 

 Poultry Operations - Poultry facilities operate either as layer ranches for egg 

production or as broiler ranches where birds are grown for the fresh meat market. 

 Beef Cattle Feeding Operations – Beef cattle facilities are facilities that raise beef 

cattle (heifers and steers) for their meat. 

 Swine Operations – These operations raise pigs for their meat. The production 

cycle for hogs has three (3) phases: farrowing (giving birth), nursing, and finishing. 

B. Rule 4570 Applicability Thresholds 

The thresholds for a facility to be classified as a large CAF in the Valley and the 

thresholds for a facility to be subject to District Rule 4570 are shown in the following 

table. The large CAF thresholds are based on the definition of a large CAF adopted by 

ARB as required by California Senate Bill (SB) 700. District Rule 4570 applies to 

confined animal facilities that have the capacity to house a number of animals equal to 

or exceeding the Rule 4570 regulatory thresholds, which are lower than the large CAF 

thresholds for certain facilities. 

 

121 Appendix F of the Staff Report for the June 2009 re-adoption of Rule 4570, starting on the 329th page of the pdf 

available here 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2009/June/Agenda%20Item_10_June_18_200

9.pdf 
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Rule 4570 Thresholds for Regulation 

Livestock Category SJVAPCD Large CAF 

Thresholds 

Rule 4570 

Regulatory Thresholds 

Dairy 1,000 milking cows 500 milking cows 

Beef Feedlots 3,500 beef cattle 3,500 beef cattle 

Other Cattle Facility 7,500 calves, heifers, or 

other cattle 

7,500 calves, heifers, or other 

cattle 

Poultry Facilities 

Chicken 650,000 head 400,000 head 

Duck 650,000 head 400,000 head 

Turkey 100,000 head 100,000 head 

Swine Facility 3,000 head 3,000 head 

Horses Facility 3,000 head 3,000 head 

Sheep and Goat 

Facilities 

15,000 head of sheep, goats, 

or any combination of the two 

15,000 head of sheep, goats, 

or any combination of the two 

Any livestock facility 

not listed above 30,000 head 30,000 head 

C. Emission Control Requirements of District Rule 4570 

District Rule 4570 requires multiple mitigation measures from the following CAF 

categories: Dairy, Beef Feedlots, Other Cattle Facilities, Swine Facilities, Poultry 

facilities, and various other smaller operations. Each of these facilities consists of 

multiple sources of emissions within the facility. Since these facilities generally cover a 

large area and have different processes, a single mitigation measure or technology is 

generally not sufficient to control overall emissions from the facility. Mitigation 

measures required by Rule 4570 have been tailored for each source of emissions, 

thereby ensuring that the overall emissions from a facility are reduced. The current 

methodology in Rule 4570 allows for the greatest overall control from the entire facility. 

District Rule 4570 recognized the following five emission sources for all of the CAFs: 

Feed, Housing, Solid Waste, Liquid Waste, and Land Application of Manure. Rule 4570 

requires each CAF to implement a certain number of mitigation measures for each of 

these sources. District Rule 4570 also distinguishes between the different types of 

housing configurations (freestall vs open corrals) for cattle and, as such, requires 

specific mitigation measures for each type of housing. By requiring mitigation 

measure(s) for each source of emissions at a facility, District Rule 4570 ensures that 

reductions are achieved throughout the facility. 

The following describes some of the mitigation measures and the ways in which these 

measures reduce ammonia emissions: 

 Nutritional management: Ammonia emissions result from the decomposition of 

undigested nitrogen compounds in animal waste. Proper nutritional 

management, with diets formulated to feed proper amounts of protein, improves 

nitrogen utilization by the animal, reducing production of ammonia from animal 

waste. 
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 Increased cleaning and removal of manure and litter from animal housing areas: 

Because animal waste is the primary source of ammonia emissions, increased 

removal of waste from animal housing areas will reduce emissions by reducing 

the exposed area. Proper management of the waste will stabilize the nitrogen 

compounds in the waste, which will reduce the rate that these compounds are 

converted to ammonia that can be lost to the atmosphere. In addition, ammonia 

is highly soluble in water; therefore, when a flush system is used, ammonia 

emissions will be reduced because much of the ammonia will dissolve in the 

water rather than volatilize to the air. 

 Incorporation of manure into fields: Incorporation of manure in fields reduces 

volatilization of gaseous pollutants by minimizing the amount of time that the 

manure is exposed to the atmosphere. Once the waste has been incorporated 

into the soil, VOCs and ammonia are absorbed onto soil particles, providing the 

opportunity for these soil microbes to oxidize these compounds into carbon 

dioxide, water, and nitrates. 

 

One area to which some of these rules may apply is silage and silage-based total mixed 

ration (TMR) used as feed for cattle. Research has demonstrated that silage and TMR 

are one of the largest sources of VOC emissions at cattle facilities but are not significant 

sources of NH3 emissions, which primarily results from the animal waste at CAFs; 

therefore, the measures that specifically apply to management of silage and TMR will 

not be discussed in detail in this analysis. 

II. How does District Rule 4570 compare with federal rules and regulations? 

A. EPA-Control Technique Guidelines (CTG) 

There is no EPA CTG guidance document for confined animal facilities. 

B. EPA - Alternative Control Technology (ACT) 

There is no EPA ACT guidance document for confined animal facilities. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS guidance document for guidance document for confined 

animal facilities. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP guidance document for confined animal facilities. 

III. How does District Rule 4570 compare to rules in other air districts?

As the largest agricultural area in California, the District took the lead in devising a list of 

mitigation measures for the various emission sources during the initial development of 
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District Rule 4570. This list of mitigation measures was essentially utilized, almost 

identically, by all air districts in their rules. However, during the last amendments to 

District Rule 4570, all of the mitigation measures were reevaluated in light of the latest 

available science. In comparison to the previous version of the rule, the current rule 

lowered threshold limits to bring in additional CAFs, requires additional mitigation 

measures, clarified previous mitigation measures, and added additional monitoring, 

testing, and recordkeeping to improve enforceability. 

The following California air district rules were compared to District Rule 4570: 

 SCAQMD Rule 223, adopted June 2, 2006 

 SCAQMD Rule 1127, adopted August 6, 2004 

 BAAQMD Regulation 2 Rule 10, adopted July 19, 2006 

 VCAPCD Rule 23 (Exemptions), amended April 8, 2008 

 SMAQMD Rule 496, adopted August, 24, 2006 

 Imperial County APCD (ICAPCD) Rule 217 and Policy Number 38, adopted 

October 10, 2006 

 Butte County AQMD (BCAQMD) Rule 450, adopted December 21, 2006

Idaho Administrative Procedure Act (IDAPA) 58.01.01 Sections 760-764 was also 

compared with District Rule 4570 and the analysis is shown below. 

It is important to note that only District Rule 4570, SMAQMD Rule 496, and SCAQMD 

Rule 1127 are prohibitory rules. For this reason, these rules include detailed 

recordkeeping as well as monitoring and testing requirements. Generally, the level of 

detail in a prohibitory rule is absent from permits rules because the purpose of a permit 

rule is different from the purpose of a prohibitory rule. 

A. SCAQMD Rule 223 

Applicability/Exemption/Large CAF Definition 

SCAQMD Rule 223 was adopted on June 2, 2006 and has not been amended. 

SCAQMD Rule 223 applies to large CAFs as defined by ARB. District Rule 4570 

defines large CAFs the same way except for large CAFs for horses. District Rule 

4570 defines a large CAF for horses as having at least 3,000 head, whereas 

SCAQMD Rule 223 defines a large CAF for horses as having at least 2,500 

head. There are currently no CAFs in the Valley with the capacity to house at 

least 2,500 horses and no CAFs for horses in the Valley are expected to exceed 

this threshold in the foreseeable future. 

In addition to applying to large CAFs, District Rule 4570 lowers the applicability 

thresholds for the following CAFs: 

 Dairies – from 1,000 milk cows to 500 milk cows 

 Broilers/Ducks and Layers – from 650,000 birds to 400,000 birds
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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Therefore, Rule 4570 is more stringent regarding applicability.

Requirements for Dairy CAFs 

Feed Mitigation Measures 

District Rule 4570 has seven mitigation measures for feed and two mitigation 

measures for silage. Operators must implement four mandatory feed mitigation 

measures and chose another one from a list of three, for a total of five mitigation 

measures required for feed. In the SCAQMD rule, there are nine feed mitigation 

measures, from which the operator must implement five. Both rules require 

selection of five mitigation measures for feed, excluding silage, but four of the 

five feed mitigation measures are mandatory in District Rule 4570. Therefore, 

overall District Rule 4570 is more stringent. 

Milk Parlor Mitigation Measures 

The milk parlor mitigation measures for SCAQMD includes one Class One and 

one Class Two mitigation measure. District Rule 4570 contains the same 

mitigation measures included in the SCAQMD rule as Class One and has 

removed the Class Two mitigation measures due to infeasibility; see the Staff 

Report for the October 21, 2010 amendments to Rule 4570 for more detail. 

Therefore, both rules will be considered identical in this category. 

Freestall Mitigation Measures 

District Rule 4570 has five mitigation measures, two of which are mandatory. 

The facility is also required to choose one additional mitigation measure from the 

remaining three. SCAQMD Rule 223 has eight Class One mitigations measures, 

from which facilities are required to implement at least two. District Rule 4570 

requires one additional mitigation measure; therefore, District Rule 4570 is more 

stringent. 

SCAQMD Rule 223 has three Class One mitigation measures that require 

increased frequency in comparison to the corresponding District Rule 4570 

measures: (inspect water pipes and troughs and repair leaks; remove animal 

waste that is not dry from individual cow freestall beds; and rake, harrow, scrape, 

or grade bedding in freestalls). The South Coast rule requires pipes and troughs 

to be inspected daily, and manure from freestall beds to be removed daily, 

whereas District Rule 4570 does not require inspection of pipes and troughs in 

freestall barns. In the Valley, the majority of freestall barns use flush systems for 

manure management and may also use misters or water sprays to keep animals 

cool; therefore, inspection of the pipes and troughs in the freestall barns was 

determined to be irrelevant since this is already a wet system. SCAQMD Rule 

223 requires freestall beds to be raked/harrowed/graded at least twice every 

seven days, whereas District Rule 4570 requires this measure to be carried out 

once every 7 days for large dairies and once every 14 days for medium dairies. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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Although, SCAQMD Rule 223 has a higher frequency for these measures, the 

emissions generated from these sources are not significant, including the 

reductions achieved from the overall dairy. In addition, the CAF stakeholders 

have questioned the cost effectiveness of a daily frequency. 

Corral Mitigation Measures 

District Rule 4570 has nine mitigation measures, six of which are mandatory. 

The facility is also required to choose one additional mitigation measure from the 

remaining three. SCAQMD Rule 223 has 14 Class One mitigation measures and 

two Class Two mitigation measures, from which facilities are required to choose 

at least six. District Rule 4570 requires one additional mitigation measure; 

therefore, District Rule 4570 is more stringent. 

SCAQMD Rule 223 has one Class One mitigation measure (inspect water pipes 

and troughs and repair leaks) that require increased frequency in comparison to 

the corresponding District Rule 4570 measure. SCAQMD Rule 223 requires this 

measure to be carried out daily, whereas District Rule 4570 requires it to be 

carried out only once every seven days. Although, SCAQMD Rule 223 has a 

higher frequency for this measure, the difference in the emissions reductions 

from the two frequencies is not expected to be significant. 

Solid Waste and Separated Solids Mitigation Measures 

District Rule 4570 contains only two mitigation measures, from which operators 

are required to choose at least one. SCAQMD Rule 223 has three Class One 

mitigation measures and three Class Two mitigation measures, from which 

facilities are required to choose at least two. 

Available studies have indicated that NH3 emissions from stored solid waste and 

separated solids pile to be a very small fraction of total NH3 emissions at dairies. 

Since the NH3 emissions from solid manure account for a very small fraction of 

emissions from the overall dairy, there would not be a significant increase in NH3 

emission reductions if more measures are required from this category. 

Liquid Waste Mitigation Measures 

District Rule 4570 has four mitigation measures, from which operators are 

required to choose at least one. SCAQMD Rule 223 has five Class One 

mitigation measures and five Class Two mitigation measures, from which 

operators are required to choose at least one. Since only one measure is 

required by both rules, the rules are similar in stringency. 

Manure Land Application Mitigation Measures 

District Rule 4570 has two mitigation measures required out of six optional 

measures. SCAQMD Rule 223 has four mitigation measures, from which 
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facilities are required to choose at least two. All the mitigation measures are 

similar in stringency. 

Requirements for Poultry CAFs 

There is a large degree of variability in the manure management practices, 

housing techniques, and potential feeding practices for the different type of 

poultry operations in the Valley. Due to these differences, District Rule 4570 

separates poultry CAFs into the following categories: 1) layers and 2) broilers, 

ducks, and turkeys. 

Although on the surface the poultry requirements results in fewer mitigation 

measures compared to the other rules, the segregating of the types of poultry 

has allowed the mitigation measures to be tailored specifically to the type of 

poultry operation. In addition, all measures for poultry in District Rule 4570 are 

now mandated rather than left as options. Due to this reconfiguration and taking 

into consideration the latest science, the District Rule 4570 requirements for 

poultry are more stringent than SCAQMD Rule 223. 

Requirements for Other CAF Categories 

In addition to dairy and poultry CAF mitigation measures discussed above, 

District Rule 4570 provides specific mitigation measures for beef cattle feedlots, 

other cattle, and swine CAFs. SCAQMD Rule 223 does not address mitigation 

measures for these additional CAF categories. For these types of large CAFs, 

District Rule 4570 is more stringent. 

Requirements – Suspension and Substitution of Mitigation Measures 

Both rules allow the temporary suspension of a mitigation measure upon the 

determination by a certified veterinarian or nutritionist that such a suspension is 

necessary for animal health purposes. The District must be notified within 48 

hours, and a new measure must be implemented if the suspension is expected to 

last longer than 30 days. In addition, both rules allow for substitution of one 

mitigation measure with an equivalent or more stringent one with the submission 

of the appropriate information. Therefore, the suspension and substitution 

requirements of both rules are equally stringent. 

Conclusion – Comparison with South Coast AQMD Rule 223 

Based on the analysis of the CAF categories in District Rule 4570 and SCAQMD 

Rule 223, it is clear that District Rule 4570 is more stringent than SCAQMD Rule 

223. There are differences in the frequency with which some mitigation 

measures are to be implemented. However, as stated earlier, many of these 

sources are a small portion of a dairy’s overall emissions. The amended version 

of District Rule requires facilities to choose more mitigation measures and makes 

several mitigation measures mandatory. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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District Rule 4570 also provides mitigation for more CAF categories (beef 

feedlots, other cattle, and swine) that are not addressed by SCAQMD Rule 223, 

and also has much more detailed recordkeeping requirements to demonstrate 

implementation of selected mitigation measures. In addition, SCAQMD recently 

identified District Rule 4570 as the most stringent rule for this source category in 

their ozone Reasonably Available Control Technology (RACT) Demonstration.122

B. SCAQMD Rule 1127 

Applicability/Exemption/Large CAF Definition 

SCAQMD Rule 1127 was adopted on August 4, 2004 and has not been

 amended. 

SCAQMD Rule 1127 applies to dairies with 50 or more cows, heifers, and/or 

calves. The rule applies to dairy farms and related operations such as heifer and 

calf farms and the manure produced on them. By comparison, District Rule 4570 

applies to dairy CAFs with at least 500 milking cows, but applies to more than 

just manure-handling operations. Although the SCAQMD Rule has a lower 

applicability threshold, the overall control effectiveness of Rule 1127 when 

compared to District Rule 4570, is far less stringent. 

Requirements for Dairy CAFs 

Milking Parlor and Freestall Mitigation Measures 

For the milking parlor, the District rule has one mandatory mitigation measure. 

District Rule 4570 has five mitigation measures for freestalls, two of which are 

mandatory. The facility is also required to choose one additional mitigation 

measure from the remaining three to implement. SCAQMD Rule 1127 does not 

address these operations. Therefore, overall District Rule 4570 is more stringent 

than SCAQMD Rule 1127. 

Corral Mitigation Measures 

District Rule 4570 has nine mitigation measures, six of which are mandatory. 

The facility is also required to choose one additional mitigation measure from the 

remaining three. SCAQMD Rule 1127 has eight mitigation measures, from which 

facilities are required to choose at least six. The mitigation measures required by 

SCAQMD Rule 1127 specify the removal of manure from the corrals, the 

minimization of water in the corrals, and the cleaning schedule and cleaning 

strategy for the corrals. While the mitigation measures in the two rules are not 

 

122 South Coast Air Quality Management District (June 6, 2014). Reasonably Available Control Technology 

Demonstration. http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-jun6-

031.pdf?sfvrsn=2
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phrased the same way, they cover similar requirements. District Rule 4570 

requires one additional measure; therefore, Rule 4570 is more stringent. 

Solid Waste, Separated Solids, and Liquid Waste, and Manure Land Application 

Mitigation Measures 

District Rule 4570 has two mitigation measures for solid waste/separated solids, 

from which operators are required to choose at least one. For liquid waste, 

District Rule 4570 has four mitigation measures for liquid waste, from which 

operators are required to choose at least one. District Rule 4570 has two 

mitigation measures for land application of manure required out of six optional 

measures. SCAQMD Rule 1127 states that manure removed must be either 

treated at an approved manure processing operation, or applied on agricultural 

land with local approval. SCAQMD Rule 1127 does not specify different 

mitigation measures for solid waste, separated solids, or liquid waste. District 

Rule 4570 has specific mitigation measures for each of these operations; 

therefore, it is able to better target the reduction of emissions from these the 

different operations. District Rule 4570 is therefore as stringent as or more 

stringent than SCAQMD Rule 1127. 

Requirements for Other CAFs 

District Rule 4570 provides specific mitigation measures for beef cattle feedlots, 

other cattle facilities, poultry facilities, and swine facilities. SCAQMD Rule 1127 

does not address mitigation measures for these additional CAF categories. 

Therefore, District Rule 4570 is more stringent for this category. 

Requirements – Suspension and Substitution of Mitigation Measures 

SCAQMD Rule 1127 provides one exemption per year from one of the corral 

clearings required every 90 days if the moisture content in the corrals is greater 

than 50%. The operator is required to notify SCAQMD 30 days before the 

required cleaning, and test moisture content weekly. If moisture content is still 

above 50% when the cleaning is due, the operator may claim the exemption. 

In comparison, District Rule 4570 allows an operator to temporarily suspend any 

mitigation measure as long as the suspension is recommended by a licensed 

veterinarian of animal nutritionist on the basis of animal health. The operator 

must notify the District within 48 hours prior to the suspension. If the suspension 

is expected to last longer than 30 days, then the operator must submit a new 

mitigation plan that identifies a new mitigation measure to be implemented in 

place of the suspended one. 

District Rule 4570’s exemption under this category is much more stringent 

because it is only a temporary suspension that cannot exceed 30 days, whereas 

SCAQMD Rule 1127’s exemption may be permanent, without any requirement to 

substitute another measure. 
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Therefore, in this category of mitigation measure suspensions/substitutions, 

District Rule 4570 is more stringent than SCAQMD Rule 1127. 

Testing, Monitoring, Recordkeeping Requirements 

Both SCAQMD Rule 1127 and District Rule 4570 require monitoring, record 

keeping and source testing as appropriate and sufficient to provide evidence of 

each mitigation measure being implemented. 

In addition to recordkeeping, Rule 1127 requires an annual report of manure 

being shipped out from the dairy. No annual reporting is required by Rule 4570. 

Rule 1127 requires records be retained for 3 years for minor sources and 5 years 

for major sources, whereas Rule 4570 requires records be retained for five years 

for all sources. 

Overall, the monitoring, testing and recordkeeping requirements are similar for 

both rules. 

Conclusion – Comparison with SCAQMD Rule 1127 

For dairy CAFs, District Rule 4570 is more stringent than SCAQMD Rule 1127. 

District Rule 4570 requires emission reductions from additional emission 

categories - milk parlors, freestall barns, and liquid manure - that are not 

addressed by SCAQMD Rule 1127 as well as requiring emission reductions from 

CAFs from other animal species. As mentioned above, the current version of 

District Rule 4570 requires facilities to choose more mitigation measures and 

makes several mitigation measures mandatory. District Rule 4570 also provides 

specific mitigation measures for beef cattle feedlots, other cattle, poultry, and 

swine CAFs, while SCAQMD Rule 1127 does not. District Rule 4570 is therefore 

more stringent than SCAQMD Rule 1127.

C. BAAQMD Regulation 2 Rule 10 (Rule 2-10) 

BAAQMD Rule 2-10 is a permit rule. As such, it has fewer specifics about large 

CAFs than District Rule 4570, which is a prohibitory rule. 

Applicability/Exemption/Large CAF Definition 

 

BAAQMD Rule 2-10 was adopted on July 19, 2006 and has not been amended. 

BAAQMD Rule 2-10 applies to large CAFs as defined by ARB. District Rule 

4570 defines large CAFs the same way except for large CAFs for horses. 

District Rule 4570 defines a large CAF for horses as having at least 3,000 head, 

whereas BAAQMD Rule 2-10 defines a large CAF for horses as having at least 

2,500 head. There are currently no CAFs in the Valley with the capacity to house 

at least 2,500 horses and no CAFs for horses in the Valley are expected to 

exceed this threshold in the foreseeable future. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-251 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

In addition to applying to large CAFs, District Rule 4570 lowers the applicability 

thresholds for the following CAFs: 

 Dairies – from 1,000 milk cows to 500 milk cows 

 Broilers/Ducks and Layers – from 650,000 birds to 400,000 birds

Therefore, Rule 4570 is more stringent regarding applicability.

Requirements for CAFs 

The BAAQMD permit conditions must implement control measures that represent 

Reasonably Available Control Technology (RACT) to reduce emissions of VOC, 

NOx and PM from the facility. BAAQMD Rule 2-10 requires RACT mitigation 

measures rather than the more stringent BARCT controls required by District 

Rule 4570 as specifically noted in the BAAQMD staff report for their rule. District 

staff previously contacted BAAQMD staff and verified that there is no list of 

RACT mitigation measures in place should a large CAF apply for a permit. In 

this respect, District Rule 4570 is more stringent than BAAQMD Rule 2-10. 

Testing, Monitoring, Recordkeeping Requirements 

District Rule 4570 requires records to be maintained and retained for at least five 

years, whereas BAAQMD Rule 2-10 requires records to be retained for three 

years. District Rule 4570 therefore has a more stringent record retention 

requirement. 

District Rule 4570 requires facilities not subject to the mitigation measure 

requirements to maintain sufficient records to demonstrate their exemption 

status. Facilities subject to the mitigation measure requirements must maintain 

sufficient records to demonstrate implementation of each mitigation measure 

selected. Facilities must also maintain animal population records. BAAQMD 

Rule 2-10 requires the maintenance of animal population records but does not 

require specific records needed to demonstrate implementation of each 

mitigation measure selected. District Rule 4570 is therefore more stringent in the 

type of records that must be maintained. 

Conclusion – Comparison with Bay Area AQMD Regulation 2 Rule 10

District Rule 4570 requires facilities to choose specific mitigation measures and 

makes several mitigation measures mandatory. In addition, District Rule 4570 

has lower applicability thresholds for dairies, chickens, and ducks. Based on this 

information and the discussion above, District Rule 4570 is far more stringent 

than BAAQMD Rule 2-10.
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D. VCAPCD Rule 23 – Exemptions from Permit 

In response to California Senate Bill (SB) 700, VCAPCD revised its “Exemptions 

from Permit” rule to remove an exemption for agricultural operations, including 

CAFs. VCAPCD does not have a specific rule for CAFs. In its staff report for the 

rule revision, VCAPCD staff noted that no facilities in their jurisdiction would meet 

the “large CAF” definition and there was no expectation that a large CAF would 

move into the area in the foreseeable future; therefore, no separate CAF rule 

was necessary. 

Applicability/Exemption/Large CAF Definition 

VCAPCD Rule 23 adopted ARB’s definition of large CAFs. District Rule 4570 

defines large CAFs the same way except for large CAFs for horses. District Rule 

4570 defines a large CAF for horses as having at least 3,000 head, whereas 

VCAPCD Rule 23 defines a large CAF for horses as having at least 2,500 head. 

There are currently no CAFs in the Valley with the capacity to house at least 

2,500 horses and no CAFs for horses in the Valley are expected to exceed this 

threshold in the foreseeable future. 

In addition to applying to large CAFs, District Rule 4570 lowers the applicability 

thresholds for the following CAFs: 

 Dairies – from 1,000 milk cows to 500 milk cows 

 Broilers/Ducks and Layers – from 650,000 birds to 400,000 birds

Therefore, Rule 4570 is more stringent regarding applicability.

Requirements for CAFs 

There are no facilities that would trigger the large CAF threshold within Ventura 

County, as stated in the VCAPCD staff report for amending Rule 23. The 

VCAPCD New Source Review Rule does not list mitigation measures for large 

CAFs. Instead, BACT would be triggered by a new CAF that met the “large CAF” 

definition or BACT would be triggered if an existing CAF expanded operations 

enough to meet the “large CAF” definition. At that point, VCAPCD staff would 

determine BACT for the CAF. 

Conclusion – VCAPCD Rule 23 

VCAPCD does not have a specific rule for CAFs; therefore, District Rule 4570 is 

more stringent. 

E. SMAQMD Rule 496 

Like District Rule 4570, SMAQMD Rule 496 is a prohibitory rule, meaning that 

there are detailed requirements for operators. 
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Applicability/Exemption/Large CAF Definition 

SMAQMD Rule 496 was adopted on August 24, 2006 and has not been

amended. 

SMAQMD Rule 496 applies to large CAFs as defined by ARB. District Rule 4570 

defines large CAFs the same way except for large CAFs for horses. District Rule 

4570 defines a large CAF for horses as having at least 3,000 head, whereas 

SMAQMD Rule 496 defines a large CAF for horses as having at least 2,500 

head. There are currently no CAFs in the Valley with the capacity to house at 

least 2,500 horses and no CAFs for horses in the Valley are expected to exceed 

this threshold in the foreseeable future. 

In addition to applying to large CAFs, District Rule 4570 lowers the applicability 

thresholds for the following CAFs: 

 Dairies - 1,000 milk cows to 500 milk cows 

 Broilers/ducks and Layers – 650,000 – 400,000

Therefore, Rule 4570 is more stringent regarding applicability.

Requirements for Dairy CAFs 

Feed Mitigation Measures 

District Rule 4570 has seven mitigation measures for feed and two mitigation 

measures for silage. Operators must implement four mandatory feed mitigation 

measures and chose another one from a list of three, for a total of five mitigation 

measures required for feed. 

SMAQMD Rule 496 has seven Class One mitigation measures for feed and two 

Class One mitigation measures for silage. Operators must implement four feed 

mitigation measures and one silage mitigation measure. 

District Rule 4570 requires a total of five feed mitigation measures, excluding 

silage, which is greater than the four feed mitigation measures required by 

SMAQMD Rule 496. In addition, four of the five feed mitigation measures are 

mandatory in District Rule 4570. Therefore, District Rule 4570 is more stringent. 

Milk Parlor Mitigation Measures 

District Rule 4570 has one required milk parlor mitigation measure. SMAQMD 

Rule 496 also only requires one mitigation measure for milk parlors. Since both 

rules only require the use of one mitigation measure, both rules will be 

considered identical for this category. 
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Freestall Mitigation Measures 

District Rule 4570 has five freestall mitigation measures, two of which are 

mandatory. The facility is also required to choose one additional mitigation 

measure from the remaining three. SMAQMD Rule 496 has eight Class One 

mitigations measures and one Class Two mitigation measure from which facilities 

are required to implement at least two. 

Rule 4570 is more stringent since it requires more mitigation measures. 

Corral Mitigation Measures 

District Rule 4570 has nine corral mitigation measures, six of which are 

mandatory. The facility is also required to choose one additional mitigation 

measure from the remaining three. SMAQMD Rule 496 has 15 Class One 

mitigation measures, which are all optional, and three Class Two mitigation 

measures, from which facilities are required to choose at least six. District Rule 

4570 requires one additional mitigation measure; therefore in this respect District 

Rule 4570 is more stringent. 

SMAQMD Rule 496 has one Class One mitigation measure (inspect water pipes 

and troughs and repair leaks) that requires increased frequency in comparison to 

the corresponding District Rule 4570 measure. SMAQMD Rule 496 requires this 

measure to be carried out daily, whereas District Rule 4570 requires it to be 

carried out only once every seven days. Although, SMAQMD Rule 496 has a 

higher frequency for this measure, the difference in the emissions reductions 

from the two frequencies is not expected to be significant. Overall, District Rule 

4570 is more stringent. 

Solid Waste and Separated Solids Mitigation Measures 

District Rule 4570 contains only two mitigation measures, from which operators 

are required to choose at least one. SMAQMD Rule 496 has five Class One 

mitigation measures and three Class Two mitigation measures, from which 

facilities are required to choose at least two. 

Available studies have indicated that NH3 emissions from stored solid waste and 

separated solids pile to be a very small fraction of total NH3 emissions at dairies. 

Since the NH3 emissions from solid manure account for a very small fraction of 

emissions from the overall dairy, there would not be a significant increase in NH3 

emission reductions if more measures are required from this category. 

Liquid Waste Mitigation Measures 

District Rule 4570 has four mitigation measures mitigation measures, from which 

operators are required to choose at least one. SMAQMD Rule 496 has four 

Class One mitigation measures and four Class Two mitigation measures, from 
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which facilities are required to choose at least one. Since only one measure is 

required, both rules are equivalent in this respect. 

Manure Land Application Mitigation Measures 

District Rule 4570 has two mitigation measures required out of six measures. 

SMAQMD Rule 496 has six Class One mitigation measures, from which facilities 

are required to choose at least two. Since two mitigation measures are required, 

both rules are equivalent in this respect. 

Requirements for Poultry Large CAFs 

There is a large degree of variability in the manure management practices, 

housing techniques, and potential feeding practices for the different type of 

poultry operations in the Valley. Due to these differences, District Rule 4570 

separates poultry CAFs into the following categories: 1) layers and 2) broilers, 

ducks, and turkeys. 

Although on the surface the poultry requirements results in fewer mitigation 

measures compared to the other rules, the segregating of the types of poultry 

has allowed the mitigation measures to be tailored specifically to the type of 

poultry operation. In addition, all measures for poultry in District Rule 4570 are 

now mandated rather than left as options. Due to this reconfiguration and taking 

into consideration the latest science, District Rule 4570 requirements for poultry 

are more stringent than SMAQMD Rule 496. 

Other CAFs 

In addition to dairy and poultry CAF mitigation measures discussed above, 

District Rule 4570 provides specific mitigation measure option tables for beef 

cattle feedlots, other cattle facilities, and swine facilities. SMAQMD Rule 496 

does not address mitigation measures for these additional CAF categories. For 

these types of large CAFs, District Rule 4570 is more stringent. 

Requirements – Suspension and Substitution of Mitigation Measures 

Both rules allow for substitution of one mitigation measure with an equivalent or 

more stringent measure with the submission of the appropriate application. 

District Rule 4570 also allows the temporary suspension of a mitigation measure 

upon the determination by a certified veterinarian or nutritionist that such a 

suspension is necessary for animal health purposes. The District must be 

notified within 48 hours, and a new measure must be implemented if the 

suspension is expected to last longer than 30 days. SMAQMD Rule 496 does 

not have a specific provision for temporary suspension of mitigation measures. 

As discussed above, District Rule 4570 is as stringent as SMAQMD Rule 496.
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Testing, Monitoring, Recordkeeping Requirements 

The testing, monitoring, and recordkeeping provisions of District Rule 4570 and 

SMAQMD Rule 496 are nearly identical and are of equal stringency. 

Conclusion – Comparison with Sac Metro AQMD Rule 496 

For dairy CAFs, District Rule 4570 is more stringent than SMAQMD Rule 496. 

District Rule 4570 requires emission reductions from four additional emission 

categories - milk parlors, feed, freestall barns, and liquid manure - that are not 

addressed by SMAQMD Rule 496 as well as having specific requirements for 

other types of CAFs. District Rule 4570 also requires facilities to choose more 

mitigation measures and mandates several mitigation measures. In addition, 

Rule 4570 applies to dairies with greater than 500 milk cows and 400,000 layers 

and broilers while SMAQMD Rule 496 applies to dairies with 1,000 milk cows or 

more and broiler and layer operations with more than 650,000 birds. As shown 

in the discussion above, District Rule 4570 is more stringent than SMAQMD Rule 

496. 

F. ICAPCD Rule 217 – Large Confined Animal Facilities Permits Required and 

ICAPCD Policy Number 38 – Recommended Mitigation Measures for Large 

Confined Animal Facilities 

ICAPCD Rule 217 is a permits rule. ICAPCD Rule 217 requires that owners or 

operators of large CAFs submit an emissions mitigation plan that demonstrates 

that the facility will use RACT to reduce emissions of pollutants that contribute to 

the non-attainment of any ambient air quality standard and are within the 

ICAPCD’s regulatory authority. 

ICAPCD Rule 217 requires operators of large CAFs to implement the control 

measures identified in their emissions mitigation plan, which may be selected 

from the ICAPCD Policy Number 38, Recommended Mitigation Measures for 

Large Confined Animal Facilities. ICAPCD Policy Number 38 specifies the 

number of mitigation measures the operator should implement for each operation 

within the CAF. The following discussion compares the recommended mitigation 

measures in ICAPCD Policy Number 38 to the measures in District Rule 4570. 

However, since the mitigation measures in ICAPCD Policy Number 38 are only 

recommended by ICAPCD Rule 217 rather than being explicitly required, it is 

clear that District Rule 4570 is more stringent. 

Applicability/Exemption/Large CAF Definition 

ICAPCD Rule 217 was adopted on October 10, 2006 and has since not been 

amended. 

ICAPCD adopted ARB’s definition of large CAF. District Rule 4570 defines large 

CAFs the same way except for large CAFs for horses. District Rule 4570 defines 
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a large CAF for horses as having at least 3,000 head, whereas ICAPCD Rule 

217 defines a large CAF for horses as having at least 2,500 head. There are 

currently no CAFs in the Valley with the capacity to house at least 2,500 horses 

and no CAFs for horses in the Valley are expected to exceed this threshold in the 

foreseeable future. 

In addition to applying to large CAFs, District Rule 4570 lowers the applicability 

thresholds for the following CAFs: 

 Dairies – from 1,000 milk cows to 500 milk cows 

 Broilers/Ducks and Layers – from 650,000 birds to 400,000 birds

ICAPCD Policy Number 38 only lists mitigation measures for dairy operations and 

beef feedlot operations while District Rule 4570 covers additional CAFs (swine, 

chicken layer, chicken broiler, duck and turkey, and other CAFs). Therefore, 

more CAFs are subject to the requirements of District Rule 4570 than ICAPCD 

Rule 217 and Policy Number 38. 

Therefore, Rule 4570 is more stringent regarding applicability.

Requirements for Dairy CAFs 

Milk Parlor Mitigation Measures 

ICAPCD Policy Number 38 has only one mitigation measure for the milk parlor. 

The District rule also only has one mitigation measure. Since the mitigation 

measure is identical, both rules are identical under this section. 

Freestall Mitigation Measures 

District Rule 4570 has five freestall mitigation measures, two of which are 

mandatory. The facility is also required to choose one additional mitigation 

measure from the remaining three. ICAPCD Policy Number 38 has eight 

mitigation measures, from which operators are required to choose at least two. 

Since District Rule 4570, requires three mitigation measures and mandates two 

out of the three, District Rule 4570 is more stringent than ICAPCD Policy Number 

38. 

Corral Mitigation Measures 

District Rule 4570 has nine mitigation measures, six of which are mandatory. 

The facility is also required to choose one additional mitigation measure from the 

remaining three. ICAPCD Policy Number 38 has eight mitigation measures, from 

which facilities are required to choose at least four. 

For three of the mitigation measures, the compliance times differ between the 

District rule and ICAPCD Policy Number 38. For these measures, ICAPCD 

Policy Number 38 allows longer time periods between repeated performance of 
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the measures than District Rule 4570. For these three mitigation measures, 

District Rule 4570 is more stringent because District Rule 4570 requires repeated 

performance of the otherwise identical mitigation measures in shorter time 

periods. 

For two of the mitigation measures, the maximum depth of manure differs 

significantly between the District Rule 4570 and ICAPCD Policy Number 38. For 

these measures, ICAPCD Policy Number 38 allows manure depths that are 

deeper than allowed by District Rule 4570. For these two mitigation measures, 

District Rule 4570 rule is more stringent because the District Rule 4570 requires 

shallower manure depths for otherwise identical mitigation measures. 

Therefore, District Rule 4570 is far more stringent than the ICAPCD Policy 

Number 38. 

Solid Waste and Separated Solids Mitigation Measures 

District Rule 4570 has two solid waste and separated solids mitigation measures, 

from which operators are required to choose at least one. ICAPCD Policy 

Number 38 has four mitigation measures from which facilities are required to 

choose at least one. Therefore, both rules are identical in this category. 

There are a few differences in ICAPCD Policy Number 38 mitigation measures 

when compared to District Rule 4570. ICAPCD Policy Number 38 policy requires 

that manure piles are covered year round whereas District Rule 4570 requires 

that the piles be covered from October through May – the months in the Valley in 

which rainfall is most likely. However, because of the greater depth of manure 

allowed in corrals and increased duration (up to two years) for removal of manure 

from the corrals allowed by ICAPCD Policy Number 38, CAFs in the ICAPCD are 

able to allow manure to accumulate in the corrals until it can be hauled offsite. 

Few, if any, CAFs in the ICAPCD are expected to actually store manure onsite 

outside of corrals, so it is likely that no facilities in ICAPCD are actually choosing 

and implementing this measure. Separated solids piles are not specifically 

addressed in ICAPCD Policy Number 38. Overall District Rule 4570 is as 

stringent as ICAPCD Policy Number 38. 

Liquid Waste Mitigation Measures 

District Rule 4570 has four liquid waste mitigation measures, from which 

operators are required to choose at least one. ICAPCD Policy Number 38 has 

four mitigation measures, from which operators are required to choose at least 

one. ICAPCD Policy Number 38 contains an option to manage the facility so 

that lagoons only contain waste from milking parlor and storm water as a 

mitigation measure. District Rule 4570 does not contain this option. This 

difference, although worth noting, is not expected to influence the overall 

effectiveness of District Rule 4570; District Rule 4570 is as stringent as ICAPCD 

Policy Number 38. 
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C-259 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

Manure Land Application Mitigation Measures 

District Rule 4570 has two mitigation measures that are mandatory if applicable. 

ICAPCD policy has a menu of five mitigation measures from which operators are 

required to choose two. Since two measures are required by both ICAPCD 

Policy Number 38 and District Rule 4570, they will be considered identical under 

this category. 

Requirements for Beef Feedlot CAFs 

Animal Housing Mitigation Measures 

District Rule 4570 has nine mitigation measures, six of which are mandatory. 

The facility is also required to choose one additional mitigation measure from the 

remaining three. ICAPCD Policy Number 38 has nine mitigation measures, from 

which facilities are required to choose at least four. Since operators in Imperial 

County are required to implement fewer mitigation measures, District Rule 4570 

is more stringent. 

For three of the mitigation measures, the compliance times differ between the 

District rule and ICAPCD Policy Number 38. For these measures, ICAPCD 

Policy Number 38 allows longer time periods between repeated performances of 

the measures than District Rule 4570. For these three mitigation measures, the 

District rule is more stringent because the District Rule 4570 requires repeated 

performance of the otherwise identical mitigation measures in shorter time 

periods. 

For two of the mitigation measures, the maximum depth of manure differs 

significantly between the District Rule 4570 and ICAPCD Policy Number 38. For 

these measures, ICAPCD Policy Number 38 allows manure depths that are 

deeper than allowed by District Rule 4570. For these two mitigation measures, 

District Rule 4570 rule is more stringent because the District Rule 4570 requires 

shallower manure depths for otherwise identical mitigation measures. 

Solid Waste and Separated Solids Mitigation Measures 

District Rule 4570 has two solid waste and separated solids mitigation measures, 

from which operators are required to choose at least one. ICAPCD Policy 

Number 38 has four mitigation measures from which facilities are required to 

choose at least one. Therefore, both rules are identical in this category. 

ICAPCD Policy Number 38 policy requires that manure piles are covered year 

round whereas District Rule 4570 requires that the piles be covered from October 

through May – the months in the Valley in which rainfall is most likely. However, 

because of the greater depth of manure allowed in corrals and increased 

duration (up to two years) for removal of manure from the corrals allowed by 

ICAPCD Policy Number 38, CAFs in the ICAPCD are able to allow manure to 
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accumulate in the corrals until it can be hauled offsite. Few, if any, CAFs in the 

ICAPCD are expected to actually store manure onsite outside of corrals, so it is 

likely than no facilities in ICAPCD are actually choosing and implementing this 

measure. Overall District Rule 4570 is as stringent as ICAPCD Policy Number 

38. 

Liquid Manure Handling 

ICAPCD Policy Number 38 does not address liquid manure handling for beef 

feedlot operations. This is likely because beef feedlot facilities in ICAPCD do not 

generally use liquid manure management systems. District Rule 4570 requires 

one measure to be selected out of a menu of options, if applicable. Therefore, 

Rule 4570 is more stringent in this category. 

Manure Land Application Mitigation Measures 

District Rule 4570 has two mitigation measures that are mandatory if applicable. 

ICAPCD Policy Number 38 has a menu of five mitigation measures from which 

operators are required to choose two. Since two measures are required by both 

ICAPCD Policy Number 38 and District Rule 4570, they will be considered 

identical under this category. 

Requirements for Other CAFs 

In the same manner as for dairy and beef feedlot operations, District Rule 4570 

specifies mitigation methods for confined animal facilities other than dairies and 

beef feedlots. ICAPCD Policy Number 38 only has mitigation measures for dairy 

and beef feedlot operations. In comparing the two documents, District Rule 4570 

is therefore more comprehensive and stringent. 

Requirements – Suspension and Substitution of Mitigation Measures 

District Rule 4570 and ICAPCD Policy Number 38 allow for substitution of one 

mitigation measure with an equivalent or more stringent one with the submission 

of the appropriate application. District Rule 4570 also allows the temporary 

suspension of a mitigation measure upon the determination by a certified 

veterinarian or nutritionist that such a suspension is necessary for animal health 

purposes. The District must be notified within 48 hours, and a new measure 

must be implemented if the suspension is expected to last longer than 30 days. 

ICAPCD Policy Number 38 allows for temporary suspension of mitigation 

measures under circumstances similar to District Rule 4570. Based on the 

discussion, Rule 4570 is as stringent as ICAPCD Policy Number 38.
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 2015 Plan for the 1997 PM2.5 Standard 

Testing, Monitoring, Recordkeeping Requirements 

District Rule 4570 requires records to be maintained and retained for at least five 

years, whereas ICAPCD Rule 217 requires records to be retained for two years. 

District Rule 4570 therefore has a more stringent record retention requirement. 

District Rule 4570 requires facilities not subject to the mitigation measure 

requirements to maintain sufficient records to demonstrate their exemption 

status. Facilities subject to the mitigation measure requirements must maintain 

sufficient records to demonstrate implementation of each mitigation measure 

selected. Facilities must also maintain animal population records. ICAPCD Rule 

217 requires the maintenance of animal population records but does not require 

specific records needed to demonstrate implementation of each mitigation 

measure selected. District Rule 4570 is therefore more stringent in the type of 

records required to be maintained. 

Conclusion- Comparison with ICAPCD Rule 217 and ICAPCD Policy Number 38 

ICAPCD Rule 217 requires operators of large CAFs to implement the control 

measures identified in their emissions mitigation plan, which may be selected 

from the ICAPCD Policy Number 38, Recommended Mitigation Measures for 

Large Confined Animal Facilities; however, compliance with ICAPCD Policy 

Number 38 is not explicitly required by the rule. District Rule 4570 contains 

several mandatory mitigation measures, unlike the optional nature of the 

mitigation measures in ICAPCD Rule 217. District Rule 4570 also has a lower 

applicability threshold for dairies (500 milk cows). In addition, ICAPCD Policy 

Number 38 only lists mitigation measures for dairy operations and beef feedlot 

operations while District Rule 4570 covers additional CAFs (swine, chicken layer, 

chicken broiler, duck and turkey, and other CAFs). As shown the discussion 

above, District Rule 4570 is far more stringent than ICAPCD Rule 217 and 

ICAPCD Policy Number 38. 

G. BCAQMD Rule 450 – Large Confined Animal Facilities 

BCAQMD Rule 450 is a permits rule. It outlines, in general terms, the 

requirements for a complete permit application and how the staff would evaluate 

and approve/disapprove the permit application. 

Applicability/Exemption/Large CAF Definition 

 

BCAQMD Rule 450 was adopted on December 21, 2006 and has since not been 

amended. 

BCAQMD adopted ARB’s definition of large CAF. District Rule 4570 defines 

large CAFs the same way except for large CAFs for horses. District Rule 4570 

defines a large CAF for horses as having at least 3,000 head, whereas BCAQMD 

Rule 450 defines a large CAF for horses as having at least 2,500 head. There 
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are currently no CAFs in the Valley with the capacity to house at least 2,500 

horses and no CAFs for horses in the Valley are expected to exceed this 

threshold in the foreseeable future. 

In addition to applying to large CAFs, District Rule 4570 lowers the applicability 

thresholds for the following CAFs: 

 Dairies – from 1,000 milk cows to 500 milk cows 

 Broilers/Ducks and Layers – from 650,000 birds to 400,000 birds

Therefore, Rule 4570 is more stringent regarding applicability.

CAF Requirements 

BCAQMD Rule 450 requires large CAFs to obtain a permit and to submit and 

implement a mitigation plan; however, the rule does not list mitigation measures 

or specify the number of mitigation measures required. District Rule 4570 has a 

menu of specific mitigation measures and stipulates the number of mitigation 

measures an operator is required to implement. In this regard, District Rule 4570 

is more stringent than BCAQMD Rule 450. 

Testing, Records, and Reporting Requirements 

BCAQMD Rule 450 requires that all CAFs record the daily number of animals onsite. These records are to be kept on-site for two years and presented if 

requested. District Rule 4570 requires testing and records be kept to 

demonstrate compliance with the operator’s selected mitigation measures. The 

records are to be kept for five years and presented upon the request of EPA or 

the District. Because District Rule 4570 covers testing, as well as having a 

longer record retention time, it is more stringent than BCAQMD Rule 450. 

Conclusion – Comparison with Butte County AQMD Rule 450 

District Rule 4570 contains specifies the actual mitigation measures that facilities 

are required to implement. In addition, District Rule 4570 has lower applicability 

thresholds for dairies, chicken facilities, and duck facilities. As shown in the 

discussion above, District Rule 4570 is more stringent than BCAQMD Rule 450. 

H. IDAPA 58.01.01 Sections 760-764: Rules for the Control of Ammonia from 

Dairy Farms

Applicability/Exemption 

IDAPA 58.01.01 Sections 760-763 was adopted on March 30, 2007 and IDAPA 

58.01.01 Subsection 764.02: Table – Ammonia Control Practices for Idaho 

Dairies was last amended on May 8, 2009. 
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Pursuant to IDAPA 58.01.01 Section 761, Sections 760-764 apply to dairies of 

the following sizes. The thresholds are based on estimating the number of cattle 

required to produce 100 tons of ammonia emissions annually. Different 

thresholds are given for drylot dairies, dairies with scraped freestalls, and dairies 

with flushed freestalls. The thresholds are given on the basis of Animal Units 

(AU) (1,000 lbs of live weight) and on a mature cow equivalent basis (1,400 lbs of 

live weight). 

SUMMARY: Animal Unit (AU) or mature cow threshold to produce 100 tons 

NH3/year 

Animal Unit (AU) Basis Drylot Free Stall/Scrape Free Stall/Flush 

 AU (100 t NH3) Threshold 

No land app 7,089 3,893 

27% volatilization 2,293 1 6,842 3,827 

80% volatilization2 6,397 3,700 

 Total Cows (100 t NH3) Threshold 

Cow Basis (1,400 lb) Drylot Free Stall/Scrape Free Stall/Flush 

No land app 5,063 2,781 

1,638 

27% volatilization1 4,887 2,733 

80% volatilization2 4,589 2,643 

No land app 5,063 2,781 

1 Assumes expected level of N->NH3 volatilization for drop-hose or ground level liquid manure application. 

2 Assumes expected level of N->NH3 volatilization for center pivot or other conventional sprinkler irrigation liquid manure 

application 

The smallest dairy to which IDAPA 58.01.01 Sections 760-764 applies would 

have the equivalent of at least 1,638 mature cows in flushed freestalls and a 

larger number of animals in scraped freestalls or corrals. In comparison, District 

Rule 4570 applies to dairy CAFs with at least 500 milking cows (at least 700 AU 

or 500 mature cows). In addition, District Rule 4570 applies to other types of 

confined animal facilities, including beef cattle feedlots, other cattle facilities, 

poultry facilities, and swine facilities. Therefore, District Rule 4570 is more 

stringent regarding applicability. 

Requirements for Dairies 

Each dairy farm subject to IDAPA 58.01.01 Sections 760 - 764 must employ Best 

Management Practices (BMPs) for the control of ammonia. The BMPs are 

applied to the following systems at a dairy: Waste Storage and Treatment 

Systems, General Practices, Freestall Barns, Open Lots and Corrals, Animal 

Nutrition, Composting Practices, and Land Application. A total of twenty-seven 

(27) points must be achieved for the BMPs employed. The table located in 

Subsection 764.02 lists the approved BMPs and their associated point values. 

During development of the regulation, a point system with a maximum of 20 

points was assigned to each practice. A practice receiving 20 points equates to 
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a system or practice that is considered to result in major reduction in ammonia 

emissions for that specific process. However, according to the supporting 

documentation, this point system is “arbitrary”.123 Therefore, there is no direct 

correlation from the points required and the amount of emission reductions 

achieved. In fact, due to the flexibility allowed in this rule, even if all points have 

been met by the rule and depending on which mitigation measures are selected, 

the overall ammonia emission reductions may not be substantial. The Idaho 

Department of Environmental Quality (IDEQ) may also determine a practice not 

listed in the table constitutes a BMP and assign a point value. Points may also 

be obtained through third party export with sufficient documentation. 

The paper Commentary Ammonia-Based Air Quality Permits for Idaho Dairies124

indicated that, “Solid separation of manure, corral harrowing, low-pressure 

irrigation, composting, and rapid manure removal from outdoor lots were found to 

be the most common BMPs.” 

Solids Separation 

In the Idaho regulation, solids separation refers to “gravity or mechanical 

separation system to remove manure solids from liquid waste stream.” This 

practice has been implemented by almost all dairies in the Valley subject to 

District Rule 4570 to comply with the liquid manure mitigation measure 

requirements of District Rule 4570. 

Corral Harrowing/Cleaning 

In the Idaho regulation corral harrowing refers to harrowing to distribute 

deposited manure, reshaping corral surface, and/or removing manure from corral 

surface and rapid manure removal from outdoor lots refers to the removal of 

winter time manure and corral bedding from an open lot surface in spring or as 

quickly as practicable. District Rule 4570 has much more stringent requirements 

for corral cleaning and maintenance at dairies. For corrals, District Rule 4570 

requires dairies to implement the following measures: a) Cleaning manure from 

corrals at least four times per year with at least 60 days between cleaning, or b) 

Cleaning corrals at least once between April and July and at least once between 

September and December; a) Scraping, vacuuming, or flushing concrete lanes in 

corrals at least once every day for mature cows and every seven days for 

support stock, or b) Cleaning concrete lanes such that the depth of manure does 

not exceed twelve inches at any point or time; inspection of water pipes and 

troughs and repairing leaks at least once every seven days; and a) Sloping the 

surface of the corrals at least 3% where the available space for each animal is 

400 square feet or less and Sloping the surface of the corrals at least 1.5% 

 

123 Idaho Department of Environmental Quality (2006). Scientific Basis for the Control of Ammonia from Dairy Farms 

Best Management Practices 7/18/2006 by Ron E. Sheffield, Waste Management Engineer, University of Idaho and 

Bruce Louks, Air Quality Division, Idaho Department of Environmental Quality. 

http://www.deq.idaho.gov/media/635665-58_0101_0502_scientific_basis_final.pdf 124 Sheffield, R. E. and Louks, B. (2008). COMMENTARY: Ammonia-Based Air Quality Permits for Idaho Dairies. 

Environmental Practice, 10, pp 13-19. doi:10.1017/S1466046608080046. 

http://journals.cambridge.org/action/displayAbstract?fromPage=online&aid=1888928 
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where the available space for each animal is more than 400 square feet per 

animal, b) Maintaining corrals to ensure proper drainage preventing water from 

standing more than forty-eight (48) hours, or c) Harrowing, raking, or scraping 

corrals sufficiently to maintain a dry surface. In addition, District Rule 4570 

requires dairies to choose an additional corral mitigation measure, requiring 

corrals to be managed such that the manure depth in the corral does not exceed 

twelve inches at any time or point, except for in-corral mounding. Therefore, the 

corral cleaning and maintenance requirements of District Rule 4570 are far more 

stringent than IDAPA 58.01.01 Sections 760 – 764. 

Previous emission studies conducted in the Valley have demonstrated that the 

corrals and pens are the sources with the greatest potential for NH3 emissions in 

Valley dairies125 and, therefore, the much more stringent corral cleaning and 

maintenance measures required by District Rule 4570 have the potential for far 

greater NH3 reductions. 

Liquid Manure Application 

In the Idaho regulation, Low Energy/Pressure Application Systems refers to use 

of center pivot and liner-move irrigation strategy that applies liquids at low 

pressures using drop nozzles. The guidance for the regulation states that larger 

droplets result in lower emissions but may cause infiltration problems on some 

soils. The use of center pivot and liner-move irrigation to apply liquid manure is 

very uncommon in the Valley and may be prohibited in the use permits for many 

dairies. In the Valley it is much more common to apply liquid manure to cropland 

through flood or furrow irrigation after it has been diluted with fresh irrigation 

water as generally required by either the Water Quality Board or the local County 

and as a means to avoid damage to growing crops. Because of the reduced 

surface area, flood and furrow irrigation have even lower emissions than low 

pressure sprinkler irrigation systems. Dilution of the liquid manure with fresh 

irrigation water further reduces NH3 emissions and is also listed as a BMP in the 

Idaho regulation. Therefore, the liquid manure practices utilized in the Valley are 

more stringent than the Idaho regulation. 

Composting 

In the Idaho regulation “composting” refers to stacking and drying of separated 

manure solids or corral manure. Almost all dairies in the Valley utilize this 

practice to prepare solid manure and/or separated solids for bedding and/or for 

use on cropland. In addition, District Rule 4570 requires that dairies implement 

one of the following measures for solid manure or separated solids: 1) within 72 

hours of removal from housing, either: a) Remove dry manure from the facility, or 

b) Cover dry manure outside the housing with a weatherproof covering from 

October through May, except for times when wind events remove the covering, 

 

125 See: Schmidt, C. and Card, T. (2006) Dairy Air Emissions Report: Summary of Dairy Emission Estimation 

Procedures (May 2006). Final Report to California Air Resource Board (ARB). 

http://www.arb.ca.gov/ag/caf/SchmidtDairyEmissions2005.pdf

http://www.arb.ca.gov/ag/caf/SchmidtDairyTestData2005.pdf
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not to exceed 24 hours per event; or 2) Within seventy-two hours of removal from 

the drying process, either: a) Remove separated solids from the facility, or b) 

Cover separated solids outside the housing with a weatherproof covering from 

October through May, except for times when wind events remove the covering, 

not to exceed 24 hours per event. Therefore, the general management practices 

conducted on dairies in the Valley and the requirements of District Rule 4570 are 

far more stringent than the Idaho regulation. 

For dairy corrals, which are the largest source of NH3 emissions at dairies in the 

Valley, District Rule 4570 requires more stringent mitigation measures and a 

greater number of these measures. District Rule 4570 is also more specific in 

regards to mitigation measures required from other processes at dairies and the 

number of mitigation measures that must be implemented for each process; as a 

result, District Rule 4570 is able to better target the reduction of emissions from 

these different operations. Therefore, District Rule 4570 is more stringent than 

IDAPA 58.01.01 Sections 760- 764. 

Requirements for Other Confined Animal Facilities 

As stated above, District Rule 4570 provides specific mitigation measures for 

beef cattle feedlots, other cattle facilities, poultry facilities, and swine facilities. 

IDAPA 58.01.01 Sections 760-764 does not address mitigation measures for 

these additional categories. Therefore, District Rule 4570 is more stringent for 

this category. 

Requirements – Suspension and Substitution of Mitigation Measures 

IDAPA 58.01.01 Subsection 762.03 provides that if a dairy farm not subject to 

Sections 760-764 becomes subject to these regulations as a result of an 

emergency (for example if a dairy farmer takes additional cows due to 

unforeseen circumstances), the dairy farm must notify the IDEQ in writing within 

14 days explaining the emergency circumstances. The dairy farm would be 

exempt from these requirements for up to one year as long as the consequences 

of the emergency continue. In the event of unforeseen equipment upsets and 

breakdowns, so long as corrective action is taken within a reasonable time, the 

event does not reduce the BMP point value. 

In comparison, District Rule 4570 allows an operator to temporarily suspend any 

mitigation measure as long as the suspension is recommended by a licensed 

veterinarian or animal nutritionist on the basis of animal health. The operator 

must notify the District within 48 hours prior to the suspension. If the suspension 

is expected to last longer than 30 days, then the operator must submit a new 

mitigation plan that identifies a new mitigation measure to be implemented in 

place of the suspended one. 

District Rule 4570’s exemption under this category is much more stringent 

because it is a temporary suspension that cannot exceed 30 days, whereas the 
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IDAPA 58.01.01 Sections 760-764 exemption may last much longer, without any 

requirement to substitute another measure. 

Therefore, in this category of mitigation measure suspensions/substitutions, 

District Rule 4570 is more stringent than IDAPA 58.01.01 Sections 760-764. 

Testing, Monitoring, Recordkeeping Requirements 

Compliance with the requirements of IDAPA 58.01.01 Sections 760-764 is 

primarily determined by inspections by the Idaho State Department of 

Agriculture. The Idaho regulations do not specify what records must be kept or 

have any requirement that the records be maintained for a certain period of time. 

District Rule 4570 includes specific requirements for monitoring, source testing 

as appropriate and recordkeeping to ensure mitigation measure are being 

implemented. Facilities must also maintain animal population records. District 

Rule 4570 also requires facilities not subject to the mitigation measure 

requirements to maintain sufficient records to demonstrate their exemption 

status. District Rule 4570 requires records be retained for five years for all 

sources. District Rule 4570 is therefore more stringent in this area. 

Conclusion – Comparison with IDAPA 58.01.01 Sections 760-764 

For dairy facilities, District Rule 4570 is far more stringent than IDAPA 58.01.01 

Sections 760-764. Unlike IDAPA 58.01.01 Sections 760-764, District Rule 4570 

requires specific practices for the various operations at dairies. District Rule 

4570 also provides specific mitigation measures for beef cattle feedlots, other 

cattle facilities, poultry facilities, and swine facilities, while IDAPA 58.01.01 

Sections 760-764 does not. The measures required by the Idaho regulation are 

also based on an arbitrary point system and as such do not guarantee a specific 

degree of control. District Rule 4570 is, therefore, more stringent than IDAPA 

58.01.01 Sections 760-764.

IV. Evaluation of Additional Control Measures 

Recent studies have cited the episodic application of sodium bisulfate (SBS) onto 

manure at dairies as a potential control strategy to reduce ammonia emissions. 

SCAQMD included a potential control measure within their 2012 Air Quality 

Management Plan (AQMP) to evaluate the use of SBS at dairies to determine the 

technical and economic feasibility of its application in reducing ammonia 

emissions as well as potential impacts to groundwater. The District did not find 

any agency requiring the use of SBS. The District has evaluated SBS as a 

potential control measure and determined that for a variety of reasons that this 

control strategy is infeasible and ineffective for reducing PM2.5 concentrations in 

the Valley. 
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SBS is an acid salt that has been used to reduce pH and bacterial levels in the 

bedding for dairy cattle. Application of SBS on fresh manure or corral surfaces 

has the potential to reduce ammonia emissions by reducing the pH of the 

manure or corral surface. With a lower pH, a greater fraction of the ammonia is 

converted to non-volatile ammonium (NH4+). The ammonium combines with 

sulfate to form ammonium sulfate, which is retained in the manure or on the 

surface of the corral. 

There are a number of potential issues that need to be considered related to the 

application of SBS at dairies including, but not limited to, the health and safety of 

dairy workers and dairy cattle, impacts on water quality, and overall cost and 

effectiveness. The SCAQMD 2012 AQMP states: that potential use of SBS 

would be specific to dairies in the SCAQMD and may be unique to localized 

operations, that “the requirements may not be applicable to dairies elsewhere 

where a site-specific assessment would need to be made relative to those 

particular conditions”, and that it is likely that each air district would need to 

conduct an assessment as to the feasibility of SBS application in their 

jurisdiction. 

The SCAQMD AQMP focuses on episodic controls to reduce ammonia 

emissions during periods of high PM2.5 concentrations. PM concentrations in 

the Valley are highest during the winter season (November – February). Unlike 

the SCAQMD where the majority of dairies are open corral facilities, most dairies 

in the Valley utilize a freestall design and generally restrict the cows’ access to 

corrals during the winter months since the corrals are wet and muddy. As a 

result, there would be very little to no fresh manure excreted in corrals during the 

winter period. In addition, once wet conditions set in, it is not feasible to utilize 

tractors in the corrals to apply SBS since the tractors tend to get stuck in 

mud. Application by hand at large dairies would be very labor intensive, time 

consuming, be extremely costly, and would potentially pose health and safety 

risks to the workers. 

Although SBS is generally considered to be safe in small quantities, excessive 

loading of salts is a major water quality concern in the central and southern 

regions of the Valley where many dairies are located. In addition, applying SBS 

to corrals, which for many dairies can be greater than several acres in size, is not 

practical or feasible. Applying SBS to large areas also requires significant 

amounts of SBS to be applied, which as discussed below can be quite costprohibitive. The application of SBS will also be short lived and conflict with 

requirements from Rule 4550 which requires dairies to scrape their corrals on a 

frequent basis at least once every two weeks, making the application of SBS 

ineffective and even more costly due to the constant need to reapply. 

A dairy would also need to work with the Regional Water Quality Control Board to 

determine if the application of SBS is allowed and if a dairy’s nutrient 

management plan would need to be revised since the water quality surrounding 

dairies is a major concern and any additional impacts would need to be 
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thoroughly reviewed. This may require hauling manure significant distances to 

areas that would not be adversely affected by the increased salinity, which would 

result in increased emissions and costs related to hauling. 

There are significant costs associated with the application of SBS. Iowa State 

University Extension estimates the costs of SBS to be $660/ton. District 

estimates show that 1,304 lb-1,955 lb/cow-yr of SBS would be needed for 

application to one entire corral area, costing $430-$645/cow-yr. Using the 

District’s corral ammonia emission factor for milk cows and assuming a 

conservatively high estimate of 50% reduction in overall ammonia emissions, the 

cost of the ammonia reductions would be at least $41,067/ton to $61,601/ton or 

higher depending on corral size. Information from Iowa State shows reduced 

costs of $129-$193/cow-yr for only treating heavy use areas, such as feed bunks 

and water troughs. It is not clear how much manure is excreted in heavy use 

areas, but even if the resulting cost per ton of reduction was cut in half, the costs 

would still be significant. 

Also, because flush dairies are common in the Valley (both freestall and open 

corral), the heavy use areas will generally be paved, and frequent flushing of the 

freestall or corral lanes (as required by Rule 4570) already significantly reduces 

ammonia emissions; therefore, application of SBS to only these areas would not 

provide significant additional reductions in ammonia emissions. By design, SBS 

will be flushed to a lagoon or pond where the high buffering capacity would 

render it ineffective and possibly increase H2S emissions. 

Overall, given the insignificant PM2.5 reduction achieved per ton of ammonia 

reduction (as demonstrated in this plan), the cost effectiveness associated with 

implementing SBS translates to a much higher relative cost effectiveness when 

compared to other, more effective strategies, such as NOx reductions. 

V. Conclusion 

While BACM and MSM requirements do not apply to ammonia since it is not a 

significant precursor to PM2.5 formation in the Valley, District staff concludes that 

District Rule 4570 meets BACM and MSM requirements for ammonia emissions from 

CAFs. The District evaluated the feasibility of additional ammonia emissions reductions 

and did not identify any additional feasible measures. In fact, the SCAQMD recently 

identified District Rule 4570 as the most stringent rule for this source category.126

Agricultural Fertilizers

Farms have continued to improve methods of fertilizer application over the years to 

maximize nitrogen use efficiency and minimize environmental impacts. Best 

 

126 South Coast Air Quality Management District (June 6, 2014). Reasonably Available Control Technology 

Demonstration. http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2014/2014-jun6-

031.pdf?sfvrsn=2 
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management practices are being implemented to minimize nitrate leaching in irrigated 

crop production. Researchers at UC Cooperative Extension have been studying the 

nitrogen use efficiency for various crop types and have begun identifying the point at 

which the application of additional nitrogen no longer significantly increases crop quality 

and yields. This will allow growers to apply fertilizer with more precision to reduce the 

amount of nitrogen left in the soil. 

Agricultural operations in California are regulated by the State Water Resources Control 

Board, which is charged by the state Legislature in enforcing state and federal water 

quality protection laws. The State Water Resources Control Board consists of Regional 

Water Quality Control Boards (Regional Boards) that develop objectives and plans to 

protect the beneficial uses of water, recognizing local differences in climate, topography, 

geology and hydrology. All dairy farms in California’s Central Valley are regulated by 

the Central Valley Regional Water Quality Control Board (“Regional Board”). The vast 

majority of dairies—about 1,200 dairies—are regulated under a Regional Board General 

Order127 and the remainder are regulated via individual orders that ensure compliance 

with the same requirements. These requirements include: 

 A Nutrient Management Plan (NMP), prepared by a certified professional crop 

advisor or equivalent, designed to control nutrient losses for protection of surface 

water and groundwater; 

 A Waste Management Plan (WMP), prepared by a licensed engineer; 

 Environmental sampling and monitoring of soil, manure, water and plant tissue 

for compliance; 

 Routine site inspections, recordkeeping, and reporting; and 

 Additional groundwater monitoring to assess ongoing water quality protection 

A major purpose of these regulations is to ensure responsible storage and use of 

manure as an important crop fertilizer and soil builder, thus preventing unnecessary 

runoff or leaching of nitrogen compounds to the environment, where they can impact 

water quality. The NMP is designed to assure that the amount of nitrogen excreted by 

milking cows and support stock is in reasonable balance with the needs of crops grown 

at the dairy farm. Manure nitrogen in excess of crop needs should be exported off the 

farm to where it can be used by other farmers. Nitrogen used on the farm is required to 

be stored safely until it is used (the major purpose of the WMP) and then only applied to 

agricultural fields when needed for crop growth and in the amounts needed. Overapplication or mistimed application of nitrogen fertilizers can result in unnecessary 

losses of nitrogen to the environment, both as seepage below the root zone (in the form 

of nitrate or other nitrogen compounds)128 or as air emissions of ammonia gas, 

ammonium, and oxides of nitrogen. 

The University of California suggested in 2005 that “...optimal N loading rates of 1.4 to 

1.65 times the crop N harvest removal are practical and, based on field observations, 

 

127 http://www.waterboards.ca.gov/centralvalley/board_decisions/adopted_orders/general_orders/r5-2013-0122.pdf 128See “Managing Dairy Manure in the Central Valley of California,” published by the University of California 

Committee of Experts on Dairy Manure Management, 2005. http://groundwater.ucdavis.edu/files/136450.pdf
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achievable if the production field is properly managed.”129 The UC assessment was the 

ultimate basis for performance standards set by the Regional Board in the General 

Order, which was adopted in 2007 and revised and reissued in 2013. Research 

suggests that to achieve the more stringent targets in the General Order, many dairies 

had to greatly increase the precision of their manure and fertilizer applications, while 

also reducing the overall amount of nitrogen applied to their crops compared to plant 

uptake.130 On a group of Valley dairy farms, it was estimated that prior to adoption of 

the General Order in 2007, losses of nitrogen to groundwater alone ranged from 370 to 

570 pounds per acre compared to 500 pounds of uptake by crops.131 Similar or larger 

amounts of nitrogen are expected to volatilize to the atmosphere as ammonia and other 

compounds following excretion of manure from animals, during storage of manure in 

ponds or corrals, and in the process of applying manure to soil as a crop 

nutrient.132 Thus, as a result of full implementation of the General Order, losses of 

nitrates to groundwater on dairies may be reduced by up to 85 percent compared to 

pre-General Order conditions, though this number will be smaller for dairies where 

manure was managed more precisely prior to the General Order’s adoption. 

Increasing crop nutrient uptake is also expected to reduce air emissions by providing for 

application of less excess fertilizer to crops, and therefore, less opportunity for 

volatilization in the fields. Some research already conducted found lower emissions with 

moderate nitrogen applications and suggested, “...synchronizing N applications with 

crop N demand. Once the N requirement for each crop stage is known, the N 

applications can be adjusted accordingly. This strategy should lead to improved N use 

efficiency and likely lower N2O emissions.”133

Other nitrogen compounds such as ammonia can also volatilize to air during application 

to fields. The University of California Committee of Experts on Dairy Manure 

Management has suggested that during application of manure water to crops, 

significant ammonia emissions can occur when manure water is not properly diluted (to 

below 100 ppm NH3/N) or applied during early growth of the crop. However, “in systems 

with frequent, but well diluted manure water applications, ammonia losses from the 

ground surface will commonly be minimal during the irrigation (10% or less).”134

 

Although additional research will be helpful in quantifying the environmental benefits of 

improved waste management and nutrient applications, the weight of evidence 

suggests that managing nutrient applications to fields as prescribed in the General 

Order, especially compared to pre-General Order management on some dairy farms, 

has significantly reduced losses of nitrogen compounds to the environment, including 

 

129Ibid., p. 47 130“Cow Numbers and Water Quality – is there a magic limit?” (Harter, Menke 2005), 

http://groundwater.ucdavis.edu/files/136451.pdf 131Ibid., Harter. 132Ibid., “Managing Dairy Manure in the Central Valley of California.” 133“Assessment of Nitrous Oxide Emissions in California’s Dairy Systems, DRAFT FINAL REPORT, California Air 

Resources Board, Contract No. 09-325, William R. Horwath, Martin Burger, Stuart Pettygrove, 

http://www.arb.ca.gov/research/rsc/10-18-13/item6dfr09-325.pdf 134Ibid., “Managing Dairy Manure in the Central Valley of California,” p. 41. 
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leaching of nitrogen compounds to groundwater and air emissions such as ammonia 

and nitrous oxide. 

Organic Material Composting (District Rule 4566) 

I. District Rule Description: 

District Rule 4566 (Organic Material Composting) is the most stringent rule in the nation 

for controlling emissions from composting operations; additional controls are 

infeasible. Additionally, as discussed in Appendix E of this 2015 PM2.5 Plan, one of the 

technology focus areas for the District’s Technology Advancement Program is for waste 

solutions that focus on waste systems or technologies that minimize or eliminate 

emissions from existing waste management systems and processes, including wasteto-fuel systems, such as dairy digesters and other bio-fuel applications. The District has 

taken every regulatory action feasible to reduce emissions from this source and 

continues to seek additional methods to reduce emissions through innovative strategies 

such as the support of research and technology demonstrations with potential to reduce 

emissions further. 

District Rule 4566, was adopted on August 18, 2011, to limit VOC emissions from 

composting facilities whose feedstock consists of greenwaste and/or foodwaste. District 

Rule 4566 applies to operations that stockpile and compost greenwaste and foodwaste. 

In addition to limiting VOC emissions, District Rule 4566 also limits NH3 emissions from 

these operations. The analysis below focuses on how District Rule 4566 limits NH3 

emissions in comparison to other rules and regulations. 

II. How does District Rule 4566 compare with federal rules and regulations? 

A. EPA-Control Technique Guidelines (CTG) 

There is no EPA CTG guidance document for greenwaste or foodwaste 

composting operations. 

B. EPA - Alternative Control Technology (ACT) 

There is no EPA ACT guidance document for greenwaste or foodwaste 

composting operations. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS guidance document for greenwaste or foodwaste composting 

operations. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 
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There is no NESHAP or MACT guidance document for greenwaste or foodwaste 

composting operations. 

III. How does District Rule 4566 compare to rules in other air districts?

District staff compared District Rule 4566 with the rules for greenwaste and foodwaste 

composting operations from other California air districts. The results of the analysis are 

discussed below. District staff only located one other air district rule that applied to 

similar sources: SCAQMD Rule 1133.3. No other air district rules that applied to 

greenwaste or similar sources were found. 

A. SCAQMD Rule 1133.3 - Emission Reductions from Greenwaste Composting 

Operations (Adopted July 8, 2011) 

The purpose of SCAQMD Rule 1133.3 is to reduce emissions of VOCs and NH3 

from greenwaste and foodwaste composting operations. The table below compares 

the significant similarities and differences between SJVAPCD Rule 4566 and 

SCAQMD Rule 1133.3. For purposes of this analysis, the ammonia control 

efficiencies achieved by the requirements of SJVAPCD Rule 4566 are assumed to be 

the same as the VOC control efficiencies since the same control measures will 

reduce both VOC and NH3 from these operations. It is worth noting that 

greenwaste/foodwaste composting produces about 16% of the ammonia emissions 

on a per ton basis compared to co-composting.135 

 

135 SCAQMD Rule 1133.3, baseline NH3 emissions from greenwaste/foodwaste composting = 0.46 lb-NH3/tonthroughput. SCAQMD Rule 1133.2, baseline NH3 emissions from co-composting = 2.93 lb-NH3/ton-throughput. 
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Rule Section SCAQMD Rule 

1133.3 District Rule 4566 Explanation of Differences 

Applicability 

New and existing 

greenwaste and 

foodwaste composting 

operations. 

New and existing organic 

material composting and 

stockpiling facilities. 

(Organic material is 

defined as green 

material, food material, or 

mixtures of the two, with 

<100 ton/yr biosolids or 

manure.) 

SCAQMD Rule 1133.3 limits 

foodwaste stockpiling time (48 hr), 

whereas District Rule 4566 limits 

organic material stockpiling time (3 or 

10 days, depending on throughput). 

Exemptions 

Applicability/exemptions 

based on facility type, 

not throughput. 

Applicability/exemptions 

based on facility type, not 

throughput. 

The same types of facilities are 

exempt in both rules: facilities subject 

to a co-composting rule (SCAQMD 

Rule 1133.2 or District Rule 4565), 

nursery, household, recreational, and 

community composting facilities. 

District Rule 4566 also exempts 

agricultural facilities which are subject 

to District Rules 4204, 4550, or 4570. 

Composting Control 

Requirements 

 ≤5,000 ton/yr 

foodwaste or ≤20% 

manure (watering and 

finished compost cover 

or ≥20% control for 

NH3) 

 >5,000 ton/yr 

foodwaste, (emission 

control device with 

≥80% control for NH3) 

 <200,000 ton/yr 

organic material 

(watering system or 

≥19% control for NH3) 

 ≥200,000 and 

<750,000 ton/yr 

organic material 

(watering system and 

finished compost cover 

or ≥60% control for 

NH3) 

 ≥750,000 ton/yr 

organic material 

(emission control 

device with ≥80% 

control for NH3) 

The throughput/control levels in Rule 

4566 are based on cost effectiveness 

and socioeconomic studies 

conducted by the District as part its 

Final Staff Report for the Revised 

Proposed New Rule 4566 

(Appendices C and D, August 18, 

2011). Rule 4566 requires the same 

management practices and control 

requirements as Rule 1133.3; 

however, the throughput levels at 

which the stricter control 

requirements in Rule 4566 become 

triggered are much higher than in 

Rule 1133.3. Thus, on paper, Rule 

1133.3 appears to be more stringent 

than Rule 4566. However, SCAQMD 

does not have any greenwaste 

composting facilities (that are not 

under an experimental research 

permit) subject to the 80% control 

requirements of Rule 1133.3. 

As shown in the table above, based on discussions with SCAQMD permitting and rule 

development staff, SCAQMD does not have any greenwaste composting production 

facilities subject to the 80% ammonia reduction requirement of Rule 1133.3. SCAQMD 

has recently issued Authority to Construct permits for two experimental research 

greenwaste composting facilities located in Fontana and Riverside operated by Burrtec. 

The permits authorize Burrtec to perform greenwaste composting for one year (with the 

possibility of an extension) in order to evaluate the feasibility of three different compost 

emissions control technologies and conduct emissions testing for each technology. If at 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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the end of the permitted experimental research period, Burrtec wanted to convert one or 

both facilities into a regular greenwaste composting production facility, they would need to 

obtain new ATC permits. The Burrtec facilities then are not representative of a 

commercial production greenwaste composting facility. 

Because SCAQMD has no existing production greenwaste composting facilities that are 

subject to the 80% ammonia control requirement of Rule 1133.3, and the new facilities 

are permitted under experimental research exemptions, then Rule 1133.3 cannot be used 

to establish BACM or MSM as 80% for that category/throughput level of greenwaste 

composting. 

B. No rules that apply to organic materials composting operations were located 

for the air districts listed below:

 Amador County Air Pollution Control District (ACAPCD) 

 Bay Area Air Quality Management District (BAAQMD) 

 Eastern Kern County Air Pollution Control District (EKAPCD) 

 El Dorado County Air Quality Management District 

 Imperial County Air Pollution Control District (ICAPCD) 

 Mojave Desert Air Quality Management District (MDAQMD) 

 North Coast Unified Air Quality Management District (NCAQMD) 

 Placer County Air Pollution Control District (PCAPCD) 

 Sacramento Metropolitan Air Quality Management District (SMAQMD) 

 San Diego County Air Pollution Control District (SDCAPCD) 

 Ventura County Air Pollution Control District (VCAPCD) 

 Yolo-Solano Air Quality Management District (YSAQMD) 

C. IDAPA 58.01.01 Sections 760-764: Rules for the Control of Ammonia from 

Dairy Farms 

 The purpose of IDAPA 58.01.01 Sections 760-764 is to set forth requirements for 

the control of ammonia through best management practices for certain size dairy 

farms licensed by the Idaho State Department of Agriculture to sell milk for human 

consumption. 

 This regulation only applies to large dairies and does not apply to other agricultural 

facilities or facilities in which the primary activity is the production of compost. 

Therefore, it was determined that this regulation is not relevant to the current 

analysis since it does not specifically limit emissions from composting facilities. 

IV. Conclusion 

While BACM and MSM requirements do not apply to ammonia since it is not a 

significant precursor to PM2.5 formation in the Valley, District staff concludes that 

District Rule 4566 meets BACM and MSM requirements for ammonia emissions from 

greenwaste and foodwaste composting operations. The District evaluated the feasibility 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-276 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

of additional ammonia emissions reductions and did not identify any additional feasible 

measures. 

Biosolids, Animal Manure, and Poultry Litter Operations (District Rule 4565) 

I. District Rule Description: 

District Rule 4565, was adopted on March 15, 2007, to limit VOC emissions from 

facilities whose throughput consists entirely or in part of biosolids, animal manure, or 

poultry litter. District Rule 4565 applies to operations that landfill, land apply, compost, 

or co-compost these materials. In addition to limiting VOC emissions, District Rule 4565 

also limits NH3 emissions from these operations. The analysis below focuses on how 

District Rule 4565 limits NH3 emissions in comparison to other rules and regulations. 

II. How does District Rule 4565 compare with federal rules and regulations? 

A. EPA-Control Technique Guidelines (CTG) 

There is no EPA CTG guidance document for biosolids, animal manure, and/or 

poultry litter operations. 

B. EPA - Alternative Control Technology (ACT) 

There is no EPA ACT guidance document for biosolids, animal manure, and/or 

poultry litter operations. 

C. Standards of Performance for New Stationary Sources (NSPS) 

There is no NSPS guidance document for biosolids, animal manure, and/or 

poultry litter operations. 

D. National Emission Standards for Hazardous Air Pollutants (NESHAPs) and 

Maximum Achievable Control Technologies (MACTs) 

There is no NESHAP or MACT guidance document for biosolids, animal manure, 

and/or poultry litter operations. 

III. How does District Rule 4565 compare to rules in other air districts?

District staff compared District Rule 4565 with the rules for biosolids, animal manure, 

and poultry litter operations from other California air districts. The results of the analysis 

are discussed below. District staff only located one other air district rule that applied to 

similar sources, which was SCAQMD Rule 1133.2. No other air district rules that 

applied to similar sources were found. 
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 2015 Plan for the 1997 PM2.5 Standard 

A. SCAQMD Rule 1133.2 - Emission Reductions from Co-Composting 

Operations (Adopted January 10, 2003) 

SCAQMD adopted SCAQMD Rule 1133.2. This rule applies to new and existing 

co-composting operations in the SCAQMD. 

Staff notes that there are some differences between District Rule 4565 and SCAQMD 

Rule 1133.2. This does not mean that one rule is more stringent than the other; 

rather the differences are due to the following factors: 

1. Technology has changed significantly since SCAQMD Rule 1133.2 was 

adopted on January 10, 2003; 

2. Additional research projects regarding mitigation measures have been 

completed since SCAQMD Rule 1133.2 was adopted; and 

3. The socioeconomic climate of the SCAQMD is significantly different from that 

of the District. 

The table below summarizes the significant differences between SCAQMD Rule 

1133.2 and SJVAPCD Rule 4565. Below are the important differences between the 

two rules. For purposes of this analysis, the NH3 control efficiency for the 

requirements of District Rule 4565 are assumed to be the same as the VOC control 

efficiency for these requirements since the same measures will generally reduce both 

VOC and NH3 from these operations. 

Category SCAQMD 

Rule 1133.2 

SJVUAPCD Rule 

4565 

Reason 

Facilities Other Than 

Co-Composting 

(Landfilling, Land 

Applying) 

Rule does not 

apply to these 

operations 

Management practice 

requirements 

Knowledge of control options has 

increased since Rule 1133.2 adoption 

and staff believes that cost effective 

methods of controlling VOC and NH3 

emissions from these facilities exist. 

Co-Composting 

Threshold for 

Applicability 

Facilities with at 

least 1,000 tpy 

throughput 

Facilities that handle 100 

tpy or more of biosolids, 

animal manure, or 

poultry litter 

Staff believes that there are reasonable 

options that are not exceedingly costly 

for facilities with throughputs of 100 

tpy that would not impose an undue 

burden on operators. 

Composting Control 

Requirements 

In-vessel 

composting with 

70% control 

efficiency for 

VOC and NH3 

for existing 

facilities and 

80% control 

efficiency for 

VOC and NH3 

for new facilities 

Control efficiency of 

10%-80% for VOC (and 

NH3) depending on type 

of operation and facility 

throughput 

Management practices (mitigation 

measures) are effective, reasonable, 

and have been achieved in practice for 

smaller facilities. 

In-vessel composting is not costeffective for smaller or medium facilities 

and there are no known, unsubsidized 

facilities in the SCAQMD that would 

comply with such rule requirements. 

It should also be noted that in practice, the facilities that are actually subject to 

SCAQMD Rule 1133.2 will have much larger throughputs than 1,000 ton per year 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

throughput threshold given in the rule. SCAQMD Rule 1133.2 includes the 

following exemptions for existing co-composting operations with a design capacity 

of less than 35,000 tons of throughput per year containing no more than 20 percent 

biosolids by volume and new and existing municipal facilities using aeration and 

processing less than 5,000 tons of biosolids or manure per year. In addition many 

operations in the SCAQMD have found it to be economical to transport these 

materials to other jurisdictions for processing. An example of this is the Synagro 

South Kern Compost Manufacturing Facility, which is a newer facility located in the 

Valley and processes biosolids transported from SCAQMD. 

Because some mitigation measures are only cost-effective for larger facilities, 

District staff developed the concept of Class One and Class Two mitigation 

measures. Class One mitigation measures are cost effective options for all 

facilities, regardless of size. These measures are management practices found to 

be best practices for all composting operations. 

Class Two mitigation measures are the technology options and achieve reductions 

greater than Class One mitigation measures; however, they were determined to not 

be cost effective for facilities with throughputs of less than 100,000 wet tons per 

year. 

District Rule 4565 requires reductions from two additional categories (landfilling and 

land applying) when compared to SCAQMD Rule 1133.2. For the third category, 

composting, District staff determined it is not cost effective to require in-vessel 

(enclosed) composting. 

B. No rules that apply to biosolids, animal manure, and/or poultry litter 

operations were located for the air districts listed below

 Amador County Air Pollution Control District (ACAPCD) 

 Bay Area Air Quality Management District (BAAQMD) 

 Eastern Kern County Air Pollution Control District (EKAPCD) 

 El Dorado County Air Quality Management District 

 Imperial County Air Pollution Control District (ICAPCD) 

 Mojave Desert Air Quality Management District (MDAQMD) 

 North Coast Unified Air Quality Management District (NCAQMD) 

 Placer County Air Pollution Control District (PCAPCD) 

 Sacramento Metropolitan Air Quality Management District (SMAQMD) 

 San Diego County Air Pollution Control District (SDCAPCD) 

 Ventura County Air Pollution Control District (VCAPCD) 

 Yolo-Solano Air Quality Management District (YSAQMD) 
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 2015 Plan for the 1997 PM2.5 Standard 

C. IDAPA 58.01.01 Sections 760-764: Rules for the Control of Ammonia from 

Dairy Farms 

 The purpose of IDAPA 58.01.01 Sections 760-764 is to set forth requirements for 

the control of ammonia through best management practices (BMPs) for certain size 

dairy farms licensed by the Idaho State Department of Agriculture to sell milk for 

human consumption. 

 This regulation only applies to large dairies and does not apply to other agricultural 

facilities or facilities in which the primary activity is the production of compost. 

Therefore, it was determined that this regulation is not relevant to the current 

analysis since it does not specifically limit emissions from composting facilities. 

IV. Conclusion 

While BACM and MSM requirements do not apply to ammonia since it is not a 

significant precursor to PM2.5 formation in the Valley, District staff concludes that 

District Rule 4565 meets BACM and MSM requirements for ammonia emissions from 

biosolids, animal manure, and poultry litter operations. The District evaluated the 

feasibility of additional ammonia emissions reductions and did not identify any additional 

feasible measures.

Major Sources of Ammonia 

The facilities listed below were identified as potential major sources of NH3 in the 

Valley. In all cases, the NH3 emissions from the facilities were entirely or primarily the 

direct result of the use of catalytic emission controls to reduce NOx emissions to 

acceptable levels as determined by regulatory agencies including, EPA, ARB, the 

District, and, in one case the California Energy Commission (CEC). Because the Valley 

is primarily a rural NOx-limited area, NOx reductions are the most critical element of 

District’s plans to reach attainment with the federal ambient air quality standards for 

both PM2.5 and ozone. Therefore, controls that reduce NH3 while increasing NOx 

would increase the formation of PM2.5 and ozone in the Valley and would be 

detrimental to the goals of reaching attainment with the federal ambient air quality 

standards. 

Facility Name: J.R. Simplot Company; District Facility #C-705 

This facility produces fertilizers. The NH3 emissions from this facility are associated 

with the Nitric acid production plant at the facility. Although ammonia is used in the 

production of nitric acid, the vast majority of the ammonia introduced is consumed in the 

production of the nitric acid or recovered. The ammonia emissions from the nitric acid 

are the result of the use of a non-selective catalytic reduction (NSCR) system to reduce 

NOx emissions from the nitric acid plant. The tail gas from nitric acid plants contains 

large amounts of NOx and this plant uses NSCR to reduce NOx to comply with 40 CFR 

60 Subpart G (Standards of Performance for Nitric Acid Plants) and federallyenforceable New and Modified Source Review (NSR) limits. The NSR permit for this 

facility includes conditions minimizing the allowable amount of NH3 slip with associated 
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 2015 Plan for the 1997 PM2.5 Standard 

emissions testing. Because the NH3 emissions are the direct result of the use of 

NSCR, which is required to comply with federal NSPS and NSR requirements, and 

reducing the amount of NH3 would increase NOx emissions, this facility is considered to 

satisfy BACM and MSM for NH3. 

Facility Name: Covanta Delano Inc.; District Facility #S-75 

This facility is a biomass power plant. The NH3 emissions from this facility are the 

result of the use of NH3 injection for Selective Non-Catalytic Reduction (SNCR) to 

control NOx from two biomass-fired boilers at the facility. Use of the SNCR to reduce 

NOx is required by the EPA-issued Prevention of Significant Deterioration (PSD) Permit 

PSD ATC SJ 90-01 and federally-enforceable NSR conditions and also required to 

comply with 40 CFR 60 Subpart Db (Standards of Performance for IndustrialCommercial-Institutional Steam Generating Units). The NSR permits state, “Ammonia 

shall be injected into boiler at a rate, in pounds per ton of biomass fuel introduced into 

boiler, which results in compliance with the NOx emission limitation.” Permit PSD ATC 

SJ 90-01 states “... A SNCR system utilizing ammonia injection shall be incorporated 

within the boilers. Ammonia shall be injected continuously during all periods of 

operation at a rate which results in compliance with the NOx emission limits.” Because 

a perfect reaction cannot be achieved, some excess NH3 must be injected in the boiler 

stacks to reduce NOx to acceptable levels and this excess unreacted NH3 escapes the 

stack as slip. The facility incurs a cost for all of the NH3 injected into the boiler stacks, 

so there is an incentive to minimize NH3 slip to reduce costs associated with 

compliance with the NOx limits. In addition, the NSR permits for the biomass-fired 

boilers include conditions limiting the allowable amount of NH3 slip. 

The NH3 emissions from the biomass boilers are the direct result of the use of SNCR, 

which is required by NSR conditions and the EPA-issued PSD Permit PSD ATC SJ 90-

01 and required to comply with the requirements of Federal NSPS. The NSR permits 

for the biomass-fired boilers include conditions limiting the allowable amount of NH3 slip 

with associated emissions testing, and further reducing the amount of NH3 could 

potentially increase NOx emissions; therefore, this facility is considered to satisfy BACM 

and MSM for NH3. 

Facility Name: Northern California Power; District Facility #N-2697 

This facility is a natural gas power plant. The NH3 emissions from this facility are the 

result of the use of NH3 injection for Selective Catalytic Reduction (SCR) to control NOx 

from two natural gas-fired turbines at the facility. Use of the SCR to reduce NOx is 

required by federally-enforceable NSR conditions and also required to comply with the 

federally-enforceable requirements of District Rule 4703 (Stationary Gas Turbines), 

which is included in the SIP. Because a perfect reaction cannot be achieved, some 

excess NH3 must be injected to reduce NOx to acceptable levels. The excess 

unreacted NH3 escapes the stack as slip. The facility incurs a cost for all of the NH3 

injected into the stacks, so there is an incentive to minimize NH3 slip to reduce costs 

associated with the compliance with the NOx limits. In addition, the NSR permits for the 

natural gas-fired turbines include conditions limiting the allowable amount of NH3 slip. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

The NH3 emissions from the natural gas-fired turbines are the direct result of the use 

SCR, which is required by NSR conditions and required to comply with the federallyenforceable requirements of District Rule 4703. The NSR permits for the natural gasfired turbines include conditions limiting the allowable amount of NH3 slip and 

associated emissions testing, and further reducing the amount of NH3 could potentially 

increase NOx emissions; therefore, this facility is considered to satisfy BACM and MSM 

for NH3. 

Conclusion 

While BACM and MSM requirements do not apply to ammonia since it is not a 

significant precursor to PM2.5 formation in the Valley, District staff concludes that major 

sources of ammonia in the Valley satisfy BACM and MSM requirements for NH3. The 

District evaluated the feasibility of additional ammonia emissions reductions and did not 

identify any additional feasible measures.
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

Table C-37 Emission Inventory Codes 

Control Measure Emission Inventory Codes 

Rule 4103 (Open Burning) 670-660-0262-9842; 670-660-0262-9862; 670-660-0262-9874; 

670-660-0262-9884; 670-660-0262-9888; 670-660-0262-9892; 

670-662-0262-9878; 670-668-0200-9858; 670-668-0200-9872; 

670-668-0200-9886; 670-995-0240-9848 

Rule 4104 (Reduction of 

Animal Matter) 420-995-6004-0000 

Rule 4106 (Prescribed 

Burns) 670-666-0200-0000; 670-670-0200-0000 

Rule 4203 (Particulate Matter 

Emissions from the 

Incineration of Combustible 

Refuse)

010-005-0243-0000 

Rule 4204 (Cotton Gins) 420-418-6028-0000; 420-420-6028-0000 

Rule 4301 (Fuel Burning 

Equipment)

Rule 4307 (Boilers, Steam 

Generators and Process 

Heaters 2 – 5 MMBtu/hr)

010-005-0110-0000; 010-005-0124-0000; 010-005-0130-0000; 

010-005-0300-0000; 010-005-1220-0000; 020-005-0110-0000; 

030-005-0110-0000; 030-005-0124-0000; 030-005-0130-0000; 

030-005-1220-0000; 030-005-1530-0000; 030-010-0110-0000; 

030-010-0130-0000; 030-010-1220-0000; 030-010-1600-0000; 

030-015-0110-0000; 030-015-0130-0000; 040-005-0110-0000; 

040-005-1530-0000; 040-010-0100-0000; 040-010-0110-0000; 

040-010-0120-0000; 040-010-0130-0000; 040-010-1000-0000; 

050-005-0110-0000; 050-005-0122-0000; 050-005-0124-0000; 

050-005-0130-0000; 050-005-0320-0000; 050-005-1100-0000; 

050-005-1220-0000; 050-005-1510-0000; 050-005-1520-0000; 

050-005-3220-0000; 050-010-0110-0000; 050-010-0120-0000; 

050-010-0320-0000; 050-010-1220-0000; 050-010-1500-0000; 

052-005-0110-0000; 052-005-0124-0000; 052-005-1220-0000; 

052-010-0110-0000; 052-010-0120-0000; 052-010-1224-0000; 

060-005-0110-0000; 060-005-0122-0000; 060-005-0124-0000; 

060-005-0130-0000; 060-005-0142-0000; 060-005-0144-0000; 

060-005-0320-0000; 060-005-1220-0000; 060-005-1510-0000; 

060-005-1520-0000; 060-010-0100-0000; 060-010-0110-0000; 

060-010-0120-0000; 060-010-0142-0000 

The EICs are the same for Rules 4306/4320, 4307, and 4308; 

the three rules share a combined emission inventory. Baseline 

emissions from the 2008 and 2009 rule amendments of these 

rules were used to determine the percentage of emissions for 

each rule. Those respective percentages are applied to the 

combined inventory to get the individual emission inventories.

Rule 4308 (Boilers, Steam 

Generators and Process 

Heaters 0.075 to less than 2.0 

MMBtu/hr)

The EICs are the same for Rules 4306/4320, 4307, and 4308; 

the three rules share a combined emission inventory. Baseline 

emissions from the 2008 and 2009 rule amendments of these 

rules were used to determine the percentage of emissions for 

each rule. Those respective percentages are applied to the 

combined inventory to get the individual emission 

inventories. See Rule 4307 for the EICs. 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

Control Measure Emission Inventory Codes 

Rule 4309 (Dryers) 430-422-7078-0000; 430-424-7006-0000; 430-995-7000-0000; 

499-995-0000-0000; 499-995-5630-0000 

Rule 4311 (Flares) 110-132-0130-0000; 110-132-0146-0000; 120-132-0136-0000; 

130-132-0110-0000; 130-132-0130-0000; 130-132-0136-0000; 

310-320-0010-0000; 310-320-0110-0000; 310-320-0120-0000; 

310-320-0130-0000; 310-320-0136-0000; 310-320-1600-0000; 

320-320-0010-0000; 320-320-0110-0000; 320-320-0120-0000; 

320-320-0130-0000 

Rule 4313 (Lime Kilns) Lime kilns are not included in the ARB emissions inventory. 

There are no lime kilns currently operating in the Valley. 

Rule 4320 (AERO for 

Boilers, Steam Generators, 

and Process Heaters >5 

MMBtu/hr) 

The EICs are the same for Rules 4306/4320, 4307, and 4308; 

the three rules share a combined emission inventory. Baseline 

emissions from the 2008 and 2009 rule amendments of these 

rules were used to determine the percentage of emissions for 

each rule. Those respective percentages are applied to the 

combined inventory to get the individual emission 

inventories. See Rule 4307 for the EICs. 

Rule 4352 (Solid Fuel Fired 

Boilers, Steam Generators, 

and Process Heaters) 

010-005-0214-0000; 010-005-0218-0000; 010-005-0220-0000; 

010-005-0240-0000; 010-005-0243-0000; 010-005-0254-0000; 

020-005-0218-0000; 020-005-0230-0000; 030-005-0214-0000; 

050-005-0214-0000; 050-005-0240-0000; 050-005-0254-0000; 

052-005-0240-0000; 060-005-0240-0000; 060-005-0264-0000 

Rule 4354 (Glass Melting 

Furnaces) 460-460-7037-0000; 460-460-7038-0000; 460-460-7039-0000 

Rule 4550 (Conservation 

Management Practices) 

620-614-5400-0000; 620-615-5400-0000;650-650-5400-0000; 

650-651-5400-0000 

Rule 4641 (Cutback, Slow 

Cure, and Emulsified Asphalt, 

Paving and Maintenance 

Operations) 

540-560-0400-0000; 540-562-0400-0000; 540-564-0400-0000; 

540-566-0400-0000

Rule 4692 (Commercial 

Charbroiling) 690-680-6000-0000 

4693 (Bakery Ovens) 420-412-6012-0000; 420-412-6037-0000 

Rule 4702 (Internal 

Combustion Engines) 

010-040-0110-0000; 010-040-1200-0000; 020-040-0110-0000; 

020-040-1200-0000; 030-040-0110-0000; 030-040-0124-0000; 

030-040-1200-0000; 030-040-1210-0000; 040-040-0110-0000; 

050-040-0012-0000; 050-040-0110-0000; 050-040-0124-0000; 

050-040-1200-0000; 052-040-0110-0000; 052-040-1200-0000; 

052-042-0110-0000; 052-042-1200-0000; 052-042-1200-0010; 

052-042-1200-0011; 060-040-0110-0000; 060-040-0124-0000; 

060-040-0142-0000; 060-040-0146-0000; 060-040-1100-0000; 

060-040-1200-0000; 060-040-1210-0000; 060-995-1220-0000; 

099-040-1200-0000 

Rule 4703 (Stationary Gas 

Turbines) 

010-045-0110-0000; 010-045-1200-0000; 020-045-0110-0000; 

030-045-0110-0000; 040-045-0134-0000; 050-045-1200-0000; 

060-045-0110-0000; 060-045-1200-0000 

Rule 4802 (Sulfuric Acid 

Mist) 410-400-2058-0000 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

Control Measure Emission Inventory Codes 

Rule 4901 (Wood Burning 

Fireplaces and Wood Burning 

Heaters) 

610-600-0230-0000; 610-602-0230-0000 

Rule 4902 (Residential 

Water Heaters) 610-608-0110-0000 

Rule 4905 (Natural Gas – 

Fired, Fan Type Residential 

Central Furnace) 

610-606-0110-0000 

Rule 8011 (General 

Requirements) 

There is no specific emissions inventory associated with Rule 

8011. 

Rule 8021 (Construction, 

Demolition, Excavation, 

Extraction, and Other 

Earthmoving Activities) 

630-622-5400-0000; 630-624-5400-0000; 630-626-5400-0000; 

630-628-5400-0000; 630-634-5400-0000 

Rule 8031 (Bulk Materials) 430-436-7006-0000; 430-436-7078-0000; 430-995-7064-0000 

Rule 8041 (Carryout and 

Trackout) 

The EICs are included in Rule 8061 (Paved and Unpaved 

Roads). 

Rule 8051 (Open Areas) 650-652-5400-0000 

Rule 8061 (Paved and 

Unpaved Roads) 

640-635-5400-0000; 640-637-5400-0000; 640-639-5400-0000; 

640-641-5400-0000; 640-643-5400-0000; 645-638-5400-0000; 

645-640-5400-0000; 645-644-5400-0000; 645-648-5400-0000 

Rule 8071 (Unpaved Vehicle 

Traffic) 

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. 

Rule 8081 (Ag Sources) 645-646-5400-0000 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

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 2015 Plan for the 1997 PM2.5 Standard 

Control Measure Emission Inventory Codes 

SC 001 (Source Category: 

Lawn Care Equipment) 

860-902-1100-4065; 860-902-1100-4094; 860-902-1100-4095; 

860-902-1100-4102; 860-902-1100-4103; 860-902-1100-4112; 

860-902-1100-4113; 860-902-1100-4124; 860-902-1100-4125; 

860-902-1100-5672; 860-902-1100-5673; 860-902-1100-5684; 

860-902-1100-5685; 860-902-1100-5692; 860-902-1100-5693; 

860-902-1100-5704; 860-902-1100-5705; 860-902-1100-5724; 

860-902-1100-5725; 860-902-1100-7604; 860-902-1100-7605; 

860-902-1100-7614; 860-902-1100-7615; 860-902-1100-8104; 

860-902-1100-8105; 860-902-1100-8112; 860-902-1100-8113; 

860-902-1100-8344; 860-902-1100-8345; 860-902-1100-8352; 

860-902-1100-8353; 860-902-1100-8364; 860-902-1100-8365; 

860-902-1100-8372; 860-902-1100-8373; 860-902-1100-8384; 

860-902-1100-8385; 860-902-1100-9074; 860-902-1100-9075; 

860-902-1100-9542; 860-902-1100-9543; 860-902-1100-9554; 

860-902-1100-9555; 860-902-1100-9834; 860-902-1100-9835; 

860-903-1100-1394; 860-903-1100-1395; 860-903-1100-1404; 

860-903-1100-1405; 860-903-1100-4084; 860-903-1100-4085; 

860-903-1100-5744; 860-903-1100-5745; 860-903-1100-5754; 

860-903-1100-5755; 860-903-1210-1190; 860-903-1210-1200; 

860-903-1210-1210; 860-903-1210-1220; 860-903-1210-1230; 

860-903-1210-1240; 860-903-1210-1250; 860-903-1210-1350; 

860-903-1210-1380; 860-903-1210-4050; 860-903-1210-4070; 

860-903-1210-4130; 860-903-1210-4140; 860-903-1210-4150; 

860-903-1210-5710; 860-903-1210-5730; 860-903-1210-8390; 

860-903-1210-8400; 860-903-1210-8410 

SC 002 (Energy Efficiency) None 

SC 003 (Fireworks) None 

SC 004 (Sand and Gravel 

Operations) 

430-422-7078-0000; 430-426-0210-0000; 430-426-7078-0000; 

430-426-7092-0000 

SC 005 (Asphalt/Concrete 

Operations) 

430-424-7006-0000; 430-424-7050-0000; 430-429-7016-0000; 

430-430-7016-0000; 430-430-7018-0000; 430-436-7006-0000; 

430-995-7006-0000; 430-995-7012-0000; 430-995-7016-0000; 

430-995-7018-0000; 430-995-7050-0000; 430-995-7072-0000 

SC 006 (Almond 

Hulling/Shelling Operations)

420-418-6003-0000 

SC 007 (Pistachio 

Hulling/Shelling Operations) 

The EIC is included in SC 006 

SC 008 (Agricultural Material 

Screening/Shaking 

Operations) 

None 

SC 009 (Tub Grinding 

Operations)

None 

SC 010 (Abrasive Blasting) 430-428-6084-0000; 430-428-7000-0000; 430-428-7036-0000; 

430-428-7078-0000; 430-428-7084-0000; 430-428-7088-0000; 

430-428-7090-0000 

SC 011 (Bakery Ovens) N/A 
San Joaquin Valley Unified Air Pollution Control District April 16, 2015

C-286 Appendix C: BACM and MSM for Stationary and Area Sources 

 2015 Plan for the 1997 PM2.5 Standard 

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