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

Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard This page intentionally blank.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

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 (N AAQS). The San Joaquin Valley Air Pollution Control District (District) has demonstr ated leadership in developing a nd implementing groundbreaking regulatory strate gies to reduce emissions. Toug h and innovative rules, such as those for indirect source review, residential wood burn ing, glass manufacturing, and agricultural burning, have se t benchmarks for California an d the nation.

Multiple regulatory contro l measures have been adopted under th e District’s air quality attainment plans that reduce parti culate 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 Pro tection Agency (EPA) policy, th ere is a preference for reliance on control measures t hat have already been adopted. T he 2015 PM2.5 Plan regulatory control measures t hat have already been adopted incl ude both stationary and area source control measures, as well as California Air Resourc es Board (ARB) rules for mobile sources.

Table C-1 below identifies the c ontrol measures that the Distri ct has already adopted and that are contributing to atta inment of the 1997 PM2.5 stand ard. These adopted District rules are achieving new emissions reductions after 201 2, the base year for this plan. Even pre-2012 emissions r eductions are contributing, and will continue to contribute, to the Valley’s progress toward clean air.

Table C-1 District Regulations Contributing to Attainment of P M2.5 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 12/17/09San Joaquin Valley Unified Air Polluti on 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 Se rious nonattainment area plan u nder Subpart 4 is to demonstrate that the pl an includes the best av ailable control m easures (BACM) that can be feasibly and cost effectively implemented. EPA defines BACM as being more stringent than reasonably available control measures (RACM), bu t less stringent than the lowest achievable emission rate (LAER), which does not take into consideration the cost effectiveness of implementi ng a particular control measure

. 1

As a Serious nonattainment ar ea, the Valley w ould have until De cember 31, 2015 to attain the 1997 PM2.5 standard. As demonstrated in Chapter 2 a nd Appendix A, the Valley will not attain the 1997 PM 2.5 standard by the attainmen t date and is therefore requesting an extensio n of the attainment date. Under Subpart 4, EPA may grant one extension of the attainment date of up to five years for a Seri ous nonattainment area provided the attainment plan for that area satisfies several fe deral requirements, including the most stringent meas ures (MSM) that are included i n the implementation plan of any State or are achiev ed in practice in any State, and can feasibly be implemented in the ar ea. EPA defines MSM as the, “maximum degr ee of emission reduction that has been required or achieved from a source or s ource category in other SIPs or in practice in other s tates and can be feasibly impleme nted in the area.” 2 This appendix demonstrates t hat 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 a nd evaluation of emission reduction opportunities for a va riety of stationary and area so urce categories. District staff in multiple de partments with expertis e in these various s ectors contributed to this effort. The evaluations in this appendix capture relevant back ground information, examine potential emission r eduction opportunities for technolo gical and economic feasibility, and make recommendat ions for appropriate District actions moving forward. This appendix reflects the comp rehensive evaluatio n performed b y the District to examine the Valley’s various emi ssions sources and identify any potential BACM or MSM for inclusion in this plan.

C.ii BACM/MSM Evaluation Process As discussed in detail in Chapt er 5, the District must demonstr ate that its rules meet both BACM and MSM requirements.

The Maricopa County PM10 nonattain ment area is the only other a rea in the nation that has conducted a BACM and MSM analysi s. Within the technical su pport document (TSD) for the Maricopa County Se rious Area Nonattainment Plan, 3 EPA defined the process for determining BACM and MSM. EPA noted that MSM follo ws the same process for determining BACM, but with one additional step to c ompare the potential MSM against the measures already adopted in the area to determi ne if the existing

1 EPA. 1994 Addendum to the G eneral Preamble, p. 10.
2 EPA. Technical Support Documen t for Maricopa County PM10 Nonat tainment Area. 2001, p. 237.
3 EPA. Technical Support Document (Notice of Proposed Rulemaking on the Serious A rea PM-10 State Implementation Plan for the Mari copa County PM-10 Nonattainment Area Provisions for Attaining the 24-Hour Standard and Cont ingency Measures). ( 2001, September 14).San Joaquin Valley Unified Air Polluti on 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. Bec ause this is the only EPA guid ance available for a Serious Nonattainment area under Subpart 4 (to evaluate BACM an d 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 o f various source categories on PM2.5 concentrations over the NAAQS to determine which sources are si gnificant and which sources are de minimis (l ess than significant) for the pu rposes of adopting BACM and MSM 4 (Chapter 5). a. ARB relative response factor ( RRF) results demonstrate that the significance levels for PM2.5 , oxides of nitrogen (NOx), and ox ides 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 du st 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 threshold s above.

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

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

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

Using the BACM/MSM process summa rized above, emission control r equirements for stationary and area sour ce categories are evaluated to determin e if they satisfy both BACM and MSM requirements or if t here are any potential technol ogies or practices

4 EPA stated in the Mari copa County TSD that more source categor ies 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 s ource category for BACM is depen dent upon the specific fact s of the nonattainment problem under consideration. EPA states that one means of dete rmining an appropriate de minimis level is to determine if applying MSM to the proposed de minimis source cat egories would meaningful ly expedite attainment. If it did, then the established de minimis level is too high, and if it did not, then the de mini mis level is appropriate.San Joaquin Valley Unified Air Polluti on 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 pro ve to be technologically and economically feasible for sources in the Va lley.

C.iii Appendix C Organiza tion and Evaluation Each control measure evaluation includes a discussion of the ru le applicability and rule adoption/amendment history; an ov erview of the source category and affected sources; an emissions inventory table fo r the source category; a regulat ory evaluation; a technological feasibility and co st effectiveness analysis of an y other potential BACM/MSM; and a summary of the ev aluation findings. The sectio ns below elaborate in more detail with respect to t he information included within each individual rule evaluation.

Discussion This section provides an overview of rule applicability, identi fies what types of emissions the rule controls, provides the rule adoption/amendment history , and discusses additional pertinent details, as necessary. This section is no t included for the source categories where there is no cu rrent District prohibitory rule.

Source Category This section discusses what types of units, industries, or oper ations are included in the respective source category.

Emissions Inventory Each emissions inventory tabl e lists the annual average and win tertime average (November through April) PM2.5, NOx, and SOx emissions for the respective source category for the years 2012 th rough 2020. The data provided in this section is a compilation of the data sources i dentified in the emission inve ntory appendix. See Appendix B (Emission Inventory) for additional information.

This section also includes a significance discussion, which com pares the emissions from the respective source cat egory to the applicable significa nce/de minimis thresholds developed by ARB, as shown in Chapter 5 of the plan.

Regulatory Evaluation As part of the regulatory evaluat ion, 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 an d guidelines are referenced in the comparisons:

 Federal Regulations – Federal regulations include t he following regulations and guidance documents:

o Control Techniques Guidelines (CTG) 5

o Alternative Contro l 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.htmlSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

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 (NESH AP) 8

o Maximum Achievable Control Technology (MACT) 9

 State Regulations – Generally, state regulations are specific to mobile sources and consumer products. However, t here are some California Heal th and Safety Code (CH&SC) requirem ents and ARB Airborne To xic Control Measur es (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 regul ation associated with their source category, any relev ant state guidelines are evalua ted within this section.

 Other Air Dist ricts’ Rules – As agreed to by EPA for the 2009 RACT SIP , the rules were also compared to analogous regulations adopted by Ca lifornia’s most progressive air districts. Control strategies and measur es in other air districts and agencies include, but are not limited to the following air districts:

o South Coast Air Quality M anagement District (SCAQMD) 11

o Bay Area Air Quality M anagement District (BAAQMD) 12

o Sacramento Metropolitan Air Qua lity Management District (SMAQM D) 13

o Ventura County Air Polluti on Control District (VCAPCD) 14

All potential BACM/MSM identified through this regulatory evalu ation were then thoroughly evaluated using the fo llowing key factors, defined b y EPA in the Maricopa County TSD, to determine if potent ial opportunities qualify as BACM/MSM for the Valley:

 Technological feasibility 15 – This analysis determines i f the new control can be integrated with the existing c ontrols without reducing or delay ing the emission reductions from the existing c ontrol. If it cannot, then it wo uld not be considered

7 EPA. 40 CFR 60 – Stan dards of Performance for New Stationary S ources (NSPS). Retrieved from http://www.tceq.state .tx.us/permitting/air/rules/federal/60/60h mpg.html
8 EPA. 40 CFR 61 – National Emi ssion Standards for Hazardous Air Pollutants (NESHAPs). Retrieved from http://www.tceq.state .tx.us/permitting/air/rules/federal/61/61h mpg.html
9 EPA. 40 CFR 63 – Maxi mum Achievable Control Technology (MACT). Retrieved from http://www.tceq.state .tx.us/permitting/air/rules/federal/63/63h mpg.html
10 California Air Resources Board (ARB). Airborne Toxic Control M easures (ATCMs). Retrieved from http://www.arb.ca.gov/toxics/atcm/atcm.htm
11 South Coast Air Quality Managemen t District (SCAQMD). Rules an d Regulations. Retrieved from http://www.aqmd.gov/home/regulations/rules/scaqmd-rule-book/tab le-of-contents
12 Bay Area Air Quality Managem ent District (BAAQMD). Rules and R egulations. Retrieved from http://www.baaqmd.gov/Divisions/Planning-and-Research/Rules-and -Regulations.aspx
13 Sacramento Metropolitan Air Qua lity Management District (SMAQM D). Rules and Regulations. Retrieved from http://www.airquality.org/rules/
14 Ventura County Air Po llution 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

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

C-6 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard to be technologically feasible fo r the area unless the emission benefit of the new measure is substantially great er than the existing measure.

 Economic feasibility 16 – If the potential contro l is determined to be technologically feasible, it is then evaluated for economic fea sibility. The District has evaluated the economic feasibil ity of various control measu res by conducting cost effectiveness analyses withi n this appendix. A cost effec tiveness analysis examines the added cost, in dollars per year, of the control te chnology or technique, divided by the emission s reductions achieved, in ton s per year. EPA cautions that the threshold for economic feasibility should be addressed on a case-by-case basis.

Additional Emission Reduc tion Opportunities The District reviewed the following areas to identify any addit ional potential BACM/MSM, exclusive of potentia l BACM/MSM evaluated in the Regu latory Evaluation section:

 Any emission reduction opportuni ties identified/considered in previously adopted District plans that were determi ned to be beyond reasonably ava ilable control technology (RACT) at that time.

 New emission reduction opportuni ties adopted in California SIP s, SIPs in other states, or achieved in practice in other areas.

All potential BACM/MS M identified were then thoroughly evaluate d for technological and economic feasibility, as previous ly defined. The District revi ewed staff reports and studies from other air districts , EPA technical guidance docume nts, and applicable study data from the sc ientific community to assist in evaluatin g the technological and economic feasibility of potential BACM/MSM.

Evaluation Findings This section provides a summary of the District’s findings base d 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 Polluti on 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 C lean Air Act (CAA), regions are required to address ammonia as a precursor in BAC M/MSM analyses unless EPA determin es that ammonia sources do not contribute significantly to PM concentrations. As demonstrated in Appendix A, ammonia emissions cont rols are not effective in sig nificantly reducing ambient PM2.5 concentrations and do not contribute to the Valle y’s PM2.5 attainment. As such, the District is not requir ed to evaluate its ammonia r egulations as part of the BACM/MSM analysis for this 2015 PM2.5 Plan.

Nevertheless, the District has i mplemented the most stringent c ontrols feasible for local sources of ammonia and the Vall ey’s ammonia emissions have been significantly reduced through stringent Distric t regulations which include th e following:

 Rule 4570 (Confined Animal Facilities)

 Rule 4566 (Organic Material Composting)

 Rule 4565 (Biosolids, Animal Ma nure, and Poultry Litter Operat ions)

Even though the District is not r equired to evaluate ammonia as part of this plan, Section C.41 (Ammonia Controls ) includes a full analysis for th e above sources and demonstrates that existing requi rements meet or exceed BACM and MSM levels of control. Therefore, even if ammo nia was a significant precurso r to PM2.5 concentrations in the Valley (wh ich they are not), there are no current opportunities for additional ammonia emission reductions.San Joaquin Valley Unified Air Polluti on 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 appl y to open burning conducted in the Valley, with the exception of prescribed burning and hazard reduction burning, a s 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 adopt ed on June 18, 1992 and it has be en amended several times to incorporate state law requirements. In 2003, Californ ia 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 fiel d, but provided for a postponement of the phase-out wher e 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 reduc ed open burning through the use of sustainable agricultural practices. Those p ractices 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 agricu ltural materials provided an economically feasible method fo r the timely disposal of thes e materials, helped prevent the spread of plant dis eases, and controlled weeds and pests. As part of implementing SB 705 and enhancing the effect iveness of the Dist rict’s burn reduction efforts, in 2004 the District e stablished the Smoke Management System (SMS), a more refined method of authorizing or p rohibiting individual burns, based on modeled smoke impacts. Rule 4103 and the Distric t’s SMS have reduced the tot al acreage of agricultural materials burned in t he Valley to date by more tha n 80% since 2002.

Smoke Management System The District uses the SMS to man age the Valley’s remaining open burning of agricultural crops and materials . The District’s air quality f orecasters incorporate projected meteorological info rmation and air quality statistica l modeling to determine the amount and location of agricultu ral burning that can be allowed without resulting in ambient air pollutant concentrati ons that exceed federal health -based standards. Through the results of this da ily analysis, the SMS allows the District to manage 103 burn zones in the Valley through allocating daily burning allow ances in each zone based on local meteorology, the air qual ity conditions, the atmospher ic holding capacity, the amount of burning already approv ed in a given area, and the pot ential impacts on downwind populations (see Figure C-1). This approach allows th e District to better distribute air pollutant emissi ons from open burning temporally and spatially, providing flexibility of burn days for gr owers while minimizing the impac t on the public.San Joaquin Valley Unified Air Polluti on 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 Zon es Defined in the District SMS

Properly managed burning allocations under the existing Distric t SMS ensures that air quality and health impacts of open burning of agricultural mate rials, prescribed burning, and hazard reduction burning are mi nimized to the fullest exten t feasible. Under the SMS, emissions within a zone are limited to levels below the ex ceedance threshold of any applicable federal ambien t air quality standard and burns a re not allowed in zones on days when exceedances of the f ederal standards are projected to occur in that zone. Additionally, zones directly adj acent to an area where open bur ning is restricted are also allocated zero emissions in an effort to reduce pollutant trans port into an area with already elevated pollutant concentrations.

During the wood-burning season fr om November through February, the District implements even tighter open burni ng restrictions based on the daily residential woodburning declarations issued for t he Check Before You Burn progr am. With the recent amendment of Rule 4901, residen tial wood-burning with unregiste red devices is no longer allowed when an area’s fo recasted PM2.5 concentration is expected to be greater than or equal to 20 μg/m 3 . This threshold is now l ower compared to past yearsSan Joaquin Valley Unified Air Polluti on 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/m 3

. To be consistent with the residential wood-burning declaration, an area’s burn zones i n SMS are allocated zero emi ssions when residential wood-burning is prohibi ted in that area. Fo llowing similar pro cedures discussed above, zones directly adjacent to an ar ea where residential wood-burni ng is restricted are also allocated zero emissions. Under t his policy, agricultural burn ing is placed under tighter control during the winter seas on and burning is only allowed wh en air quality is expected to be below 20 μg/m 3 , when meteorological conditi ons are projected to be conducive for pollutant dispersion, which is well below the cur rent federal 24-hour average PM2.5 stand ard of 35 μg/m 3

.
Under the SMS, indivi duals who need to burn their agricultural waste first submit their permit request to the District, whi ch includes information rega rding the material that needs to be burned and the location of the burn project (see at tachment for sample burn permit). If there are positiv e air quality and atmospheric dis persion conditions, the District allocates a certain am ount of emissions to the applica ble burn allocation zone. The SMS will then automatically c all the specified contact’s ph one number to notify them that burn allocation is ava ilable in their zone for their project. Through the phone system, the individual can then ei ther notify SMS that they wil l proceed with their burn or hold off until another time.

Through this process, SMS is abl e to automatically manage and n otify a large number of stakeholders in the agricultu ral community on whether they c an proceed with their burn project. If there are more requests for burning than ther e are emissions allocated in the system for a day, those i ndividuals will be placed on a waiting list and given priority when another burn window opens.

As agricultural burning project s are occurring across the Valle y, District air quality enforcement staff inspect the r egion to observe permitted agric ultural burns to ensure their practices conform to Dis trict regulations. In addition, on days when agricultural burning is not permitted, enfor cement staff inspect the region to ensure that unpermitted agricultural burning is not occurring and to issue no tices of violation (NOVs), as needed.

The continued issuance of burn permits for certain crop categor ies is not expected to cause or substantially contribut e to a violation of an applicab le federal ambient air quality standard because the District follows its SMS procedure s.San Joaquin Valley Unified Air Polluti on 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 emissi ons from this source category c ontinue to decline and contribute 5.2% of average winte r NOx and 5.6% of average winte r PM2.5 emitted from stationary and area sources in t he 2014 emission inventory. Di strict regulatory efforts have fostered significant reducti ons in emissions from this sou rce category.

As detailed in Chapter 5, the si gnificance threshold for source categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts is 1.4 tons per day (tpd) for PM2.5 combustion em issions, 13.1 tpd for NOx, and 1.0 tpd for SOx. As identified in the abov e table, emissions from open burning are lower than the NOx and SOx BACM/MSM significance thre sholds. Therefore, the Clean Air Act does not require a NOx and SOx control measure evaluation for this source catego ry for the purpose of satisfying BACM/MSM requirement s; however, the District has sti ll conducted a full control measure evaluat ion for Rule 4103.

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

Federal Regulations There are no EPA CTG, ACT, NSPS, N ESHAP, or MACT requirements f or this source category.

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

 CH&SC §41850-41866 (Agr icultural Burning)

The District has continued to wor k closely with the stakeholder s to identify economically feasible alternatives to open burni ng of various agricultural m aterials and to meet its legal obligation under the CH&SC. T o fulfill the state law req uirements, the District has implemented the requirements for most crop categories identifie d in CH&SC §41855.5. In addition to those requirement s, the state law authorizes the District to postpone the burn prohibition dates for specific types of agricultural mater ial if the District makes three specific determinations and the Air Resources Board (ARB) concurs. The determinations are: (1) there are no economically feasible alte rnatives to open burning for that type of material; (2) open burning for that type of ma terial will not cause orSan Joaquin Valley Unified Air Polluti on 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 v iolation of an air quality stand ard; and (3) there is no longterm federal or state funding co mmitment for t he continued oper ation 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 revie w its determinations for any pos tponed crops and materials at least once every five years. In 2010, the Distric t also evaluated each crop category identified in CH&SC § 41855.5 to determine any technolo gically and economically feasible alternat ives to open burning. After work ing extensively with stakeholders to understand viable alternatives to open burning and the associated costs, the District provided reco mmendations for allowing or pr ohibiting the open burning of agricultural materi al 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-tim e request that the District re-visit the 2010 findings a fter two years to determin e if additional reductions in open burning were feasible.

The District revisited its 2010 ana lysis in 2012 and submitted those findings to ARB. The 2012 Report showed that in the two years since the 2010 Rep ort, there had been no significant changes in the econom ic feasibility of various a lternatives to agricultural burning. The amount of agricultura l materials accepted at biom ass facilities continued to fluctuate based on market condi tions and there were no long- term federal or state funding commitments for the operat ion of biomass facilities or development of alternatives to burning. EPA fi nalized 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 o f alternatives to open burning in the 2014 Reasonably Available Control Technology Demons tration for the 8- Hour Ozone State Implementation Plan ( 2014 RACT SIP ). The District is committed to review its determinations for any postponed c rops and materials by Decembe r of 2015.

Current Status of Biomass Facilities Biomass power plants in the Vall ey will generally accept agricu ltural, forestry, construction, and urban residues . The power plants burn the ma terial in combustors to produce steam and the st eam is then used to spin turbines to ge nerate electricity.

Biomass power plants do not universally accept all agricultural material due to concerns that some materials may harm pow er plant machinery. Several is sues have been noted concerning the types of material, such as citrus chips, that ca n be burned by the biomass power plants and the amount of agricultural materials t hat is accepted at the plants at any given time.

Using the orchard removal mate rials for fuel at the biomass pow er plant is currently the most viable and cost effective alternative to open burning for growers due to available

17 Revisions to the California Stat e Implementation Plan, San Joa quin Valley Unified Ai r 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 Polluti on 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 facilitie s and required agricultural of fsets for some biomass power plants. However, the ability to meet the needs of the ag ricultural industry in a timely and cost effective fashi on is a critical factor in any a ction taken by the District to address the biomass industry’s l ong-term viability as an altern ative to open burning. Farmers need certainty and timely removal of material so that t hey do not miss planting seasons. In the past, lack of coor dination and av ailable stora ge for biomass fuels has led to uncertainty as to when ma terial would be removed from th e field. This has been a major concern of the agricultu re industry. If the process is not optimized, it can quickly result in a system that d oes not meet agriculture’s nee ds.

In addition, the reliance on bioma ss fuel as a primary alternat ive to open burning is somewhat uncertain since there are no long-term federal or stat e funding commitments for biomass facilities in the Va lley. In fact, the biomass ind ustry has indicated that given current energy policy in Califor nia there is concern that bioma ss power facilities are in jeopardy. Many biomass plants in the Valley are nearing the en d of their long-term contracts with utilities and find themselves in a position wher e the power that they provide is not the type of power that utilities are seeking (ba se load vs. intermittent) and that the prices being offered for new contracts are too low to support their operations.

Two biomass power plants servi ng 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 loc ated in Mendota was shut down in January 2015. Initia lly, another Covanta facility in Delano had indicated that they were likely to shut down, but is now reporting that t hey were able to secure a one-year extension on their curren t utility contract at the sam e rate that enables them to continue to operate.

Staff has convened a number of pr oductive meetings with agricul tural stakeholders and representatives of the biomass in dustry 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 bet ween agriculture representatives and biomass power producers and developing consensu s on short-term and long-term solutions.

The District and representatives fr om agriculture and biomass i ndustries are working to develop and pursue specific acti ons with the legislative branch , utilities, Public Utility Commission, CalRecycle, and other government agencies to help l evel the playing field and allow the biomass industry to fairly compete.

In June 2014, the District’s Gove rning Board adopt ed positions on two pieces of legislation that impact the bi omass industry. The District ado pted a position in support of AB 2363 (Dahle), which was s ponsored by the biomass industry , and would make biomass plants more competitive by fully accounting for the cos ts associated with intermittent sources of renewabl e power (solar and wind) when c omparing 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 posit ion in opposition to SBSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-14 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard 1139 (Hueso) that would have giv en preferential treatment to ne w geothermal power plants by requiring that utilities purchase specified amounts o f new geothermal power. Ultimately, AB 1139 was not pa ssed by the legislature.

The District is also working wit h the stakeholders, including t he Federal Department of Energy, California Energy Co mmission, and other partner agencie s, to pursue clean alternatives to biomass power pr oduction for agricultural waste disposal.

How does District Rule 4103 compar e to rules in o ther air distr icts?

BAAQMD

 Regulation 5 (Open Burning)

The District evaluated the requi rements contained within BAAQMD ’s Regulation 5 and found no requirements that were more stringent than those alrea dy in Rule 4103. BAAQMD Regulation 5 was amended on June 19, 2013 to add new fee requirements. The amendments did not implemen t any requirements more stringen t than the current requirements in District Rule 4103.

SMAQMD

 Rule 407 (Open Burning)

The District evaluated the require ments contained within SMAQMD ’s Rule 407 and found no requirements that were more stringent than those alrea dy in Rule 4103.

VCAPCD

 Rule 56 (Open Burning)

The District evaluated the require ments 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 require ments contained within SCAQMD ’s Rule 444 and found no requirements that were more stringent than those alrea dy in Rule 4103. SCAQMD Rule 444 was amended on July 12, 2013 to include beach b urning in the rule applicability. The amendments apply to sources that do not exi st within District’s boundaries. Rule 444 also restricts burning on residential woo d combustion curtailment days. As discussed in detail abov e, this is a practice that ha s already been implemented within the District. District Rule 4103 is still a s stringent as SCAQMD Rule 444.

Evaluation Findings The District has evaluated all potential control technologies a nd all control technologies achieved in practice in another a rea or included in another sta te implementation plan. As demonstrated above, Rule 4103 cu rrently has in place the mos t stringent measuresSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-15 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard feasible to implement in the Va lley and therefore meets or exce eds both BACM and MSM requirements for this sour ce category. Ther efore, there ar e no recommendations for additional regulatory ac tions for Rule 4103.

The District carefully manages agr icultural burning with its SM S with even tighter open burning restrictions based on the daily residential wood-burnin g declarations issued within the Check Before You Burn program. With the recent amen dment of Rule 4901, residential wood-burni ng with unregistered de vices is no longer allowed when an area’s forecasted PM2.5 concentration is expected to be greater than o r equal to 20 μg/m 3

. This threshold is now lower com pared to past years when it was set at 30 μg/m 3

. Burning is only allowed when ai r quality is forecasted to be be low 20 μg/m 3 , which is well below the current federal 24-hour average PM 2.5 standard o f 35 μg/m 3 . By restricting open burning to this l evel, 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-b y-case basis and in accordance with the five year evaluation period out lined in Rule 4103 with the next evaluatio n scheduled for 2015.

Further progress and complete phase-out of agricultural burning requires economically feasible alternatives that do not currently exist. Subsidies o r preferential utility rates for power produced from biomass c an serve as measures to enhance th e economic feasibility of this alternative. Additional research is also n eeded to identify other technologically and economically feasible alternatives. A comp rehensive strategy to promote these alternatives will also help in meet ing renewable power goals and standards. As the District cont inues to develop new attainment plans that address increasingly stringent federal a ir quality standards, the Distr ict will continue to evaluate potential opportunities to reduc e emissions from open burning i n the Valley.San Joaquin Valley Unified Air Polluti on 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 Polluti on 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 Polluti on 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 s ource operation used for the re duction of animal matter. Adopted on May 21, 1992, prima rily to control pathogens, this r ule was amended for District rule number reorganizati on on December 17, 1992. Rule 4104 requires 100% VOC capture and a hi gh level of destruction (1,200 degrees for 0.3 seconds). EPA finalized approval for Rule 4 104 on March 9, 2010 and deemed th is rule as being at least as stringent, if not more stringent than, RACT requiremen ts.

Source Category The reduction of animal matter includes rendering, cooking, dry ing, dehydration, digesting, evaporating, and prot ein concentration processes. T he emission control equipment for these processes ge nerally includes a condenser fo r VOC control and a venturi scrubber or cyclone, follo wed by either a packed bed sc rubber or a thermal oxidizer. Blood drying facilities have additional processes co ntrolled 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 s team from a boiler (indirect-fi red) or a rotary dryer (directfired) for their operations, whi ch 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 rul es.

As detailed in Chapter 5, the si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from t his source category are lower than the BACM/MSM significance thresholds. Theref ore, the Clean Air Act does not require a control measure evaluation for this sour ce category for the purpose of satisfying BACM/MSM requirements; however, the Distr ict has still conducted a full control measure evaluation for the reduction of animal matter.San Joaquin Valley Unified Air Polluti on 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 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, N ESHAP, or MACT requirements f or this source category.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 4104 compar e to rules in o ther air distr icts?

SCAQMD

 Rule 472 (Reduction of Animal Matter)

The District evaluated the require ments contained within SCAQMD ’s Rule 472 and found no requirements that were more stringent than those alrea dy in Rule 4104.

BAAQMD

 Regulation 12 Rule 2 (Rendering Plants)

The District evaluated the requi rements 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 require ments contained within SMAQMD ’s Rule 410 and found no requirements that were more stringent than those alrea dy in Rule 4104.

VCAPCD

 Rule 58 (Reduction of Animal Matter)

The District evaluated the require ments contained within VCAPCD ’s Rule 58 and found no requirements that were more stringent than those already in Rule 4104.

Additional Emission Re duction Opportunities

Packed Bed Scrubbers The District evaluated the pot ential opportunity to reduce emis sions if facilities were to replace their thermal oxidiz ers with packed bed scrubbers. In certain installations, packed bed scrubbers may be more e fficient at removing PM from the exhaust and additionally do not generate NOx or SOx emissions. However, de termining the scrubber medium may take some ex perimenting on the part of the facility to ensure it does not cause an increase in emi ssions or violate other Distri ct rules. It would also need to be replaced periodically , adding to the cost of upkeep. Thermal oxidizers doSan Joaquin Valley Unified Air Polluti on 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. Als o, facilities subject to Rule 4 104 produce only a very small amount of directly emitt ed PM2.5 and are otherwise alread y required to have a high level of control for emi ssions. The current requirements are as stringent as possible for these types of facilities.

Regenerative Thermal Oxidizers The District also evaluated t he potential opportunity to reduce emissions from facilities by replacing thermal oxidizers with regenerative thermal oxidiz ers (RTOs) with heat recovery, which is a current practice at some facilities in the Valley. RTO devices use less supplementary fuel. While u sing less fuel may reduce NOx emissions, this is not necessarily the case. The PM c ontrol efficiency is nearly the same for both thermal oxidizers and RTOs, and the total NOx emissions from this categ ory 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 w ould be evaluated through the District’s Best Availa ble Control Technology New So urce Review requirements.

Evaluation Findings Even though the reduction of anima l matter is not a significant source of PM2.5, NOx, or SOx in the Valley, the District has evaluated all potential con trol technologies and all control technologies achieved in p ractice in other areas or inc luded in other state implementation plans. As demons trated above, Rule 4104 current ly has in place the most stringent measures feasible to implement in the Valley and therefore meets or exceeds both BACM and MSM require ments for this source category . As the District continues to develop new attainm ent plans that address more str ingent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emissions from this source category in the Valley.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-21 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.3 RULE 4106 PRESCRIBED BURNIN G AND HAZARD RE DUCTION 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 interf ace within the Valle y. Rule 4106 incorpor ated provisions made necessary by the March 23, 2000 amendment of Title 17 of the Ca lifornia Code of Regulations. Recognizing the impor tance of both prescribed bur ning and hazard reduction burning, the purpose o f Rule 4106 is to permit, regul ate, and coordinate the use of prescribed burning and ha zard reduction burning while mi nimizing smoke impacts on the public. Through this rule, the District has exp ended considerable resources to ensure that the i gnition of burn projects is only allowed when air quality and dispersion conditions are fa vorable, thus lessening the hea lth impacts on Valley citizens and on air quality in the Valley.

Source Category This rule is applicable to range improvement burning, forest ma nagement burning, wildland vegetation management burning, and hazard reduction bu rning. Agricultural burning, which is subject to R ule 4103, is generally done by fa rmers to dispose of tree prunings, crop residue, and other agricultural materials; disea se and pest control; and orchard removal. In contrast, p rescribed burning generally inc ludes forest waste, fire hazard reduction, rangeland managem ent, wildlife habitat improv ement, 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from prescribed burning and hazard r eduction burning are lower than the BACM/MSM signific ance thresholds. Therefore, th e Clean Air Act does

18 67 Federal Register 39, pp. 8 894-8897 (to be codified at 40 CF R Part 52). (2002, February 27). Revisions to the California State Implementation Plan, San Joaqui n Valley Unified Air Pollution Control District . Retrieved from https://www.federalregister.gov/articles/2002/02/27/02-4526/rev isions-to-the-california-stat e-implementation-plan-sanjoaquin-valley-unified-air-pollution

.San Joaquin Valley Unified Air Polluti on 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 ev aluation for this source catego ry for the purpose of satisfying BACM/MSM requirement s; however, the District has sti ll conducted a full control measure evaluation fo r prescribed burning and hazard re duction burning.

How does District Rule 4106 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, N ESHAP, or MACT requirements f or this source category.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 4106 compar e to rules in o ther air distr icts?

SCAQMD

 Rule 444 (Open Burning)

The District evaluated the require ments contained within SCAQMD ’s Rule 444 and found no requirements that were more stringent than those alrea dy in Rule 4106.

BAAQMD

 Regulation 5 (Open Burning)

The District evaluated the requi rements contained within BAAQMD ’s Regulation 5 and found no requirements that were more stringent than those alrea dy in Rule 4106.

SMAQMD

 Rule 501 (Agricultural Burning)

The District evaluated the require ments contained within SMAQMD ’s Rule 501 and found no requirements that were more stringent than those alrea dy in Rule 4106.

VCAPCD

 Rule 56 (Open Burning)

The District evaluated the require ments 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 (Nonagricultu ral Burning Smoke Management)

The District evaluated the require ments contained within PCAPCD Rule 301 and found no requirements that were more stringent than those already in Rule 4106.San Joaquin Valley Unified Air Polluti on 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 (Prescri bed Burning Smoke Management)

The District evaluated the require ments contained within PCAPCD Rule 303 and found no requirements that were more stringent than those already in Rule 4106.

Additional Emission Reduc tion Opportunities

Prescribed Burning Emissi on Reduction Opportunities Land Management Agencies (LMAs) a re the agencies that regularly conduct prescribed burning operations. Since the adoption of Rule 4106, the Distr ict has developed cooperative relations hips with the LMAs. Through this cooperat ion, the District advises the LMAs on which days would be the most conducive for igniting a burn project, based on air quality and meteorologic al conditions. The District con tinues to work with LMAs to identify favorable burning co nditions with the goal of compl eting a maximum number of prescribed burning projects wh ile minimizing air quality imp acts. This collaborative effort ensures that the ignition of burn projects occurs when a ir quality and dispersion conditions are favorable, thus l essening the impacts on air qua lity in the Valley. Potential opportunities to reduc e emissions from prescribed bur ning include the mechanical removal of the materi als, firebox air curtain burner s, and management of wild fires.

Mechanical Removal of Materials One potential option to reduce burning materials would be to ph ysically 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 fore st lands to collect and remove the material. Additional ly, mechanical removal is much more expensive for the LMAs, who are already subject to budgeting restrictions, to red uce the fuels in an area as compared to burning. Mechanica l removal of materials from f orest areas is not technologically or economically feasible.

Firebox Air Curtain Burners Assuming that a LMA could mechani cally remove all of the materi al from a project burn site and that the mate rial was placed in piles and prepared for burning, an alternative to open burning would be to use a f irebox air curtain burner. A f irebox air curtain burner is a device that circulates large volumes of air over a burning fi re in an open topped fire proof metal box. When compared to open burning, firebox air cu rtain burners have been shown to greatly reduce PM and carbon dioxide emissions; h owever, the potential NOx emissions compared to open bur ning have not been fully eval uated yet. Because the Valley is a NOx-limited area, more research on the technolo gy is needed to verify that there would be pot ential NOx emission reductions by switch ing from open burning practices to the use of fir ebox air curtain burners.

Wildfires Often, primarily during the warm summer months, wildfires are n aturally ignited through lightning strikes from passing storms. These wildfires have th e potential to produce significant emissions and heavily impact residents within the V alley. When these wildfires occur, the District wor ks with the responsible LMA in managing the fire as theSan Joaquin Valley Unified Air Polluti on 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 condi tions fluctuate. This cooperat ion allows the LMA to be more aggressive with the fire w hen meteorological conditions ar e favorable and more defensive when the conditions ar e poor. The District will cont inue to use the tools available to guide the activiti es of LMAs when wildfires occur, and is continuously seeking opportunities to work with LMAs to improve the manageme nt of these fires in order to reduce emissions and im pacts to Valley residents.

Hazard Reduction Burning Emi ssion Reduction Opportunities Hazard reduction burning is used exclusively by landowners in t he 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 fee t in all directions; this defens ible perimeter is commonly created through the clearing of v egetation. Although Section 4 291 does not require it, most of this vegetation is bur ned because it is less expensive, faster, and more convenient than other options. Pot ential opportunities evaluat ed below include the reorganization of hazard reducti on zones and alternatives to bu rning the vegetation.

Reorganization of Hazard Reduction Zones Under Rule 4106, hazard reduction burning is only allowed when the District forecasts favorable air quality and disper sion conditions. Currently thi s forecast is based on a county-by-county basis, with appr opriate elevation breaks. As an improvement to this zone system, and similar to agric ultural burning, the Valley co uld be separated into smaller hazard reduction zones to provide more effective smoke management. Managing the allowance of hazar d reduction burning under this t ype of scheme also has the potential to limit smoke im pacts on residents. Establishin g this type of management system would not cause an increas e in costs for landowners, mak ing this a cost effective opportunity. Howeve r, emissions reduced, if any, wou ld be minimal, since the burning would still occur, just on different days when conditio ns are favorable.

Alternatives to Burning As an alternative to the open bur ning of the vegetation, the Di strict could encourage alternative methods like chi pping or burn boxes through grant p rograms targeted at communities that regularly conduc t hazard reduction burning.

1. Chipping One potential alternative to t he open burning of material is to use a chipper to break down the material into small pi eces suitable for landscaping, d ust control cover, or biomass burning. Evaluation o f this alternative option reveale d that chippers are not a viable alternative. The require ment by the CPRC to maintain a defensible perimeter of 100 feet is enfor ced annually; theref ore, the orga nic materials to be cleared and disposed of consist of leaves, pine needles, weeds, and some small brush, all of which are not acc eptable materials for wood chipp ers.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-25 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard 2. Firebox Air Curtain Burners Another potential oppor tunity examined is the feasibility of us age of a firebox air curtain burner, which was descr ibed earlier. Again, this is no t a feasible option for the Valley because the potential NOx emission reductions have n ot been verified.

3. Biomass Removal Program A potential opportunity to reduce em issions from hazard reducti on burning would be by removing the biomass from the area and sending it for combus tion at a biomass plant, similar to a pilot program implemented by the PCAPCD in 2007. The pilot program in Placer Cou nty was evaluated belo w to determine feasi bility for implementation in the Valley.

PCAPCD Program PCAPCD implemented a “Biomass Box” program beginning in the spr ing of 2007 to collect and utilize biomass that w ould traditionally be collect ed and burned as a part of hazard reduction efforts, fo r use as fuel for producing ener gy. The program, funded with a grant from PCAPCD, collected the biomass by distr ibuting 20 to 40 foot industrial containers thr oughout participating communities in the county. When full, the containers were transpor ted to another location where the materials were grinded into useable fuel that b iomass energy companies could a ccept. The chipped biomass was then loaded onto larger trucks and hauled t o one of two biomass facilities.

Figure C-3 Image of a Typical 4 0' Biomass Box Used in Placer C ounty in 2007

The final report by PCAPCD that eva luated this pilot program do cumented that from an emissions reductions standpoint the project was a success, w ith 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 s tudy, the DistrictSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-26 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard evaluated this pilot program fo r potential emissions reductions and feasibility of implementation in the Valley.

Hazard reduction in Placer Count y is overseen by the Placer Cou nty 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 desi gned to change the culture of hazard reduction burni ng by providing an alternative to burning. However, the bin program proved to have many complications that rendered it an ineffective program. One issue wa s that residents were disposing of items other than biomass into the bins. This caused probl ems for the chippers and produ ced less than ideal fuel for biomass plants. Additi onally, PCAPCD determined that the transport of biomass bins any further than 30 miles round trip was cost proh ibitive. 19

A few biomass bins were still in u se as of 2013, but only in co mmunities that explicitly requested them follo wing the 2007 pilot project. PC APCD determined that there are more cost effective opt ions for removing residential biomass then using community biomass bins, such as u sing mobile chippers to provid e residents with a low cost “curb side” chipping se rvice. The chipped biomass is blown back onto the property for use as mulch or as a dust suppressant. The progra m is supported in part by grants from Placer Count y Resource Conservation Distric t, Placer County Sheriff’s Department, PCAPCD, and Calfire. As stated above, ch ipping is not a feasible option to imp lement in the Valley.

Evaluation Findings Even though prescribed burning a nd hazard reduction burning are not a significant source of PM2.5, NOx, or SOx in the Valley, the District has ev aluated all potential control technologies and all c ontrol technologies achieved in p ractice in other areas or included in other state implem entation plans. As demonstrated above, Rule 4106 currently has in place the mos t stringent measures feasible to implement in the Valley and therefore meets or exceeds b oth BACM and MSM requirements f or this source category. As the District conti nues to develop new attainment plans that address more stringent National Ambient Air Q uality Standards, the District will continue to evaluate potential opportunities to reduc e emissions from prescribed bur ning and hazard reduction burning in the Valley.

19 Storey, B., Biomass Program Mana ger, Placer Coun ty Executive O ffice, Personal Communication.San Joaquin Valley Unified Air Polluti on 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, inc inerator, or equipment used to dispose or process combustion r efuse. The rule limits the c oncentration of particulate matter emissions based on proce ss weight rates, and prohibits t he discharge of visible emissions. Rule 4203 was adopted on May 21, 1992 and subsequen tly amended for District rule number reorganizati on on December 17, 1992.

Source Category There are currently 3 facilitie s in the Valley subject to Rule 4203. Units subject to this rule already meet BACT level re quirements, which require the mi tigation of air pollution to the maximum degree achievable using control technologies lik e 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 si gnificance threshold for source categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts is 1.4 tons per day (tpd) for PM2.5 combustion . As identified in the above tab le, emissions from the incineration of combus tible refuse are lower than the BACM/MSM PM2.5 significance threshold. Therefore, the Cl ean Air Act does not require a con trol measure evaluation for this source category for t he purpose of satisfying BACM/MSM requirements; however, the District has still co nducted a full control measur e evaluation for the incineration of combustible refuse.

How does District Rule 4203 compar e with federal and state rule s and regulations?

Federal Regulations There are no specific federal guidelines for particulate matter concentration in terms of EPA CTG, ACT, NSPS, NESHAP, or MA CT requirements. EPA BACT sta ndards require the use of a fabric f ilter or baghouse. District BACT standards are as stringent and require existing facilities to use a natural gas supplement al fuel with a baghouse.San Joaquin Valley Unified Air Polluti on 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 re gulations applicable to this source catego ry.

How does District Rule 4203 compar e to rules in o ther air distr icts? There are no analogous rules fo r this source category in BAAQMD

.

SCAQMD

 Rule 473 (Disposal of Solid and Liquid Wastes)

The District evaluated the require ments contained within SCAQMD ’s Rule 473 and found no requirements that were more stringent than those alrea dy in Rule 4203.

SMAQMD

 Rule 407 (Open Burn)

The District evaluated the require ments contained within SMAQMD ’s Rule 407 and found no requirements that were more stringent than those alrea dy in Rule 4203.

VCAPCD

 Rule 57 (Incinerators)

The District evaluated the require ments 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 o f PM2.5 in the Valley, the Distri ct has evaluated all potential control technologies and all control technologies ach ieved in practice in other areas or included in other state implementation plans. As demo nstrated above, Rule 4203 currently has in place the most stringent measures feasibl e to implement in the Valley and therefore meets or exceeds bot h BACM and MSM require ments for this source category. As the District continues to develop new atta inment plans that address more stringent National A mbient Air Quality Standards, the District will continue to evaluate potential opportuniti es to reduce emissions from th e incineration of combustible refuse in the Valley.San Joaquin Valley Unified Air Polluti on 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, R ule 4204 is intended to reduce p articulate emissions from cotton ginning facilities operating within the Valley. Th e implementation of this rule has achieved 0.79 tpd of PM10 r eductions from this source categ ory. EPA finalized approval of Rule 4204 on Novemb er 9, 2006 and deemed this rule as meeting established RACT standards.

The 2003 PM10 Plan identified cotton gins as a signi ficant source of PM10 emissio ns in the Valley. The federal CAA requi res air districts designated as Serious nonattainment for PM10 to implement BACM, inc luding BACT, on significant stat ionary and area sources of PM10 and PM 10 precursors. Although many gins in the Valley were already retrofitted with 1D3D high-e fficiency cyclones, considered BACT , the District developed Rule 4204 to assure that all cott on gins met BACT requirements at the earliest practicable date.

Source Category There are two types of cotton gi ns: saw and roller. A saw gin is commonly used for short fiber cotton where the co tton is pulled across knifed edg es 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 perfo rated metal where the trash i s removed. Throughput for saw gins can be higher than t hat of a roller gin, but a rol ler gin produces a higher quality end-product.

Modern ginning uses pneumatic c onveyance, in the form of fans b lowing air, which moves the cotton gin material. P articulate matter emissions ar e the unwanted byproducts of this otherwise very efficient means of transferring massive quantities of cotton gin material from one pr ocess to the next process, such as from unloading to drying and cleaning. PM emissions from cotton ginning faciliti es occur mostly during a three-month period from October to December, the time of year d uring which the Valley’s ambient PM concentrations are highest.

Cotton ginning, the process o f separating the lint from the see d, has evolved from a labor-intensive process capable of producing small quantities o f cotton to a highly efficient industry producing mill ions of bales. With this incr ease in production came the problem of how to handle the debri s made up of plant and soil m aterial that comes from machine harvesting the cotton. Since cotton gins use large qua ntities of air for conveying, the use of cyclones fo r air pollution abatement was a logical choice.

Cotton gins are regulated through a combination of permit condi tions and other prohibitory rules aside from R ule 4204. Permit conditions cite Rules 1070, 2201, 4101, 4102, 4201, and 4202 as the regulat ory 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 Polluti on 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 cont rol devices for specific exhau st points. b. Allowable PM10 emission rate fo r the cotton gins as an integ rated 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 t he atmosphere of air contaminant s for a period or periods aggregating mo re than three minutes in any on e hour, which is as dark as or darker than Rin gelmann 1 or 20% opacity.

 Rule 4102 prohibits the release of air c ontaminants that causes a public nuisance.

 Rule 4201 limits particulate matter emi ssions concentration to 0.1 grain s/dscf or less.

 Rule 4202 limits particulate matter emi ssions 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from c otton gins are lower than the BACM/MSM significance thresholds. Therefore, the Clean Air Act does not require a co ntrol measure evaluation for this source category for t he purpose of satisfying BACM/MSM requirements; however, the District has still co nducted a full control measur e evaluation for cotton gins.

How does District Rule 4204 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, N ESHAP, or MACT requirements f or this source category.

State Regulations There are no state re gulations applicable to this source catego ry.San Joaquin Valley Unified Air Polluti on 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 compar e to rules in o ther air distr icts? 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 require ments contained within New Me xico Administrative Code 20.2.66.1 and found no requirements that were more stringe nt than those already in Rule 4204.

 Louisiana Department of Environm ental Quality, Title 33 (Envir onmental Regulatory Code), Part III (Air)

The District evaluated the requi rements contained within Louisi ana 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, S ection .0542 (Control of Particulate Emissions from Cotton Ginning Operation s)

The District evaluated the require ments contained within North Carolina Administrative Code Title 15A, Subchapter 2D, S ection .0542 and found no requi rements that were more stringent than those already in Rule 4204.

 South Carolina Air Pollution Control Regula tions and Standards , Regulation 61-62.5, Standard No. 4, Section V (Cotton Gins)

The District evaluated the require ments 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 Environment al Quality, Air Pollution Co ntrol, 252:100-23 (Cotton Gins)

The District evaluated the require ments 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 Environmen tal Quality, Air Quality Standar d Permit for Cotton Gin Facilities and Cotton Burr Tub Grinders

The District evaluated the requi rements contained within the ab ove rules and found no requirements that were more str ingent than those already in Rul e 4204.San Joaquin Valley Unified Air Polluti on 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 Reduc tion Opportunities

Research and PM2.5 Fraction Research was completed in 2013 by the United States Department of Agriculture Agricultural Research Service (US DA-ARS), in part nership with c otton associations, EPA, ARB, and the District to measu re actual PM10 and PM2.5 emi ssions from stack sources and fugitive emissions in and around several ginning fa cilities. This research provided emission factors for co mparison to previous estimation s 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 fro m facilities with current emissions control technologies in place and to improve emission s estimations by measurement with the highest qua lity methods and instruments. The project was not designed to evaluate new technol ogies or measures to further re duce emissions. Results for the seven gins that were sampled for th e 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 t he emissions inventory current ly being used. Future research will include particle s ize analysis of EPA Method 17 s amples, and modeling to compare model output and ambien t sampling data and develop sugg ested modeling corrections.

1D3D Cyclones with Expansion Chamber Currently, all cotton gins in t he Valley are required to operat e using a 1D3D cyclone. About two thirds of the 1D3D cycl ones used in the Valley have a n expanded chamber outlet. Research has shown that an expansion chamber allows fo r more flow since it is not as narrow. In initial tests , a larger D/3 size expanded ch amber exit produced PM10 emissions that were about 8% lower than those resulting from us e of the standard, small-diameter (D/4) exit. 21 However, there is no complet ed research indicating the fraction of PM2.5 emitted or t he 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 v erify the effectiveness in redu cing PM2.5 emissions with an expansion chamber, this is not a feasible opportunity to red uce emissions.

Loadout Rule 4204 currently require s wind screens for loadout. Two pot ential opportunities to reduce emissions through control options to capture PM10 emissi ons from the truck loading operation we re identified as follows: 1) venting the lo adout area to pre-cleaning cyclones and a baghouse; and 2) vent ing the receiving pit to a 1D-3D cyclone. While it is technologically feasible to enclose the loadout area and rec eiving pits and vent to the respective control devices, the Dis trict’s BACT Guideline 5.1.8 has found those options to not be cost effective. This analysis was calculated accordi ng to PM10 emission factors and again, the PM2.5 fr action is unknown at this time.

20 United States Department of Agr iculture, Agricultural Research Service. (2013). Characterization of Cotton Gin Particulate Matter Emissions. Obtained from http://buser.okstate.edu/air-qualit y/cotton-gin/nat ional-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 Polluti on 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 demonstra ted as feasible for newly constructed or rebuilt co tton gins. Mechanical conveyanc e almost entirely eliminates emissions from cott on gin trash handling exhaust str eams, which were previously moved pneumatically . The cotton gin trash handling systems only comprise a fraction of the emissions tha t are released from the full cot ton ginning process. Newer or rebuilt cotton gins are able to accommodate a mechanical con veyance system since they are able to design the cotton gin around the equipment and space needed. Operators that have installed a mechanical conveyance system fo r their cotton gin have had to build a lower floor, below the main level containing the major cotton gin equipment, to house the mechanic al conveyors. Therefore, as co nfirmed by industry representatives and equipment m anufacturers, it is not technolo gically feasible to retrofit existing cotton gins with mechani cal conveyance systems to repl ace existing trash handling equipment. Addi tionally, any new fac ilities would tri gger New Source Review requirements and would be required to implement BACT level cont rols.

Plenum Chambers Plenum chambers are in use at a number of cotton gins in the Va lley. Plenum chambers are placed upstream of s elected cyclones to remove lar ge trash. Studies have been inconclusive in demonst rating an increase in PM contr ol efficiency with the utilization of a plenum chamber. Most cotton ginning facilitie s that have installed plenum chambers are using thos e 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 evaluat ed all potential control techno logies and all control technologies achieved in practic e in other areas or included in other state implementation plans. As demons trated above, Rule 4204 current ly has in place the most stringent measures feasible to implement in the Valley and therefore meets or exceeds both BACM and MSM require ments for this source category . As the District continues to develop new attainm ent plans that address more str ingent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emissions fr om cotton gins in the Valle y.San Joaquin Valley Unified Air Polluti on 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 ru le is to limit emissions of air contaminants from fuel burni ng equipment by specifying maxi mum emission rates for SOx, NOx, and PM (identified in t he rule as combustion contamin ant emissions). EPA finalized approval of the 1992 am endments to Rule 4301 on May 1 8, 1999 and deemed this rule as being at least as stringent as established RACT re quirements.

Source Category Rule 4301 has a very broad applic ability, as it applies to all types of fuel burning equipment. Since its early adopti on in 1992, it has largely be en superseded by several District rules with more stringen t NOx requirements for specifi c types of fuel burning equipment. See the control meas ure evaluations for Rules 4306, 4307, 4308, 4309, 4352, and 4703 for more specific i nformation about the individu al fuel burning equipment source categories.

Emissions Inventory There is no emissions inventor y specific to Rule 4301; see Rule s 4306, 4307, 4308, 4309, 4352, and 4703 for the indivi dual emissions inventories.

How does District Rule 4301 compar e with federal and state rule s and regulations? Facilities subject to Rule 4301 are subject to various state ru les and federal requirements, such as CTG, ACT , NSPS, NESHAP, and MACT. Howeve r, as previously mentioned, several District rules have superseded Ru le 4301 with more stringent requirements. Comparisons of those District rules to the applicable federal and state rules are di scussed within those control measure eval uations.

How does District Rule 4301 compar e to rules in o ther air distr icts? There are no analogous rules in BAAQMD, SMAQMD, and VCAPCD.

SCAQMD

 Rule 474 (Fuel Burning Equi pment—Oxides of Nitrogen)

The District evaluated the require ments contained within SCAQMD ’s Rule 474 and found no requirements that were more stringent than those alrea dy in Rule 4301.

Evaluation Findings District Rule 4301 alone cannot be considered to fulfill BACM/M SM requirements for this source category. The NOx re quirements of this rule have be en superseded by the requirements of other District r ules that satisfy BACM/MSM for fuel burning equipment since all units subj ect to Rule 4301 are subject to a more spec ific NOx rule discussed elsewhere in this appendix. See t he control measure evaluation s for Rules 4306, 4307, 4308, 4309, 4352, and 4703.San Joaquin Valley Unified Air Polluti on 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 appl y to any gaseous fuel or liquid fuel fi red boiler, steam generator, or process heater with a total rated heat input grea ter than 5 million British thermal units per hour (MMBtu/h r). The purpose of these rules is to limit NOx and carbon monoxide (CO) emissions fr om boilers, steam generators, and process heaters of this size range.

Rule 4320 is the third generati on rule for this source category . The first District rule for this source category, Rule 4305 (B oilers, Steam Generators, and Process Heaters), was adopted on December 16, 1993 . Rule 4305 was superseded by Rule 4306 (Boilers, Steam Generators, and Pr ocess Heaters – Phase 3) on S eptember 18, 2003 to implement a NOx control measur e from the District’s ozone and P M10 attainment plans, lowering the NOx emi ssions limits in Rule 4305. Since adoption , Rule 4306 has been amended twice.

The amendment of Rule 4306 in Oct ober 2008 was initially propos ed to lower the NOx emission limit from 9 ppmv to 6 ppmv for units greater than 20 MMBtu/hr. It was determined that the pr oposed NOx limits coul d be accomplished b y using selective catalytic reduction (SCR) or a co mbination of SCR and ultra-low NOx burners (ULNBs), thus making the lower limits te chnologically feasible. However , through the public workshop process and additional re search 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 effec tive and/or technological infeasible because of physical limitations. There fore, the lower NOx limits were included in new Rule 43 20 and an option wa s provided in th e rule that allows for the payment of an annual emissions fee based on total actual em issions, rather than installation of additional NOx c ontrols. These fees are used b y the District to achieve cost effective NOx reductions th rough District incentive progra ms, the District’s Technology Advancement Program, and other routes. The previous versions of Rule 4305 and 4306 combined wit h the implementation of Rule 4320 ach ieve approximately 96% control of NOx emissions from this source category.

The implementation of Rule 432 0 does not substitute the require ments of Rule 4306, but enforces requirements supplem entary 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 ran ge of industries, including but not limited to electrical utilities, cogeneration, oil and gas production, petroleum refining, manufacturing and indu strial processes, food and agri cultural processing, and service and commercial facilities.San Joaquin Valley Unified Air Polluti on 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 te chnical differences between different types of equipment subject to Rules 4306 and 4320, the different equipme nt types were separated into several major cat egories, with different require ments, including the following:

 Units with a total rated heat i nput greater than 5.0 MMBtu/hr to 20.0 MMBtu/hr

 Units with a total rated hea t input greater th an 20.0 MMBtu/hr

 Oilfield steam generators o f all ratings and fuel types

 Refinery units of all ratings and fuel types

 Low-use units limited by a P ermit to Operate to an annual heat input greater than 1.8 billion Btu/year but less than or equal to 30 billion Btu/y ear

 Units at a wastewater treatment facility using less than 50% P UC quality fuel

 Small specialty units oper ated 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion em issions, 13.1 tons per day (tp d) for NOx, and 1.0 tpd for SOx. As identified in the above table, emissions from boil ers, steam generators, and process heaters greater than 5.0 MMBtu/hr are lower than the BA CM/MSM significance thresholds. Therefore, the Clean Air Act does not require a co ntrol measure evaluation for this source category for t he purpose of satisfying BACM/MSM requirements; however, the District has still co nducted a full control measur e evaluation for this source category.

How does District Rul e 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 (Alter native Control Techniques Document – NO x emissions from Process Heaters)San Joaquin Valley Unified Air Polluti on 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 requi rements contained within the AC T for NOx Emissions from Process Heaters and found no requirements that were more s tringent than those already in Rule s 4306 and 4320.

 EPA-453/R-93-022 (Alter native Control Techniques Document – NO x Emissions from Industrial/Commercial /Institutional Boilers)

The District evaluated the requi rements contained within the AC T for NOx Emissions from Industrial/Commercial/Instit utional Boilers and found no r equirements that were more stringent than those alr eady in Rules 4306 and 4320.

 EPA-453/R-93-023 (Alter native Control Techniques Document – NO x Emissions from Utility Boilers)

The District evaluated the requi rements contained within the AC T for NOx Emissions from Utility Boilers and found no requirements that were more s tringent than those already in Rule s 4306 and 4320.

NSPS

 40 CFR 60 Subpart D (Standards of Performance for Fossil-Fuel Fired Steam Generators for Which Constructi on Is Commenced After August 17, 1971)

The District evaluated the require ments contained within 40 CFR 60 Subpart D and found no requirements that were more stringent than those alrea dy in Rules 4306 and 4320.

 40 CFR 60 Subpart Db (Standards o f Performance for Industrial- CommercialInstitutional Steam Generating Units)

The District evaluated the require ments contained within 40 CFR 60 Subpart Db and found no requirements that were more stringent than those alrea dy in Rules 4306 and 4320.

 40 CFR 60 Subpart Dc (Standards o f Performance for Small Indus trial- CommercialInstitutional Steam Generating Units)

The District evaluated the require ments contained within 40 CFR 60 Subpart Dc and found no requirements that were more stringent than those alrea dy 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 am ended on January 31, 2013 to incl ude new emission limits for PM, CO, and to tal selective metals (TSM), r eplace numeric dioxinSan Joaquin Valley Unified Air Polluti on 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 pra ctice standards, add new subcatego ries of facilities, and add alternative monitoring approa ches for compliance with the P M limit. The PM limit in District Rule 4320 is more stri ngent for liquid fuels because i t only allows liquid fuels to be burned during PUC qual ity natural gas curtailment periods. It is equivalent to DDDDD for all gasses burned exc ept for gasses exceeding 40 μg/m 3 of mercury.

The District evaluated the requi rements contained within the ab ove NESHAP and found no requirements that were more stringent than those already in Rules 4306 and 4320.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rul e 4306/4320 compare to rules in other air districts?

SCAQMD

 Rule 1146 (Emissions of Nitrogen from Industrial, Institutiona l, and Commercial Boilers, Steam Generators , and Process Heaters)

SCAQMD Rule 1146 was amended on November 1, 2013 to include rul e language clarifications and revisions to address SIP credi tability issue s. None of the amendments affected emissions reductions.

The District evaluated the require ments contained within SCAQMD ’s Rule 1146 and found no requirements that were more stringent than those alrea dy in Rules 4306 and 4320.

BAAQMD

 Regulation 9 Rule 7 (Nitrogen Ox ides and Carbon Monoxide from Industrial, Institutional and Commercial Bo ilers, Steam Generators and Proc ess Heaters)

The District evaluated the requi rements contained within BAAQMD ’s Regulation 9 Rule 7 and found no requirements that w ere more stringent than those already in Rules 4306 and 4320.

 Regulation 9 Rule 10 (Nitrogen Oxides and Carbon Monoxide from Boilers, Steam Generators and Proce ss Heaters in Petro leum Refineries)

The District evaluated the requi rements contained within BAAQMD ’s Regulation 9 Rule 10 and found no requirements tha t were more stringent than thos e already in Rules 4306 and 4320.

SMAQMD

 Rule 411 (NOx from Boilers, P rocess Heaters and Steam Generato rs)

The District evaluated the require ments contained within SMAQMD ’s Rule 411 and found no requirements that were more stringent than those alrea dy in Rules 4306 and 4320.San Joaquin Valley Unified Air Polluti on 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 Gener ators and Process Heaters)

The District evaluated the require ments contained within VCAPCD ’s Rule 74.15 and found no requirements that were more stringent than those alrea dy in Rules 4306 and 4320.

Additional Emission Reduc tion Opportunities Over the years, the District has adopted numerous generations o f rules and rule amendments for boilers greater t han 5 MMBtu/hr that have signif icantly reduced NOx and PM emissions from this source category. The emissions inve ntory for NOx from these boilers has dropped from 4 0.2 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 te chnologies. Given the significa nt effort already made to reduce emissions from this source category, there are little re maining 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 Oxi dation (LTO) System was instal led at a dairy in the SCAQMD and was able to reach NOx limits between 1.0- 3.2 ppmv f or 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 informati on, capital and installation costs ranged from $360,000 - $400,000 for the LTO system when it was installed in 1997. 22 Installation within t he South Coast region was heavily subsid ized with government funding and the in stallation costs appear cost prohibitive for an installation that is not subs idized. In addition, the LTO syst em is classified as “Other Technologies” in the SCAQMD BAC T guidelines, which means that t he technology has not met the achieved in practice (AIP) criteria of six months o f continuous operation at a minimum of 50% operating capac ity and does not qualify as the l owest achievable emission rate (LAER). Since t he technology has not been achiev ed in practice and cost prohibitive without significan t subsidies, this is not a feasib le opportunity at this time.

EMx The District researched the potent ial for emissions reductions through EMx, the second generation of the SCONOx technol ogy that is a post-combustion c ontrol that reduces NOx, SOx, CO, and volatile or ganic compound (VOC) emissions. T his technology has not been AIP in the District and th ere is no available data tha t indicates that SCONOx or EMx has been installe d on boilers even though the manufacturer’ s website states that the technology is transferrable to industrial boilers. Based o n research of the best available controls from EPA and o ther air districts, the SCONOx and EMx systems have only been utilized by power plants for control of turbine emiss ions. In fact, cost effectiveness analyses conducted by the District for the instal lation of SCONOx/EMx

22 South Coast Air Quality Management District. (2012). SCAQMD Best Available Control Technology (BACT) Database

.San Joaquin Valley Unified Air Polluti on 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 turbin e installations within the Val ley have been found to not be cost effective. Given the high cost effectiveness demonstra ted for turbines and lack of demonstrated practice with boilers, this technology is not f easible or cost effective for reducing emissions from this category.

PM2.5 Limits for Alternative Fuels The majority of boilers (>5 MMB tu/hr) in the Valley combust Pub lic Utilities Commission (PUC) quality natural gas, which c ontains a very low sulfur con tent and inherently has low emissions. Few boilers in t he Valley use alternative fuels for their combustion processes. Alternative fuels include digester gas, produced ga s, and liquid fuel. Units fired on digester gas or produc ed gas are already required to u se inlet gas scrubbers to meet District rule requirement s. Current rule language require s that liquid fuel shall be used only during a PUC- quality natural gas c urtailment period p rovided it contains no more than 15 ppm sulfur. While the use of liquid fuel is stric tly limited, the feasibility of reducing PM emissions through addi ng PM2.5 limits for units usi ng liquid fuel was explored as part of the District’ s comprehensive control measur e evaluation.

There are 83 units that are permi tted to utilize liquid fuel in the Valley (> 5 MMBtu/hr) during a natural gas curtailmen t with an average combined emiss ions inventory of approximately 0.034 tons per year o f total PM. The low emissio ns inventory is attributed to the fact that thes e units either utilize liquid f uel as a backup if there is a natural gas curtailment. The fo llowing three technologies were researched as potential opportunities to reduce PM emissi ons: baghouses, electrostatic precipitators (ESPs), and wet scrubbers. Baghouses control total PM and PM2.5 emissi ons by 90-99%; ESPs control total PM and PM2.5 emissions by 90-99%; and wet sc rubbers control large particulates (>PM5) by 99 % and PM2.5 emissions by approxi mately 50%. 23 Currently, there are a few crude oil-fired or field gas-fired s team generator s operating in crude oil production facilities t hat are required by their perm its to operate SOx scrubbers and ESPs. However, baghouses are typically not used with liqui d-fired boilers due to the potential clogg ing of the baghouse 24 and are therefore not a recommended technology due to infeasibility and safety issues.

23 Northeast States for Coordinat ed Air Use Management. (Novembe r 2008) Applicability and Feas ibility of NOx, SO2, and PM Emissions Control Technologies for Indus trial, Commercial, and Inst itutional (ICI) Boilers. Retrieved from http://www.google.com/u rl?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=7nfvVIivFai1sAT 07IHIAg&usg=AFQjCNFBdQn7MVAibSTZ IbHV7- ojXkVlXQ&bvm=bv.86956481,d.cWc

. 24 Northeast States for Coordinat ed Air Use Management. (Novembe r 2008) Applicability and Feas ibility of NOx, SO2, and PM Emissions Control Technologies for Indus trial, Commercial, and Inst itutional (ICI) Boilers. Retrieved from http://www.google.com/u rl?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=7nfvVIivFai1sAT 07IHIAg&usg=AFQjCNFBdQn7MVAibSTZ IbHV7- ojXkVlXQ&bvm=bv.86956481,d.cWc

.San Joaquin Valley Unified Air Polluti on 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 calcul ations, the following assumptio ns were made:

1. For simplicity, the analysis will evaluate the cost effectiv eness of these technologies for total PM reduc tions from liquid fuel fired uni ts. 2. The PM control effici ency of an ESP is 99%. 3. The PM control efficien cy 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 insta llation of an ESP for a 1-5 MMBtu /hr boiler ranges from $90,000 - $100,000 and t he annual maintenance cost is $1,000-$2 ,000. 25 For the wet scrubber system, EPA estimated t he annualized cost at $5,300-$1 02,000 per sm 3 /sec at an average air flow rate of 0.7-47 sm 3 /sec. 26 The District used the following assumptions in the cost effectiveness calculations:

1. The capital cost of an ESP fo r a 5 MMBtu/hr boiler is assume d to be $100,000. 2. The annual maintenance cost o f an ESP for a 5 MMBtu/hr boile r is assumed to be $2,000. 3. The annualized cost of a wet scrubber system is assumed to b e the median of the range above ($53,650 per sm 3 /sec). 4. The average air flow rate fo r a wet scrubber system is assum ed to be the median of the range above (23.85 sm 3 /sec). 5. The total capital and maint enance cost of an ESP will be cal culated by multiplying the cost of 1 uni t by the total number of units. 6. The total annualized cost of a wet scrubber will be calculat ed by multiplying the annualized cost of 1 unit by t he total number of units. 7. Lifetime of the ESP is 10 years at 10% i nterest. To account for this, the annualized capital cost will be calc ulated by multiplying the t otal capital cost by the capital recovery factor o f 0.1627 and adding the annual mai ntenance 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 Agen cy Office of Air Quality Planning and Standards and Northeas t 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/ttnca tc1/dir1/fsprytwr.pdf

.San Joaquin Valley Unified Air Polluti on 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/ sm 3 /sec) x (83) x (23.85 sm 3 /sec) Annual Cost (scrubber) = $106,202,858/ year

Cost Effectiveness of an ESP and Wet Scrubber Cost Effectiveness = Annual Cos t / 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 e ffective option for this source category. The cost of the ESP technology does not inclu de costs of retrofitting equipment and/or the facility or compliance monitoring costs, w hich would drive the cost effectiveness up even more.

Evaluation Findings Even though boilers, steam generat ors, and process heaters grea ter 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 ach ieved in practice in other areas or included in other state implementation plans. As demo nstrated above, Rule 4306 and 4320 currently have in p lace the most stringent measur es feasible to implement in the Valle y and therefore meet o r exceed both BACM and MSM requirements for this source c ategory. As the District continu es to develop new attainment plans that address mo re stringent National Ambient A ir Quality Standards, the District will continue to e valuate potentia l opportunities to reduce emissions from this source category in the Valley.San Joaquin Valley Unified Air Polluti on 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 GE NERATORS AND PROCESS HEATERS– 2.0 MMBTU/HR TO 5.0 MMBTU/HR

Discussion This rule applies to any gaseous fuel or liquid fuel fired boil er, steam generator, or process heater with a total ra ted heat input of 2.0 million Bri tish thermal units per hour (MMBtu/hr) up to and including 5.0 MMBtu/hr. The purpose of th is rule is to limit emissions of NOx, carbon monoxide (CO), sulfur di oxide (SO2), a nd particulates from units subject to this rule.

Rule 4307 was adopted on December 15, 2005 to establish emissio ns limits and control requirements for these units whi ch were previously exempt becau se of their smaller size. Since its adoption, the rule has been amended three time s. The October 2008 amendments strengthened the rule by removing some exemptions, i mposing NOx limits of 9 or 12 ppmv for new and repl acement units, and adding a men u-approach for particulate matter control tha t also encompasses SOx controls. The rule was amended again in 2011 to specifically inc orporate tree nut pasteurizers as a separate type of unit. EPA published a direc t final approval of the 2011 amendments to Rule 4307 on February 12, 2015 and deemed this rul e as being at least as str ingent as established RACT requirements. NOx emissi ons have been controlled by over 84% for units in this source category.

Source Category Based on District permits infor mation, 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 ran ge of industries, including but not limited to, medical fac ilities, educational institution s, 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from b oilers, steam generators, and process heaters 2.0 to 5.0 MMBtu/hr are lower than the BACM/MSM significance threshold s. Therefore, theSan Joaquin Valley Unified Air Polluti on 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 c ontrol measure evaluation for this source category for the purpose of satisfying BACM/MS M requirements; however, the D istrict has still conducted a full control measure evaluation for this source cat egory.

How does District Rule 4307 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG or NSPS requirements for this source categ ory.

ACT

 EPA–453/R-93-034 (Alternative Cont rol Techniques Document–NOx Emissions from Process Heaters)

The District evaluated the requi rements contained within the AC T for NOx Emissions from Process Heaters and found no requirements that were more s tringent than those already in Rule 4307.

 EPA–453/R-94-022 (Alternative Cont rol Techniques Document–NOx Emissions from Industrial/Commercial/Institutional Boilers)

The District evaluated the requi rements contained within the AC T for NOx Emissions from Industrial/Commercial/Instit utional Boilers and found no r equirements that were more stringent than those already in Rule 4307.

 EPA–453/R-94-023 (Alternative Cont rol Techniques Document–NOx Emissions from Utility Boilers)

The District evaluated the requi rements contained within the AC T for NOx Emissions from Utility Boilers and found no requirements that were more s tringent 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 am ended on January 31, 2013 to incl ude new emission limits for PM, CO, and to tal selective metals (TSM), r eplace numeric dioxin emission limits with work pra ctice standards, add new subcatego ries of facilities, and add alternative monitoring approa ches for compliance with the P M limit. The PM limits in 40 CFR 63 Subpart DDDDD would not apply to Rule 4307 sources . Subpart DDDDD contains alternative requirement s for units less than 10 MMBtu/ hr and requires tuning every 2-5 years.

The District evaluated the require ments contained within 40 CFR 63 Subpart DDDDD and found no requirement s that were more stringent than those a lready in Rule 4307.San Joaquin Valley Unified Air Polluti on 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 re gulations applicable to this source catego ry.

How does District Rule 4307 compar e to rules in o ther air distr icts?

SCAQMD

 Rule 1146.1 (Emissions of Oxides of Nitrogen from Small Indust rial, Institutional, and Commercial Boilers, Steam Gener ators, and Process Heaters)

The District evaluated the require ments contained within SCAQMD ’s Rule 1146.1 and found no requirements that were more stringent than those alrea dy in Rule 4307.

BAAQMD

 Regulation 9 Rule 7 (Nitrogen Ox ides and Carbon Monoxide from Industrial, Institutional, and Commercial Bo ilers, Steam Generators, and Pr ocess Heaters)

The District evaluated the requi rements contained within BAAQMD ’s Regulation 9 Rule 7 and found no requirements that w ere more stringent than those already in Rule 4307.

 Regulation 9 Rule 10 (Nitrogen Oxides and Carbon Monoxide from Boilers, Steam Generators and Proce ss Heaters in Petro leum Refineries)

The District evaluated the requi rements contained within BAAQMD ’s Regulation 9 Rule 10 and found no requirements tha t were more stringent than thos e already in Rule 4307.

SMAQMD

 Rule 411 (NOx from Boilers, P rocess Heaters and Steam Generato rs)

The District evaluated the require ments contained within SMAQMD ’s Rule 411 and found no requirements that were more stringent than those alrea dy in Rule 4307.

VCAPCD

 Rule 74.15.1 (Boilers, Steam Gener ators, and Process Heaters)

The District evaluated the require ments contained within VCAPCD ’s Rule 74.15.1 and found no requirements that were more stringent than those alrea dy in Rule 4307.

Additional Emission Reduc tion Opportunities The District has adopted numerous rule amendments over the year s for boilers that have significantly reduced emissi ons 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. Th e NOx limits implemented through Rule 4307 and its amendments will reduce em issions from over 1,000 small (2-5 MMBtu/hr) boile rs in the Valley when fully imp lemented, including from units that were previously exemp t. As a result of these regula tory efforts, the emissions inventory for NOx from these bo ilers has dropped from 3.81 tpd in 2005 to 0.41 tpd inSan Joaquin Valley Unified Air Polluti on 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 reducti ons are forthcoming with exi sting Rule 4307 as additional compliance dates are approaching in 2016. Given the significant efforts and investments already made to reduc e emissions from this source c ategory, there are little remaining opportunities for obtai ning additional emissions redu ctions.

EMx as Potential Control The District researched post-combustion controls such as EMx, t he second generation of the SCONOx technology that r educes NOx, SOx, CO, and volatil e organic compound (VOC) emissions. This technolog y has not been achieved in prac tice (AIP) in the District and there is no availabl e data that indicates that SCO NOx or EMx has been installed on boilers, particula rly in this size range, even tho ugh the manufacturer’s website states that the technology is transferrable to industri al boilers. Based on research of the best available controls from EPA and other air districts, the SCONOx and EMx systems have onl y been utilized by power plants for the control of turbine emissions. In fact, cost effectiveness analyses conducted by t he District for the installation of SCONOx/EMx units on large power plant turbine i nstallations within the Valley have shown that this te chnology is not cost effective. Given the high cost effectiveness demonstrated for tu rbines and lack of demonstrate d practice with boilers, this technology is not feasible o r cost effective for reducing emissions from this category.

PM2.5 Limits for Alternative Fuels The majority of boilers (2-5 MM Btu/hr) in the Valley combust PU C-quality natural gas; PUC natural gas contains a ver y low sulfur content and inherent ly has low emissions. Few boilers in the Valley use alt ernative fuels for their combu stion processes. Alternative fuels include digester gas, produced gas, and liqui d fuel. Units fired on digester gas or produced gas are a lready required to use inlet gas scrubbers to meet District rule requirements. Cu rrent rule language requires tha t on and after July 1, 2015 liquid fuel shall be used only during a PUC qual ity natural gas curtailment period provided it contains no more t han 15 ppm sulfur. While the cur rently limited use of liquid fuel will become even mo re 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 comprehensiv e control measure evaluation

. There are 24 liquid fuel fired uni ts in the Valley (2-5 MMBtu/h r) with an average combined emissions inventory of approximately 0.00077 tons per year of total PM. The low emissions inventory is att ributed to the fact that these un its either utilize liquid fuel as a backup if there is a natur al gas curtailment or are minima lly operated units. The following three technologies wer e evaluated as potential contro l options for reducing PM emissions: baghouses, electrostatic precipitators (ESPs), and w et 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 emissi ons by approximately 50%. 27 However, baghouses are

27 Northeast States for Coordinat ed Air Use Management. (Novembe r 2008) Applicability and Feas ibility of NOx, SO2, and PM Emissions Control Technologies for Indus trial, Commercial, and Inst itutional (ICI) Boilers. Retrieved fromSan Joaquin Valley Unified Air Polluti on 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 potenti al clogging of the baghouse and are therefore not a recommen ded technology due to infeasibi lity and safety issues. 28

PM Potential Emissions Reduc tions for an ESP and Scrubber

For the purposes of these calcul ations, the following assumptio ns were made:

1. For simplicity, the analysis will evaluate the cost effectiv eness of these technologies for total PM reduc tions from liquid fuel fired uni ts. 2. The PM control effici ency of an ESP is 99%. 3. The PM control efficien cy 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 insta llation of an ESP for a 1-5 MMBtu /hr boiler ranges from $90,000 - $100,000 and t he annual maintenance cost is $1,000-$2 ,000. 29 For the wet scrubber system, EPA estimated t he annualized cost at $5,300-$1 02,000 per sm 3 /sec at an average air flow rate of 0.7- 47 sm 3 /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 th e range above ($95,000). 2. The annual maintenance cost of an ESP is assumed to be the m edian of the range above ($1,500).

http://www.google.com/u rl?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=7nfvVIivFai1sAT 07IHIAg&usg=AFQjCNFBdQn7MVAibSTZ IbHV7- ojXkVlXQ&bvm=bv.86956481,d.cWc

. 28 Northeast States for Coordinat ed Air Use Management. (Novembe r 2008) Applicability and Feas ibility of NOx, SO2, and PM Emissions Control Technologies for Indus trial, Commercial, and Inst itutional (ICI) Boilers. Retrieved from http://www.google.com/u rl?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=7nfvVIivFai1sAT 07IHIAg&usg=AFQjCNFBdQn7MVAibSTZ IbHV7- ojXkVlXQ&bvm=bv.86956481,d.cWc

. 29 Catherine Roberts. (March 2009) Information on Air Pollution Control Technology for Woody Biomass Boilers. Environmental Protection Agen cy Office of Air Quality Planning and Standards and Northeas t 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/ttnca tc1/dir1/fsprytwr.pdf

.San Joaquin Valley Unified Air Polluti on 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 b e the median of the range above ($53,650 per sm 3 /sec). 4. The average air flow rate fo r a wet scrubber system is assum ed to be the median of the range above (23.85 sm 3 /sec). 5. The total capital and maint enance cost of an ESP will be cal culated by multiplying the cost of 1 uni t by the total number of units. 6. The total annualized cost of a wet scrubber will be calculat ed by multiplying the annualized cost of 1 unit by t he total number of units. 7. Lifetime of the ESP is 10 years at 10% i nterest. To account for this, the annualized capital cost will be calc ulated by multiplying the t otal capital cost by the capital recovery factor o f 0.1627 and adding the annual mai ntenance 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/ sm 3 /sec) x (24) x (23.85 sm 3 /sec) Annual Cost (scrubber) = $30,709,260/ year

Cost Effectiveness of a n ESP and Wet Scrubber

Cost Effectiveness = Annual C ost / 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 e ffective option for this source category. The cost of the ESP technology does not inclu de costs of retrofitting equipment and/or the facility or compliance monitoring costs, w hich would drive the cost effectiveness up even more.

Evaluation Findings Even though boilers, steam generat ors, and process heaters 2.0 to 5.0 MMBtu/hr are not a significant source of PM2.5 , NOx, or SOx in the Valley, t he District has evaluated all potential control technologie s and all control technologies achieved in practice in other areas or included in other state implementation plans. A s demonstrated above, Rule 4307 currently has in plac e the most stringent measures fe asible to implement in the Valley and therefor e meets or exceeds b oth BACM and MSM req uirements for this source category. As the District continues to develop new atta inment plans that address more stringent National A mbient Air Quality Standards, the District will continue to evaluate potential opportuniti es to reduce emissions from th is source category in the Valley.San Joaquin Valley Unified Air Polluti on 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 GE NERATORS AND PROCESS HEATERS– 0.075 MMBTU/HR TO LESS THAN 2.0 MMBTU/HR

Discussion This rule applies to any pers on who supplies, sells, offers for sale, installs, or solicits the installation of any boiler, st eam 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 r ule is to limit NOx and carbon monoxide (CO) emissions from units within this source category. As a point o f sale rule, Rule 4308 achieves emissions reductions as units subject to the rule are replaced over time. This rule has resulted in more t han 93% control of emissions from th is source category.

Rule 4308 was adopted on Octobe r 20, 2005 to establish NOx emis sions limits for these units which were previously exe mpt from District regulations be cause of their small size. The rule was amended in December 2009 to lower the NOx emission s limits to 20 ppmv for units fired on natural gas, wit h the exception of instantan eous water heaters and pool heaters greater t han or equal to 0.075 MM Btu/hr but less t han or equal to 0.4 MMBtu/hr. In 2013, the District determined that a 20 ppmv limi t was now technologically feasible and co st effective for instantaneous w ater heaters 0.075 MMBtu/hr to 0.4 MMBtu/hr; as su ch, that emission limit was lowe red during the November 2013 amendment of Rul e 4308. EPA publis hed a direct f inal approval the 2013 amendments to Rule 43 08 on February 12, 2015.

Source Category Units subject to Rule 4308 are us ed in settings including, but not limited to, apartment buildings, large homes, small businesses, commercial buildings, manufacturing facilities, government facilities , restaurants, hotels, hospita ls, educational institutions, and religious organizations. Affec ted persons include water he ater manufacturers, plumbing wholesalers, supply stor es, plumbers, contractors, and end-users. This pointof-sale approach allo ws the District to achieve NOx emission re ductions without forcing immediate replacement of existin g units to comply with rule req uirements and thus placing an undo financial bur den 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 0.10San Joaquin Valley Unified Air Polluti on 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from t hese units are lower than the BACM/MSM significance thresholds. Therefore, the Clean Air Act does not require a co ntrol measure evaluation for this source category for t he purpose of satisfying BACM/MSM requirements; however, the District has still co nducted a full control measur e evaluation for boilers, steam generators, and process heat ers 0.075 to 2.0 MMBtu/hr.

How does District Rule 4308 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, N SPS, NESHAP, or MACT requirements for bo ilers, steam generators, and process heat ers of this size.

ACT

 EPA – 453/R-93-034 (Alter native Control Techniques Document—NO x Emissions from Process Heaters)

The District evaluated the requi rements contained within the AC T for NOx Emissions from Process Heaters and found no requirements that were more s tringent than those already in Rule 4308.

 EPA – 453/R-94-022 (Alter native Control Techniques Document—NO x Emissions from Industrial/Commercial / Institutional Boilers)

The District evaluated the requi rements contained within the AC T for NOx Emissions from Industrial/Commercial/Instit utional Boilers and found no r equirements that were more stringent than those already in Rule 4308.

 EPA – 453/R-94-023 (Alter native Control Techniques Document—NO x Emissions from Utility Boilers)

The District evaluated the requi rements contained within the AC T for NOx Emissions from Utility Boilers and found no requirements that were more s tringent than those already in Rule 4308.

State Regulations There are no state re gulations that apply to this source catego ry.

How does District Rule 4308 compar e to rules in o ther air distr icts?

SCAQMD

 Rule 1146.2 (Emissions of Oxides of Nitrogen From Large Water Heaters and Small Boilers and Process Heaters)San Joaquin Valley Unified Air Polluti on 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 require ments contained within SCAQMD ’s Rule 1146.2 and found no requirements that were more stringent than those alrea dy in Rule 4308.

BAAQMD

 Regulation 9 Rule 6 (Nitrogen Ox ides Emissions from Natural Ga s-Fired Boilers and Water Heaters)

The District evaluated the requi rements contained within BAAQMD ’s Regulation 9 Rule 6 and found no requirements that w ere more stringent than those already in Rule 4308.

 Regulation 9 Rule 7 (Nitrogen Ox ides and Carbon Monoxide from Industrial, Institutional, and Commercial Bo ilers, Steam Generators, and Pr ocess Heaters)

The District evaluated the requi rements contained within BAAQMD ’s Regulation 9 Rule 7 and found no requirements that w ere more stringent than those already in Rule 4308.

SMAQMD

 Rule 411 (NOx from Boilers, P rocess Heaters and Steam Generato rs)

The District evaluated the require ments contained within SMAQMD ’s Rule 411 and found no requirements that were more stringent than those alrea dy in Rule 4308.

 Rule 414 (Water Heaters, Boile rs and Process Heaters Rated Les s Than 1,000,000 Btu Per Hour)

The District evaluated the require ments contained within SMAQMD ’s Rule 414 and found no requirements that were more stringent than those alrea dy 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 implem ent 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 uni ts 0.075-1.0 MMBtu/hr (with the exception of pool heaters 0.075-0.4 MMBt u/hr) are currently subject to a 20 ppmv NOx emission limit. As such, ther e are no requirements in VCAP CD Rule 74.11.1 that are more stringent than thos e already in Rule 4308.

 Rule 74.15.1 (Boilers, Steam G enerators, and Process Heaters)

VCAPCD Rule 74.15.1 was also a mended on September 11, 2012. Th e amendments incorporated a 20 ppmv NOx emi ssion limit for natural gas fired units 1-2 MMBtu/hr and other administrative recordkeepi ng requirements. Rule 4308 con tains 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 VC APCD Rule 74.15.1 tha t are more stringentSan Joaquin Valley Unified Air Polluti on 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 Wa ter Heaters, Small Boilers and P rocess 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 PC APCD Rule 247 that are more stri ngent than those already in Rule 4308.

Additional Emission Reduc tion Opportunities

Mobile Home Exemption The District evaluated the possib ility of removing the exemptio n for water heaters used in mobile homes because multiple air districts do not exempt th ese sources in their analogous rules. However, because those air districts have dif ferent rule structures with regards to the size of devices r egulated, District Rule 4308 re quirements are as stringent as the other districts’ rules.

For example, SCAQMD Rule 1146.2 does not regulate mobile home w ater heaters, per the definition for type 1 units , because they are subject to Ru le 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 ou t 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 t han 0.075 MMBtu/hr. District Rul e 4902 (Residential Water Heaters) applies to units less than 0.075 MMBtu/hr and currentl y regulates mobile home water heaters with the same emi ssion 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 t he size of mobile home water he aters, it was found that mobile home water heaters are not available in the 0.075-2.0 MM Btu/hr size range. Four mobile home retailers and th ree 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 wa ter heater is 30-40 gallons, wh ereas 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 b ut rarely used. If the exemption for mobile home wate r heaters in Rule 4308 were to be removed, it would not result in any additional emi ssions reductions since units d o not exist in this size
range.

Recreational Vehicle Exemption The District evaluated the potent ial opportunity to remove the exemption for recreational vehicles (RVs). Stakeholder inpu t indicates that there are ver y few units in RVs that fall under the size category subject to this rule. Most units in RV s are 12 gallons, which isSan Joaquin Valley Unified Air Polluti on 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 0.07 5 MMBtu/hr unit. 31 Also, RV units are typically not used on a frequent basis and thus are s mall contributors to the NOx emissions of this source category. Other air districts, suc h as SCAQMD and BAAQMD, include this exemption in their rules. Removing this e xemption would result in little to no emissions reduc tions because of the lack of uni ts within this size range and the intermittent use of units in RVs.

Evaluation Findings Even though boilers, steam generat ors, and process heaters 0.07 5 to 2.0 MMBtu/hr are not a significant source of PM2.5 , NOx, or SOx in the Valley, t he District has evaluated all potential control technologie s and all control technologies achieved in practice in other areas or included in other state implementation plans. A s demonstrated above, Rule 4308 currently has in plac e the most stringent measures fe asible to implement in the Valley and therefor e meets or exceeds b oth BACM and MSM req uirements for this source category. As the District continues to develop new atta inment plans that address more stringent National A mbient Air Quality Standards, the District will continue to evaluate potential opportuniti es to reduce emissions from th is source category in the Valley.

31 SJVAPCD. (2009). Final Staff Report for Amendments to Rule 43 08 (Boilers, Steam Generators, and Process Heaters—0.075 MMBtu/hr to less than 2.0 MMBtu/hr)

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

C-54 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.10 RULE 4309 DRYERS, DEHYDRATORS, AND OVENS

Discussion Rule 4309 is applicable to any d ryer, dehydrator, or oven that is fired on gaseous fuel, liquid fuel, or is fired on gas eous and liquid fuel sequentiall y, and the total rated heat input for the unit is 5.0 million British thermal units per hou r (5.0 MMBtu/hr) or greater. The purpose of this rule is to limit NOx and carbon monoxide (C O) emissions from these units, which result from the combustion of fuel in the bu rners. The rule enforces NOx emission limits bet ween 3.5-12 ppmv for four categories of equipment, achieving approximately 34% control of total NOx emissions.

Rule 4309 was adopted on Decem ber 15, 2005 and ha s not been ame nded. 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 f our broad industry groups: dehydrators; asphalt/concrete; milk, cheese, and other dairy pr ocessing; and other. Dryers, dehydrators, and ovens c urrently operate either seasona lly or year-round depending on the industry and the unit’s purpose within the pro cess. There are 126 units subject to this rule, ranging in size from 5.0 MMBtu/hr t o 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from dry ers, dehydrators, and ovens are lower than the BACM/MSM significance threshol ds. Therefore, the Clean Air Act does not require a control measure evaluation for this source category for the pur pose of satisfying BACM/MSM requirements; however , the District has still conducte d a full control measure evaluation for dryers, dehydrators, and ovens.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-55 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard How does District Rule 4309 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, N SPS, NESHAP, or MACT requirements for th is source category.

Alternative Control Techniques (ACT)

 EPA – 453/R-94-004 (Alter native Control Tec hniques Document–NO x Emissions from Cement Manufacturing)

The District evaluated the requi rements contained within the AC T for NOx Emissions from Cement Manufacturing and found no requirements that were m ore stringent than those already in Rule 4309.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 4309 compar e to rules in o ther air distr icts? There are no analogous rules fo r this source category in BAAQMD , SMAQMD, or VCAPCD.

SCAQMD

 SCAQMD Rule 1147 (NOx Reducti ons from Miscellaneous Sources)

The District evaluated the require ments contained within SCAQMD ’s Rule 1147 and found no requirements that were more stringent than those alrea dy in Rule 4309.

Additional Emission Reduc tion Opportunities The adoption of Rule 4309 has cons iderably reduced NOx and PM e missions 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. Althoug h this source category had a relatively small emissions inventory prior to the adoptio n of Rule 4309, stakeholders have installed c ontrol equipment and modified thei r operations considerably to reduce emissions to ultra-low levels. Given th e significant effort already made to reduce emissions from thi s source category, there are l ittle remaining opportunities for obtaining addit ional emissions reductions.

Asphalt Plants PUC-quality natural gas fuel is part of the BACT requirements f or 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 facili ties are physically too far removed from natural gas lines to use natural gas. Six of the se asphalt plants use LPG fuel or propane to comply with t he same gaseous fuel fired limi t as PUC-quality natural gas-fired facilities. The other th ree facilities utilize diese l gas; however, none of the facilities operate full time and their combined NOx emissions a re less than 7 tons perSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-56 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard year. Therefore, requiring natur al gas for all asphalt facilit ies is not a feasible opportunity that would generate si gnificant emission reduction benefits.

The District evaluated the potent ial opportunity to lower the N Ox emissions limits for asphalt plants from the current limits of 4.3 ppmv (gaseous fu el) and 12 ppmv (liquid fuel) to make them closer or equivalent to the BAAQMD BACT limi t of 3.9 ppmv @ 19% O2. To meet this limit, operat ors would need to install low-NO x burners or modify existing burners to comply with lower limits; however, all of t he asphalt plants have already installed new low-NOx bur ners or modified their units t o meet the 4.3 ppmv @ 19% O2 and 12 ppmv @ 19% O2 emissi ons limits in Rule 4309.

Based on District permit recor ds, 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 w ould reduce the margin of compl iance the facility has, and would make it more difficul t for the facility to show conti nued 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 con trol equipment or changes in operating techniques or prac tices to comply, and it would no t generate additional emissions reductions from these units.

A higher NOx limit is required fo r the liquid fuel fired facili ties due to the characteristics of liquid fuels. In BAAQMD’s BACT guideline for hot mix aspha lt 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 pp mvd 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 petr oleum gas and 17.73 ppmv @ 19% O2 for fuel oil. The District’s Permits departmen t enforces a limit of 4.3 ppmv @ 19% O2 for liquefied petroleum gas and 12 ppmv for ot her liquid fuels. Therefore, t he District’s requirements are more stringent than both limit s in the BAAQMD BACT guidelin e.

Dehydrators Rule 4309 requires de hydrators be fired on PUC-quality natural gas. The District evaluated the potentia l opportunity to furt her reduce emissions by requiring the use of low-NOx burners; however, this option is infeas ible due to the potential negative effects on product quality. Additionally, e nforcing the emissions limi ts is potentially infeasible because monitoring and source tes ting of dehydrators is difficu lt to perform, if not impossible.

Dryers The District considered the pot ential opportunity to add a requ irement for the use of dust collection devices, such as baghouses. Through the District’s New Source Review Rule (Rule 2201), dust colle ction devices are already in place in th e permit requirements for units that create PM emissions fr om handling the products they are drying. These facilities install baghouses or cyclones because they do not wa nt to blow their productSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-57 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard out of their stack. While baghous es can foster PM2.5 reduction s, cyclones are generally not as effective in rem oving fine particulate matter. 32

The District researched the potent ial installation of baghouses on dryers. However, it is technologically infeasible to i nstall a baghouse for some of th e dryers subject to Rule 4309. The purpose of a dryer is to remove moisture from a prod uct, which means that the exhaust from dryers have a high humidity. Baghouses can ha ve problems with high humidity exhaust streams because the bags become caked. The ai r stream would have to be dried somehow before ent ering the baghouse. As a result, this is not a feasible opportunity at this time.

The District also evaluated the possibility of removing the exe mption for column dryers and dryers with no stack and one or more sides open to the atmo sphere. However, compliance with the proposed limi ts would be difficult to deter mine reliably given the design of these units. Column drye rs have large fans to move t he warm air through the material and air escapes thr ough screens that cover the side of the dryer. Similarly, dryers with no stack and at leas t one side open deal with air e scape, which makes monitoring and testing emissions d ifficult, if not impossible. Since source testing of these types of dryers is difficu lt due to the fact that there i s not a stack where all emissions are exhausted, this i s not a technologically feasible opportunity at this time.

Evaluation Findings Even though dryers, dehydrators, and ovens are not a significan t source of PM2.5, NOx, or SOx in the Valley, the District has evaluated all poten tial control technologies and all control technologies achie ved in practice in other area s or included in other state implementation plans. As demons trated above, Rule 4309 current ly has in place the most stringent measures feasible to implement in the Valley and therefore meets or exceeds both BACM and MSM require ments for this source category . As the District continues to develop new attainm ent plans that address more str ingent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emissions from dryers, dehydrators, and ovens in the Valley.

32 Northeast States for Coordinat ed Air Use Management. (Novembe r 2008) Applicability and Feas ibility of NOx, SO2, and PM Emissions Control Technologies for Indus trial, Commercial, and Inst itutional (ICI) Boilers. Retrieved from http://www.google.com/u rl?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=7nfvVIivFai1sAT 07IHIAg&usg=AFQjCNFBdQn7MVAibSTZ IbHV7- ojXkVlXQ&bvm=bv.86956481,d.cWc

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

C-58 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.11 RULE 4311 FLARES

The purpose of Rule 4311 is to limit volatile organic compounds (VOC), NOx, and SOx emissions from any operation invo lving the use of flares, with the exception of a limited list of sources identified in t he rule. Any unreasonable restr ictions on flaring could potentially result in catastr ophic consequences which may lead to explosions resulting in loss of property, injury, and potentially loss of human life

.
Flaring is a high temperature ox idation process used to burn co mbustible components, primarily hydrocarbons, of wast e gases from industrial operatio ns, primarily for the purpose of controlling emissions and as a safety device. The m ajority of waste gases flared are natural gas, propane, e thylene, propylene, butadiene and butane. During combustion, gaseous hydrocarbons react with atmospheric oxygen to form carbon dioxide (CO 2 ) and water. In some waste gases , carbon monoxid e (CO) is the major combustible component. In additi on to serving as safety device s, the combustion of industrial gas streams in flares is also recognized as a means of reducing greenhouse gases (GHG), in line with Cali fornia’s AB32 GHG reduction goals and emerging federal GHG reduction goals.

Combustion efficiency depends on fl ame temperature, residence t ime in the combustion zone, vent gas flammability, auto ignition temperature, heating value, and turbulent mixing. When operated at an optimal combination of these facto rs, flares have a destruction efficiency of 98 perc ent or greater. Complete comb ustion converts all VOCs to CO 2 and water; however incomplete combustion generates air polluta nts such as NOx, sulfur dioxide, carbon monox ide, and particulate matter. Additionally, there is a possibility of release of hydro carbons if they have not been co mpletely combusted. To prevent the creation of smoke o r soot, which is influenced by f uel characteristics and the amount and distribution of oxyge n in the combustion zone, most industrial flares are steam-assisted or air-assisted. I n some cases, another fuel mu st be added to flare gas to achieve the minimum heat ing value of 200-250 Btu/ft 3 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 o f 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 unf oreseeable and unpreventable emergency situati ons/standby situations and less commonly as a primary emissions control device for VOC emissions. As safety devices, flares are necessary to prevent catastrophic consequences s uch as the release of toxic gases and explosions, which could result in loss of p roperty, injury, and loss of hum an life. In the Valley, the vast majority of flares are em ployed as emergency/standby contr ol 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 producti on. Also, while regions like North Dakota utilize flar es to combust associated gas duri ng the initial extractionSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-59 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard phase of the production process (i .e., directly from the well), Valley flares are typically used further down the process chai n, primarily as a safety devi ce associated with gas collection systems, res ulting in far lower quantities of flared gas.

Valley operators have generally eva luated all feasible and cost effective options for handling and disposin g of the associated/waste gases generated by their facilities and installing a flare as the primar y method of disposal would be t he last resort. In addition to Rule 4311 requirements to eva luate and implement all feasibl e measures to reduce flaring activities, other associ ated rules also implement strin gent capture and control of these gases. Therefore, most fa cilities have made significant investments to capture and utilize these process gases i n a variety of methods and thi s ability has allowed facilities to maximize income generation. Some capture and tre at these gases and sell them to natural gas/utility pro viders (generates monetary incom e), while others utilize these gases on-site to fuel equi pment that generates electricit y and/or provides process heating (saves fuel costs). In fa ct, most Valley facilities re gard flaring events as a significant monetary cost, through directly lost profit or incr eased fuel costs.

In the District’s evaluation o f Valley flaring activity, 33 nearly all of the flaring events were either one-time events due to new control equipment installatio n or maintenance of existing equipment, and therefor e not repeated, or in response to emergency situations or process upsets. For example , one Valley facility (light oil production facility) experienced abnormally high flar ing because the sales transmiss ion pipeline was offline for repairs, an event beyond their control. Another facility ( wastewater treatment plant) normally uses the fuel onsite to produce electricity and proces s heating, but could not do so because additional air pol lution control devices were bei ng installed.

Flares in the Valley subject to the requirements in Rule 4311 a re employed by a diverse group of industries for a wide va riety of applications, as illu strated by the below list. In contrast, other air districts’ flare rules generally limit the applicability of their rules to petroleum production fac ilities 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_Q uality_Plans/docs/R4311.pdf

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

C-60 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 0.16 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 si gnificance threshold for source categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts is 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from fl ares are lower than the BACM/ MSM significance thresholds. Therefore, the Clean Air Act does not require a co ntrol measure evaluation for this source category for t he purpose of satisfying BACM/MSM requirements; however, the District has still co nducted a full control measur e evaluation for Rule 4311.

Valley Flaring Activity Compared to Other Regions Flares in the Valley and other a ir districts are primarily engi neered for emergency operation during process upsets and emergency situations. Give n this use, any unreasonable restrictions on flar ing could potentially result i n catastrophic consequences which may lead to exp losions resulting in loss of property, injury and potentially loss of human life . While flares can be used durin g maintenance, new equipment installations, and star tup/shut-down, the main concer n is safety. In this regard, Valley flares are simila r 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 o il and gas refineries , with significantly higher throughputs than those in the Vall ey. Temperatures and pressur es 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 fla re header, where it is distributed to multiple large fl ares. The flares at these faci lities are much larger in physical size, as well as capacit y, as shown in the table below

. Table C-2 Comparison of Flaring Capacity for Flares in Califor nia 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 18,200San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-61 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Flaring capacities of the flares in the SCAQMD, BAAQMD, and SBC APCD are all significantly higher than the flar ing capacities of flares in t he Valley, while those in VCAPCD are similar size to Valley flares. Flares in BAAQMD hav e a wide range of capacities, while those in SCAQMD are all greater than 1,000 MM Btu/hr. The figure below shows the average capacity of flares in the District, SCA QMD, BAAQMD, VCAPCD, and SBCAPCD.

Figure C-4 Average Flare Capaci ties in California Air District s

With roughly ten times the number o f flares, the Valley has tot al 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 table s below is compiled from all flaring activities in each air district’s jurisdiction and is provided in the ARBmaintained 2012 CEPAM: NORCAL 201 2 PM2.5 SIP Baseline Emission Projection Tool. 0 2000 4000 6000 8000 10000 12000 14000 16000

District SBCAPCD VCAPCD SCAQMD BAAQMDMeanCapacity(MMBtu/hr)San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-62 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Table C-3 NOx Emissions Inventori es for Flares in California A ir 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 Inventori es for Flares in California A ir 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 Inventori es for Flares in California A ir 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 f lare 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 compar ing North Dakota Century Code 38-08-06.4 to Distr ict Rule 4311, the District exa mined flaring in North Dakota. Research indicates that N orth Dakota has become the se cond largest producer of oil in the United St ates, behind Texas. The recent boom in oil production has led to far greater producti on, without the infrastructure a nd regulation to support emissions control. Oil production facilities in North Dakota h ave focused on expanding oil production by opening new w ells, and as a consequence have not invested in the installation of onsite cogenerat ion equipment or sales transmis sion pipelines. The resultSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-63 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard has been the flaring off of approx imately 29% of all natural ga s produced in North Dakota 34 , compared to approximately 3.8% i n the Valley (as shown in the table below).

Rule 4311 Regulatory Background

Rule 4311 was adopted in June 2002 to establish flaring require ments and reduce emissions from flares. Amendment s were adopted on June 15, 200 6 and June 18, 2009. The September 2009 amendment i ncorporated requirements f or flare minimization plans and increased the stringency of existing req uirements for sulfur emissions. EPA finalized approv al of the 2009 amendments to Ru le 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 so lid waste landfills subject to t he requirements of Rule 4642, flares subject to the requi rements of 40 CFR 60 Subpart W WW (Standards of Performance for Municipal Waste Landfills) or Subpart Cc (Emiss ion Guidelines and Compliance Times for Municipal S olid Waste Landfills), and exce pt for recordkeeping requirements, any stationary sour ce that does not have the pote ntial to emit at least ten tons per year of VOC and NOx (non-major sources).

Of the 235 flares operating in t he Valley, 126 are exempt from Rule 4311 requirements other than basic recordkeeping d ue to one of the following reas ons:

 The flare is not part of a major source - 60 flares

 The flare is subject to other r ules regulating landfills – 27 flares

 The flare is not stationary (i .e. transportable units) – 39 fl ares

Of the flares exempt from Rule 4311 requirements (other than re cord keeping), over 90% flaring activity is associ ated with landfills that utilize flares as part of their federally mandated gas collection systems. T hese flares are already requ ired to meet strict local and federal requirements through 40 CFR 60 Subpart WWW (Standar ds of Performance for Municipal Sol id Waste Landfills), or Subpart Cc (Emission Guidelines and Compliance Times for Munici pal Solid Waste Landfills) and D istrict Rule 4642 (Solid Waste Disposal Sites). Rule 4642 applies to any solid w aste disposal sites which have a gas collection system and/ or control device in operation or undergoing maintenance or repair. Ma jor 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 f rom http://www.gpo.gov/fdsys/pkg/FR-2012-01- 10/pdf/2012-139.pdfSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-64 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard  For gas collection system: oper ate so that TOC concentrations do not exceed 1000 ppmv at any point on the su rface of the solid waste dispos al site or along the gas transfer path of the gas collection system; install sam pling ports on each well head; operate in a manner whi ch maximizes the amount of la ndfill gas extracted while preventing over draw that can cause fires or dam age the gas collection system; control by a c ontrol device that meet the co ntrol device requirements.

 For a control device: achieve a VOC destruction efficiency of at least 98% by weight, or reduce the VOC concen tration 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 leas t 90% by weight or reduce the VOC concentration to 20 ppmv; operate enclosed flar es in accordance with 40 CFR 6 0.756(b) and 40 CFR 60.18 and open flares in a ccordance with 40 CFR 60.756(c ) and 40 CFR 60.18.

 During maintenance, notify t he APCO 24 hours in advance, minim ize the emissions during shutdown, and pr event shut down for more than 144 cumulative hours in any calendar year.

 Other requirements not applicable to flares.

In addition to Rule 4311 requirem ents, any new flares are subje ct to New Source Review (NSR) requirements (Dis trict Rule 2201) including Best A vailable Control Technology (BACT) requirements , meaning they may be required to implement even more stringent controls regardle ss of whether they are subject to Rule 4311. All sources must obtain an ATC permi t before they are operated.

Rule 4311 includes the following major requirements (described in more detail in the following sections):

 Operation requirements that ensur e the flare is achieving maxi mum destruction efficiency

 Operation of measurement and m onitoring devices to ensure all requirements are being met

 VOC and NOx emission limits fo r ground-level enclosed flares

 Flare minimization plans

 Petroleum refinery SO 2 performance targets

 Extensive recordkeeping require ments including annual monitori ng reports and reportable flaring event reports

Operation Requirements General requirements for flare operation include:

 Maintain a flame at all times when combustible gases are vente d through the flare

 Equip the outlet with an automatic ignition system, or operate with a pilot flame present at all times when comb ustible gases are vented through the flare, except during purge periods for automat ic-ignition equipment flares

 Except for flares equipped with a flow-sensing ignition system , install and operate a heat sensing device such as a t hermocouple, ultraviolet beam sensor, infraredSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-65 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard sensor, or an alternative equivale nt device, capable of continu ously detecting at least one pilot flame or the flare

 Use purge gas for purging flares that use flow-sensing automat ic 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-l evel enclosed flares to meet the following emission standards for VOC and NOx:

Table C-6 Rule 4311 Em ission 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 Mini mization Plan (FMP) to be submit ted to and approved by the District for any petroleum r efinery with a flare or any fla re with a flaring capacity greater than or equal to 5.0 MMBtu /hr. The rule prohibits faci lities subject to FMP requirements from flaring unless it is consistent with a Distri ct-approved FMP and all commitments in that FMP have been met. FMPs must include all n ecessary information to satisfy the underlying regulat ory requirements, and must be submitted to the District for approval. In addition to their initial submittal, FMPs mus t be modified prior to making any modifications to related equipm ent or processes, and at lea st every five years. FMPs are required to include the following:

 Description and technical spec ifications for each flare and as sociated knock-out pots, surge drums, water seals , and flare gas recovery systems

 Process flow diagrams of upstr eam equipment and process units venting to each flare (with identific ation of type and location of control equi pment)

 Description of equipment, proce sses, or procedures the operato r plans to install or implement to eliminate or min imize flaring , and planned date of installation or implementation

 Evaluation of prevention meas ures to reduce flaring that has o ccurred or may be expected to occur during planned major maintenance activities, including startup and shutdownSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-66 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard  Evaluation of preventative m easures to reduce flaring that may be expected to occur due to issues of gas quant ity and quality. This includes an audit of vent gas recovery capacity of each flare system, storage capacity fo r excess vent gas, and scrubbing capacity available for vent gas for use as a fuel ; and shall determine the feasibility of reduc ing flaring through the recov ery, treatment, and use of the gas

 Evaluation of preventative m easures to reduce flaring caused b y the recurrent failure of air pollution cont rol equipment, process equipment, or a process to operate in a normal or usual m anner. Evaluation shall determin e adequacy of existing maintenance schedules and protocols for such equipment . A failure is recurrent if it occurs more than twice during any five year per iod 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 re finery 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 tab le.

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 f acility and operation type, as well as the quality of gas being flared. Similarly, the fea sibility of potential control options is highly dependent on t he same factors. The following table is a sample of measures committed to in FMPs submitted to the District:San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

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 M easures 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 fl are gases to condition for sale

Inject flare gas in DOGGR-approved wells

Use other combustion devices (an d offset the need for other nat ural gas fuel sources) such as glycol re-boiler/thermal oxidizer

Wastewater Treatment/ Reclamation Install new equipment to combust digester gas in internal combu stion engines, fuel cells, and process heaters

Install equipment to allow diges ter gas storage and conditionin g for greater use in turbines (additional storage is minimal and only capable of handling excess gas duri ng minor process upsets)

Wine Production Burn flare gas in steam generati on boilers; coordinate plant operations that generate the flar e gas with production operatio ns requiring steam Cheese Production Modify boiler to combust a nat ural gas/digester gas blend

Flat Glass Manufacturing Reduce idle time during calib ration and purge test to reduce necessary flaring
Dairy Farming Install additional gensets (elect ricity generation equipment lo cated near the end user) to com bust more produced biogas

Many of the above measures are no t feasible for all facilities. For oil and gas production, the flare gas produced is often in excess of what c ould be used onsite to power equipment. For these facilit ies, flares are generally us ed only under abnormal conditions, as the flare gas i s usually high enough quality to sell for use at other facilities.

For facilities other than oil and gas production, the gas produ ced is usually a much lower heating value a nd requires conditioning if combusted for electrical generation or process heating. Expensive modi fications or new equipment is o ften required to allow said combustion activities and t he flare gas is sometimes of to o low quality or quantity to make these installations cos t effective. Additionally, emissio ns from other combustion devices would likely be higher because flares are inherently lo w emitting and serve as combustion control devices.

Of the 95 flares required to subm it 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 t he remaining 3 flares in the Valley are permitted toSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-68 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard be used as primary disposal devices. Two of the three flares a re used at an oil and natural gas production facility as strictly an emissions contro l device for vapors displaced from trucks only durin g load-out operations pursuant to requirements in District Rule 2201 (New and Modifi ed Stationary Source Review R ule). 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 compon ent 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 requi red to minimize SO2 emissions to less than 1.5 tons per million barrels of c rude processing capacity. Sta rting January 1, 2017, operators of petroleum refinerie s will be required to lower thi s target to 0.5 tons SO2 per million barrels of crude processing capacity.

Annual Monitoring Reports Rule 4311 also requires the operat or of any petroleum refinery flare or any flare with a flaring capacity equal to or gr eater than 50 MMBt u/hr to submit an Annual Monitoring Report (AMR) to the Distric t no later than July 31 st of each calendar year, containing the following information:

 Total volumetric flow of vent gas

 Hydrogen sulfide content, met hane content, and hydrocarbon con tent of vent gas

 If vent gas composition is moni tored by a continuous analyzer: average total hydrocarbon content by volume, a verage methane content by volum e, and depending upon the analytical met hod used, total reduced sulfur content by volume or hydrogen sulfide cont ent by volume of vent gas flared for each hour of the month

 If the flow monitor measures m olecular weight, the average mol ecular weight for each hour of each month

 For any pilot and purge gas us ed, the type of gas used, the vo lumetric flow for each day and for each month, and the means used to determine fl ow

 Flare monitoring system downtim e periods, including dates and times

 For each day and each month provide calcul ated sulfur dioxide emissions

 A flow verification r eport for each flare

Of the facilities subject to FMP requirements, 40 are not requi red to submit annual monitoring reports. Some of thes e facilities are too small or do not utilize their flares, but the majority have accepted s pecific limiting conditions on their permits to operate that limit the amount of flaring the facility can conduct to le ss than the threshold for reportable flaring events. The remaining 55 facilities are the refore subject to AMR requirements. Of these 55 flares , only one is used as a primar y 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 compos itions and increased understand ing of flaringSan Joaquin Valley Unified Air Polluti on 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. Thi s information in turn allows the District to calculate the amounts of emissions from reported flaring and compare those va lues to verify the accuracy of the emissions inventory for flares.

Reportable Flaring Events Rule 4311 requires annual reports to be submitted each year sum marizing all reportable flaring events. A flaring even t is considered a reportable fla ring event if more than 500,000 standard cubic feet (scf) of vent gas is flared per cal endar 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, a lthough most flares commonly operate at a small frac tion of maximum capacity. Addi tionally, some low quality waste gases can have hea ting values of 200-300 Btu/scf, which would lower the minimum capacity for reportable flaring events. Reportable fla ring event requirements are applicable to the operator of a flare subject to FMP requir ements with the exception of flares that the operator can ve rify are not capable of produ cing reportable flaring events.

The reports are required to inc lude at least the following:

 The results of an investigation to determine the primary cause and contributing factors of the flaring event

 Any prevention measures consid ered or implemented to prevent r ecurrence together with a justif ication for rejecting any measures that w ere considered but not implemented

 If appropriate, an explanation o f why the flaring was an emerg ency and necessary to prevent accident, haz ard or release of vent gas to the atmosphere, or where, due to a regulatory mandate to vent a flare, it canno t be recovered, treated, and used as a fuel at the facility

 The date, time, and duration of the flaring event

The majority of reportable flar ing events are planned—thereby a llowing for greater preparation and control—for repai r, maintenance, or new equipme nt installations, including new air pollution cont rol devices. Most of the event s are one-time events. Of the gas flared, less than 20% i s salable quality, lending suppo rt to the fact that facilities sell flare gas when feasible.

Of the 109 flares subject to Rul e 4311, 21 flares generated 395 reportable flaring events during the 2011-2012 period. This period is a conservative ref lection of potential reporting flaring event activity in the Valley given the unusua lly high number of events reported by a single facility ( described in more detail below). The table below summarizes these events by facility type.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

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 Re portable 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 th e fact that the majority of f laring events are for equipment installations, m aintenance, and repair.

Figure C-5 Summary of Reasons for Reportable Flaring Events (2 011-2012)

During this period, the larges t percent of all gas flared durin g reportable flaring events was by a single wastewater treat ment plant. According to the D istrict-approved FMP for this facility, digester gas is utilized to create electricity a nd provide heat for the digesters (and offset the combustion of pi peline natural gas). The WWTP uses two 3.4 MW turbine engines and o ne 16.7 MMBtu/hr proce ss boiler that are a lmost completely fueled by digester gas. Because there is no significant gas st orage capacity, any excess digester gas or gas pr oduced during interruptions to the turbines or boiler must be flared to avoid direct emissi ons to the atmosphere or potent ial gas build-up leading to explosions at the plant. To fulfill commitments in the FMP, the facility installed a small digester gas storage tank, i nstalled additional digester gas conditioning, and increased the allowable digeste r 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%San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

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 holdi ng gas for small periods, such as during switchover between turbines, and the gas condi tioning allows the use of se lective catalytic reduction (SCR) on the turbines . The addition of this equipmen t has resulted in a 71% reduction in the volume of gas fl ared by the WWTP; however, dur ing the 2011-2012 reporting period the facility ex perienced abnormally high flari ng activity. During this period, the turbines were out of service to allow installation of SCR control devices for reducing over 90% of NOx emissi ons from the turbines pursuant t o District Rule 4703 (Stationary Gas Turbines) and pe rmitted emission limits. As a result, a large portion of the digester gas was flared. Out of the 395 total reportable f laring events in the Valley during the 2011-2012 reporting peri od, 164 occurred at the WWTP . Those events accounted for 36% of the total volume of gas flared during repo rtable events, more than three times the next highest vol ume at any facility. By contra st, the 2012-2013 reporting period showed only 46 reportable flaring events at this facilit y, all of which were for regular activities except one due to failure of a turbine. Bec ause the majority of flaring events during the 2011-2012 reporti ng period were due to instal lations and are therefore one-time events, they are not par t of normal facility operation s.

The following graph illustrates th e percentages of gas flared f rom all sources during reportable flaring events for the 2011-2012 period.

Figure C-6 Percent of Reportabl e Flaring from All Sources (201 1-2012)

Comparison of Rule 4311 to State , Federal, and Local Regulation s

Comparison of Rule 4311 to Federal Regulations There are no EPA CTG or ACT requi rements for this source catego ry.

The following federal regulations apply to Rule 4311 sources: 0 5 10 15 20 25 30 35 40

ABCDE FGH I J K LMPercentofTotalVolumeFlaredfromReportableFlaringEvents

Facility (Facility 'A' is Fresno/Clovis Regional WWTP)San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

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 V ent Systems, Control Devices, Recov ery Devices and Routing to a Fue l Gas System or a Process)

 NSPS:

o 40 CFR 60.18 (General Control Devi ce and Work Practice Require ments)

o 40 CFR 65.147 (Flares)

o 40 CFR 60 Subpart OOOO (Standards of Performance for Crude Oi l and Natural Gas Production, Transmission and Distribution)

o 40 CFR 60 Subpart Ja (Standards o f Performance for Petroleum Refineries for Which Constructi on, Reconstruction, or Modificat ion Commenced After May 14, 2007)

Rule 4311 is as stringent as or more stringent t han the above N SPS and NESHAP requirements. The most recent ly amended NSPS (40 CFR 60 Subpar t OOOO and 40 CFR 60 Subpart Ja) are discussed below.

40 CFR 60 Subpart OOOO is a new NSPS requirement th at was finalized by EPA on August 16, 2012. This NSPS may i ndirectly affect some Valley f lares since there is a possibility that a flare is exe mpt from the majority of Rule 43 11 and is used as a control device for a vapor controlled tank that is subject to Subpart O OOO.

Affected facilities under this s ubpart that may use flares as a n approved control device include centrifugal compresso rs, storage vessels, and onshore n atural gas processing plants. If the facility chooses to meet the control requiremen ts, then the flare must be designed and operated in accordance with § 60.18(b) and must con duct the compliance determination using Method 22 a t 40 CFR part 60, appendix A-7, to determine visible emissions. §60.18(b) was last a mended on December 22, 2008, wh ich is before the last amendment for District Rul e 4311 (June 18, 2009). The req uirements of the 2008 amendments were closely evaluat ed during the District’s 2009 Ru le amendment. EPA deemed Rule 4311 as being at leas t as stringent as established RACT requirements on January 10, 2012. 37 Since Subpart OOOO has no new requi rements for flares after t he 2012 EPA RACT approval, Rule 4311 continues to be at least as s tringent as these requirements.

40 CFR 60 Subpart Ja was amended by EPA on Sept ember 12, 2012. Amendments clarified existing requirement s and applicability, including wh at constitutes a flare modification, clarification o f secondary flares, and clarificat ion of the records that must be maintained by the operator. EPA also added new requirements to Subpart Ja as part of these amendments, includi ng flare related unit and proc ess descriptions, assessments, and evaluations; anal yses of causes and corrective actions for reportable flaring events; and sulfur limit s 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.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

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 mor e stringent requirements than D istrict Rule 4311. Subpart Ja has one new exemption for continuous monitoring, whi ch allows for fewer requirements than previously req uired in the NSPS, and therefor e, is not more stringent than current rule language. While there may be some minor diff erences in terminology or requirements making direct com parisons not possible, the sam e level of controls and emission reductions are achiev ed through District regulations a s through this NSPS. Additionally, the District’s Pe rmit Services Department continu ously 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 string ent as or more stringent than the applicabl e federal regulations.

Comparison to State Regulations There are no state rules or r egulations that apply to this sour ce category.

Comparison to Regulations in other Air Districts As previously stated, EPA analy sis of Rule 4311 resulted in the 2012 determination that Rule 4311 is as stringent as requi rements in other air district s in California (76 FR 68106); however, in keeping with t he methodology of this plan, the District conducted a thorough examination of rules in other air districts, including the following:

 SCAQMD Rule 1118 (Control of E missions from Refinery Flares)

 BAAQMD:

o Regulation 12 Rule 11 (Flare Moni toring at Petroleum Refinerie s)

o Regulation 12 Rule 12 (Flares at Petroleum Refineries)

 SMAQMD and VCAPCD do not have an analogous rule for this sourc e category.

The District also conducted an exhaustive search for rules in a ll other air districts, including those outside of Ca lifornia, to identify any that mig ht contain more stringent requirements. While Rule 4311 is as stringent as or more strin gent than any rules in the nation, the District prepared com parisons to Santa Barbara Coun ty Air Pollution Control District (SBCAPCD) Rul e 359 and North Dako ta Century Code 38-08 -06.4. The North Dakota rule is not included in t he comparison table below becau se it does not contain most of the core requirements of California air district flare regulations. The following table compares major e lements 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, 1994San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

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

A PPLICABILITY

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 (SO 2 ) 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 sulfurSan Joaquin Valley Unified Air Polluti on 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 showsmethane/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 flaringdue 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 volumeSan Joaquin Valley Unified Air Polluti on 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 forflares, 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 compositionsSan Joaquin Valley Unified Air Polluti on 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 H 2 S

 If composition

monitored w/ continuous analyzer, avg. content by volume of: total HC; methane; total reduced sulfur; H 2 S

 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 flaringSan Joaquin Valley Unified Air Polluti on 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

 SO 2 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 SO 2 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 andSan Joaquin Valley Unified Air Polluti on 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 SO 2 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 str ingent than analogous rules in other Califor nia air districts.

SBCAPCD Rule 359 (Flares and Thermal Oxidizers) 38 SBCAPCD Rule 359 was adopted on June 28, 1994. Provisions of t his rule apply to the use of flares and thermal oxid izers at oil and gas production s ources, petroleum refinery and related sources, and natural gas services. Rule 359 sets s pecific requirements for the sulfur content in gaseous f uels, technology based standards , flare minimization plans, emergency events, and emi ssion and operational limits.

38 Santa Barbara County Air Poll ution Control District. (1994, Ju ne 28). Rule 359 Flares and Thermal Oxidizers. Retrieved February 13, 2015 from http://www.ourair.org/wp-cont ent/uploads/rule359.pdf

.San Joaquin Valley Unified Air Polluti on 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 sour ce subject to this rule that operates a flare rated a t 15 MMBtu/hour or greater. For p lanned flaring, the FMP for all sources subject to thi s rule shall list a targeted maxi mum monthly flared gas volume, which shall not exceed 5% of the average monthly gas handled/produced/treated at the sour ce unless the operator demo nstrates such a maximum volume to be infeasib le based on safety, engineering or cost constraints and proposes a different percentage . Any flaring that causes an ex ceedance of the emission limits or standards of Ru le 359 is also not considered to be in violation if the operator demonstrates that the exceedance re sulted from an emer gency event.

Unlike District Rule 4311, SBC APCD Rule 359 does not apply to t he burning of sulfur compounds in the manufacturing o f sulfur compounds. Additional ly, under SBCAPCD Rule 359, flares for which flari ng operations solely consist of planned, continuous flaring due to the non-availability of a p roduced gas pipeline are exem pt from FMP requirements.

Although FMPs in SBCA PCD Rule 359 ar e required to list a target ed maximum monthly flared gas volume of five percent (5%) of the average monthly g as handled/produced/treated, the operat or can obtain approval of a higher percentage by demonstrating that the maximum fl are volume limit is infeasible based on safety, engineering, or cost constraint s, which leaves the rule open to allow a higher amount of flaring. The District evaluated the percentage of gas flared i n the Valley and found that the average percentage of gas flared between 2009 and 2013 was well below SBCAPCD’s 5% theoretical level a t 3.8% as shown in the table be low.

Table C-11 Percent of Gas Fl ared 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 ru le 359, Rule 4311 does not allow an exceedance of any emissions limits or the requirem ent to minimize flaring activit y, regardless of the cause. Allowing such a measur e in the Valley would result in a serious relaxation of rule requirements and a potential in crease in emissions. Under the District’s rule, any exceedance or excess flaring not allowed under R ule 4311, regar dless of the cause, would result in a violation and be subject to enforcement actio n. Flares subject to SBCAPCD Rule 359 whose flaring operations solely consist of pla nned, continuous flaring due to the non-availabilit y of a produced gas pipeline outlet are also exempt fromSan Joaquin Valley Unified Air Polluti on 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 flar es subject to Rule 4311 are not exempt from FMP requirements and are still requi red to identify and implement a ctions that reduce flaring.

Based on the discussion above, Dis trict Rule 4311 is clearly mo re stringent than SBCAPCD Rule 359 for the following reasons:

 Rule 4311 applies to a broader r ange of sources than SBCAPCD R ule 359

 SBCAPCD Rule 359 includes a per formance standard for the volum e of gas flared (5%), but also includes A PCO discretion for allowing unl imited flaring activity

 SBCAPCD Rule 359 contains sever al exemptions not allowed in Ru le 4311, including the allowance fo r 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 requirem ents

 Overall, Rule 4311 results in si gnificantly less flared gas re lative to flaring capacity in the District as compar ed the allowable levels of fl aring under SBCAPCD

State of North Dakota

 Century Code 38-08-06.4 39

 Industrial Commission Order 40

North Dakota Century Code 38-08- 06.4 applies to flaring of gas produced with crude oil from an oil well. The North Dako ta rule allows for the uncontr olled flaring of all gases during the first year after openi ng a new crude oil production well, after which flaring of the entire volume of gas must c ease and the well must be:

 Capped;

 Connected to a gas gathering line;

 Equipped with an electrical genera tor that consumes at least s eventy-five percent (75%) of the gas from the well;

 Equipped with a system that intak es at least seventy-five perc ent (75%) of the gas and natural gas liquids volum e 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 liqui d fuels, separating and collecting over fifty perc ent (50%) of the propane and heav ier hydrocarbons;

or

 Equipped with other val ue-added processes as approved by the i ndustrial commission, which reduce the volume or intensity of the flare b y 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 Commissi on Authority. Retrieved February 13, 2015 from http://www.legis.nd.gov/cenco de/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 Polluti on 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 N orth Dakota, the North Dakota Industrial Commission acted on a motion of the commissi on to consider amending the cu rrent oil production rule to reduce the amount of fl ared gas by issuing an order in July 2014 to increase gas capture from oil wells. The or der 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 p roduction 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. I f the 60% gas capture target is not met, t he well may continue to produce 100 barrels of oil per day. This Order of the Commission is not an actual rule amendment and, be cause it did not pass through the entire public process, could be defeated in court o r simply expire January 2016. 41

Many of the sources subject to Rule 4311 design and operate the ir equipment and processes in a manner that inherent ly results in minimal flarin g activity. Flare gas is typically flared further along in the process, rather than dire ctly from production wells, resulting in less flaring acti vity. In contrast, sources in No rth Dakota flare large portions of the gas generated at oil product ion wells. This is a rudime ntary oil production method that is often seen in regions wit h little to no hi story of emis sion regulations. Flaring in North Dakota has increased more than 50% in the past two years to levels previously unknown in the United St ates and comparable to those of Russia and Nigeria. 42 According to North Dakota's Depa rtment of Mineral Resources, 29 percent (29%) of the natural gas now extracted in Nor th Dakota is flared off, which accounts for almost 28% of all flaring in the United St ates and one percent (1%) of all flaring worldwide. 43 In April, 2014 alone, North Dakota we lls burned off 10.3 billion s cf of natural gas, worth almost $50 million on the spot m arket. The annual value of fla red 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 Com mission to increase gas capture to 74% by October 2014 , 77% by January 2015, 85% by 201 6, and 90% by 2020, the District already requires a minimum of 95% gas captur e and achieves over 96%. In addition, because the Nort h Dakota rule contains no re quirements 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/s tate-and-regional/helms-says-t ax-revenue-atrisk-if-flaring-oil-conditioning /article_e615f72d-d2ff-50a6-a15 1-4875945792c5.html
42 King & Spalding. (2014, June). Dispute Resolution, Oil & Gas Litigation . Retrieved February 13, 2015 from http://www.kslaw.com/library/new sletters/EnergyNewsletter/2014/ June/article2.html

. 43 North Dakota Pipeline Authority. Natural Gas Facts . Retrieved February 13, 2015 from http://northdakotapipelin es.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 Februa ry 13, 2015 from http://www.ndoil.org/image/ cache/NDPCAnnual092111_2.pdf

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

C-83 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard the fraction of gas not address ed by one of the required option s, a producer would be able to vent up to 40% of produc ed gas directly to the atmosphe re and still have the ability to flare the full capt ured amount. For the first year of operation, operators of new oil production wells are permitte d to flare 100% of produced ga s. Additionally, the optional equipment used to contro l the captured gas, such as un controlled internal combustion engines, could easily i ncrease emissions because fla ring in itself is a highly effective control technology. Finally, a producer may obtain a n exemption by demonstrating to the industria l commission that connection of t he well to a natural gas gathering line is economically inf easible or that a market for the gas is not available and equipping the well with an electr ical generator to produce elec tricity from gas or employing a collection system i s economically infeasible. Nort h Dakota regulators granted ninety-five percent (95% ) of extension requests over th e last two years. 47

In the Valley, operator s do not have the flex ibility to capture only 60% of associated gas or to obtain extensions or exem ptions from rule requirements as allowed in the North Dakota rule. New steam enhanced w ells (the vast majority of we lls in the District are heavy oil steam enhanced wells) r equire an ATC permit before th ey are operated. As part of receiving an ATC, these we lls are subject to the Distri ct’s New Source Review rule (District Rule 2201), which r equires the installation of B est Available Control Technology (BACT) consisting of a system that collects and cont rols well vapors and must comply with a multitude o f additional requirements (i.e, o ffsets, public noticing, health risk assessment, etc.).

The District has two rules spec ific to the operation of crude o il wells. Rule 4401 (SteamEnhanced Crude Oil Production Wells ) and Rule 4409 (Components at Light Crude Oil Production Facilities, Natural gas Production Facilities, and N atural Gas Processing Plants). These rules contain c ontrol requirements including a minimum 95% capture and control, periodic leak detection, and r epair requirements f or steam enhanced wells and light oil wells. These rules also require the development of an Operator Management Plan (OMP) that descr ibes how a facility will comply . The OMP must be updated annually to reflect any c hanges to the OMP, including c hanges to address newly installed wells. These proh ibitory rules are applicable to both existing and new wells.

Regions such as North Dakota hav e only recently begun controlli ng emissions from flares and, as such, must make si gnificant progress before matc hing the District in capture and control technolog y and stringency of regulations. After extensive analysis of the North Dakota rule require ments and comparison to those i n the District, it is clear that Rule 4311 is significantly more stringent than North Dakot a Century Code 38-08- 06.4 for at least the following reasons:

 Rule 4311 applies to a broader r ange 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/

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

C-84 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard  Rule 4311 requires 95% captur e and treatment of produced gas, whereas the North Dakota rule only require s 60% capture and allows one year of unlimited flaring

 The North Dakota rule does no t contain any requirements that a ddress the remaining 40% of produced gas

 95% of facilities that requested extensions to the requirement s of the North Dakota rule were approved

Evaluation Findings Even though flares are not a si gnificant source of PM2.5, NOx, or SOx in the Valley, the District has evaluated all potentia l control technologies and a ll control technologies achieved in practice in other ar eas or included in other state implementation plans. As demonstrated above, Rule 4311 curr ently has in place the most s tringent measures feasible to implement in the Va lley and therefore meets or exce eds both BACM and MSM requirements for this source category.

As described in the se ction detailing FMP r equirements, operato rs of flares in the Valley are already implementing all f easible measures to reduce flarin g activity. Even for those devices that have been committed to in FMPs, alternative method s of disposal do not necessarily decrease emissions, and could even increase emissio ns compared to the baseline from flares; however, c ombusting gas onsite or transmi tting it for use at other sources could prevent the additi onal combustion of other fuel, thereby reducing overall emissions in the Valley, if not a ctually reducing emissions fro m the combustion of the flare gas.

In other air districts, the addi tion of transmission pipelines is the only major viable possible measure to reduce emis sions. In the Valley, most prod ucers of associated gas have access to transmission pipel ines and are already selling a s much gas as possible. The addition of pipelines would most likely not be performed by the facilities operating flares, but would instead be inst alled by utility companies suc h as PG&E. Requiring oil and gas producers that do not hav e access to transmission pipel ines to construct them would be cost prohibitive and is beyond the scope of what is re quired by any other air district.

Although Rule 4311 already meets BACM and MSM requirements, the District is committing to further evaluate Ru le 4311 beginning in 2015. Se e Chapter 8 (Commitment to Leave No Stone Unt urned to Evaluate Additional O pportunities) for more information.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-85 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.12 RULE 4313 LIME KILNS

Discussion Rule 4313 was adopted in 2003 to limit NOx emissions from the o peration of lime kilns. Lime kilns can be used in a varie ty of manufacturing and proces sing 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 leas t as stringent as established RACT requirements.

Source Category There are currently no lime kilns operati ng in the Valley. At the time of rule adoption, there were a total of three lime kilns in the Valley, used at t wo sugar processing plants; however, these plants have been non-operational since 2008. An y lime kilns beginning operation in the Valley in the fu ture would be required to meet District BACT requirements, per District Rules 2201 (New and Modified Station ary Source Review Rule) and 4001 (New Source P erformance Standards).

Emissions Inventory There is no emissions inventory associated with lime kilns beca use there are no lime kilns operating in the Valley; no lime kilns are in the prelimi nary permitting process to become operational in the Valley, nor are any lime kilns expect ed to be operated in the Valley in the future.

How does District Rule 4313 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG or ACT requi rements for this source catego ry.

NSPS

 40 CFR 60 Subpart HH (Standards o f Performance for Lime Manufa cturing Plants)

The District evaluated the require ments contained within 40 CFR 60 Subpart HH and found no requirements that were more stringent than those alrea dy in Rule 4313.

NESHAP/ MACT

 40 CFR 63 Subpart AAAAA (National Emission Standards for Hazar dous Air Pollutants for Lime Ma nufacturing Plants)

The District evaluated the require ments contained within 40 CFR 63 Subpart AAAAA and found no requirement s that were more stringent than those a lready in Rule 4313.

State Regulations There are no state re gulations applicable to this source catego ry.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-86 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard How does District Rule 4313 compar e to rules in o ther air distr icts? There are no analogous rules for this source category in SCAQMD , BAAQMD, SMAQMD, and VCAPCD.

Evaluation Findings There are no lime kiln s operating in the Vall ey and thus no emi ssions or emission reduction opportunities for this source category. As previousl y mentioned, any lime kilns beginning operati on in the future would be required to me et District BACT requirements. As such, Rule 431 3 meets or exceeds both BACM an d MSM requirements for this source category.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-87 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.13 RULE 4352 SOLID FUEL FIRED BOILERS, STEAM GENERATORS, AND PROCESS HEATERS

Discussion The purpose of Rule 4352 is to lim it NOx and carbon monoxide (C O) emissions from any boiler, steam generator or process heater fired on solid fu el. Prior to September 14, 1994 solid fuel fired units were e xempt from the requirements o f District Rule 4305. The adoption of Rule 4352 established NOx limits of 200 parts per m illion volume (ppmv) for municipal solid waste facilit ies (MSW), 0.35 pounds per million British thermal units per hour (lb/MMBtu) for biomass fac ilities, and 0.20 Ib/MMBtu for a ll other solid fuel fired units. Since its adoption, the rule has been amended three tim es. The December 2011 amendments strengthened the rule by lowering NOx emissions limi ts for all three source categories. However, no emissi ons reductions were quantified b ecause the rule amendments were meant to satisfy EPA RACT require ments and all units were determined to be operating at t he new emission limits. EPA fin alized approval of Rule 4352 on November 6, 2012 and deemed th is rule as being at least as stringent as established RACT requirements.

While previous rule-amending proj ects for Rule 4352 have not qu antified specific emissions reductions, the use of b iomass facilities in the Vall ey has fostered emissions reductions. As an energy source, bi omass can either be used di rectly or converted into other energy products such as b iofuel. Biomass facilities in t he 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 w ood 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 pr ocess heaters are used in a br oad range of industrial, commercial, and institutional s ettings. Units subject to this rule fire on a variety of solid fuels: coal, petroleum coke, b iomass, tire-derived fuel, and MS W. Although the output from units subject to the rule cou ld be utilized in many settin gs, 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 cont rolling NOx emissions from boile rs, steam generators, and process heaters ar e either to change the combustion paramet ers to reduce NOx formation (i.e., combustion modi fication) or to treat the NOx f ormed in the process before the NOx is emitted into th e atmosphere (i.e., post-combu stion control or flue gas treatment).San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-88 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 0.62 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from s olid fuel fired boilers, steam generators, and process heaters are lower than the BACM/ MSM significance thresholds. T herefore, 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 Distr ict has still conducted a full control measur e evaluation for solid fuel fire d boilers, steam generators, and process heaters.

How does District Rule 4352 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG requirements for this source category.

ACT

 EPA–453/R-94-022 (Alternative Cont rol Techniques Document– NOx Emissions from Industrial/Commercial / Institutional Boilers)

The District evaluated the requi rements contained within the AC T for NOx Emissions from Industrial/Commercial/Instit utional Boilers and found no r equirements that were more stringent than those already in Rule 4352.

 EPA – 453/R-94-023 (Alter native Control Tec hniques Document– N Ox Emissions from Utility Boilers)

The District evaluated the requi rements contained within the AC T for NOx Emissions from Utility Boilers and found no requirements that were more s tringent than those already in Rule 4352.

NSPS

 40 CFR 60 Subpart Cb (Emission Gu idelines and Compliance Times for Municipal Waste Combustors that are Constr ucted on or before December 19, 1995)San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-89 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard The District evaluated the require ments contained within 40 CFR 60 Subpart Cb and found no requirements that were more stringent than those alrea dy in Rule 4352.

 40 CFR 60 Subpart D (Standards of Performance for Fossil-Fuel- Fired Steam Generators for which Constructi on is Commenced after August 17, 1971)

The District evaluated the require ments contained within 40 CFR 60 Subpart D and found no requirements that were more stringent than those alrea dy in Rule 4352.

 40 CFR 60 Subpart Db (Standards o f Performance for Industrial- CommercialInstitutional Steam Generating Units)

The District evaluated the requi rements contained within the 40 CFR 60 Subpart Db and found no requirements that were more stringent than those alrea dy 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 am ended on January 31, 2013 to incl ude new emission limits for PM, CO, and to tal selective metals (TSM), r eplace numeric dioxin emission limits with work pra ctice standards, add new subcatego ries of facilities, and add alternative monitoring appr oaches. The District evaluated the requirements contained within this NESHAP a nd found no requirements that wer e more stringent than those already in Rule 4352.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 4352 compar e to rules in o ther air distr icts? There are no analogous rules for this source category in VCAPCD

.

SCAQMD

 Rule 1146 (Emissions of Oxides of Nitrogen from Industrial, In stitutional, and Commercial Boilers, Steam Gener ators, and Process Heaters)

The District evaluated the require ments contained within SCAQMD ’s Rule 1146 and found no requirements that were more stringent than those alrea dy in Rule 4352.

BAAQMD

 Regulation 9 Rule 7 (Nitrogen Ox ides and Carbon Monoxide from Industrial, Institutional, and Commercial Bo ilers, Steam Generators, and Pr ocess Heaters)

The District evaluated the requi rements contained within BAAQMD ’s Regulation 9 Rule 7 and found no requirements that w ere more stringent than those already in Rule 4352.San Joaquin Valley Unified Air Polluti on 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 requi rements contained within BAAQMD ’s Regulation 9 Rule 11 and found no requirements tha t were more stringent than thos e already in Rule 4352.

SMAQMD

 Rule 411 (NOx from Boilers, P rocess Heaters, and Steam Generat ors)

The District evaluated the require ments contained within SMAQMD ’s Rule 411 and found no requirements that were more stringent than those alrea dy in Rule 4352.

Additional Emission Reduc tion Opportunities

Biomass Facilities The presence of biomass facilit ies in the Valley, from either n ew facilities or other solid fuel fired boilers that have c onverted to biomass, continues to significantly reduce NOx and PM emissions from open burning practices. However, the bio mass industry has indicated that given current ener gy policy in California there is concern that biomass power facilities are in jeopardy . Many biomass plants in the V alley are nearing the end of their long-term contracts wit h utilities and find themselves in a position where the power that they provide is not th e type of power that utilities are seeking (base load vs. intermittent) and that the prices being offered for new contrac ts are too low to support their operations.

The District has learned that two biomass power plants have shu t down due to their inability to secure contracts wit h utilities at rates that are sufficient to sustain their operations. Greenleaf Power tha t operates the Tracy Biomass Pl ant, located in Tracy, reported that they shut down on October 31, 2014 and the Covant a facility located in Mendota was shut down in Januar y 2015. Initially, another Cova nta facility in Delano had indicated that they were lik ely to shut down but is now rep orting that they were able to secure a one-year extension on their current utility contrac t at the same rate that enables them to continue to operate . With addition al biomass f acilities on the brink of closure, it has become even more infeasible to require citrus o rchard removals to be sent for use in biomass.

The District has convened a number o f productive meetings with agricultural stakeholders and representatives o f the biomass industry in ord er to more fully understand the issues faced by th e industry and develop a commo n vision of the future of biomass power amongst the st akeholders in the Valley. The m eetings have been helpful in forging a better work ing relationship between agricu lture representatives and biomass power producers and devel oping consensus on long-term s olutions. The group has also discussed potent ial short term solutions.

In June 2014, the District’s Gove rning Board adopt ed positions on two pieces of legislation that impact the bi omass industry. The District ado pted a position in supportSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-91 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard of AB 2363 (Dahle), which was s ponsored by the biomass industry , and would make biomass plants more competitive by fully accounting for the cos ts associated with intermittent sources of renewabl e power (solar and wind) when c omparing 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 posit ion in opposition to SB 1139 (Hueso) that would have giv en preferential treatment to ne w geothermal power plants by requiring that utilities purchase specified amounts o f new geothermal power. Ultimately, AB 1139 was not pa ssed by the legislature.

Long-Term Solutions for Biomass There is consensus that biomass pow er producers currently are n ot on a level playing field in competing with other r enewable sources of power for ut ility contracts. They are also not receiving any preferent ial treatment for the societal benefits for providing a cleaner alternative to the open burni ng of agricultural waste a nd assisting with meeting landfill diversion goals.

Contracts between power producer s and utilities are confidentia l, but the current market rate that the biomass plants c an garner is approx imately 6 cent s/KWH. This is the rate that the utilities obtain through contracts with solar power pr oviders. This low cost is made possible largely due to gov ernment subsidies provided for solar power production. Biomass power producers have i ndicated that it takes approximat ely 9-10 cents/KWH for the plants to cover their operating costs.

The District and representatives fr om agriculture and biomass i ndustries are working to develop and pursue specific acti ons with the legislative branch , utilities, Public Utility Commission, CalRecycle, and other government agencies to help l evel 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 Co mmission, and other partner agencie s to pursue clean alternatives to biomass power pr oduction for agricultural waste disposal.

Selective Catalytic Reduction When comparing Rule 4352 to EPA and other air districts’ BACT r equirements, it was noted that SCR systems are cons idered BACT. A SCR system reduc es NOx emissions by converting the emissions to w ater and elemental nitrogen. I n the analyses below, the District evaluated the cos t 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 genera lly equipped with Selective Non -Catalytic Reduction (SNCR) and utilize this technolog y to meet emission limits rang ing between 165 ppmv to 210 ppmv. Although it appears t hat facilities can achieve a lower NOx limit beyond the current rule requirements, an additional NOx control techno logy such as Selective Catalytic Reduction (SCR) w ould be needed. In fact, the instal lations that are achieving lower NOx emissions were instal led as new installations equippe d with the SCRSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-92 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard technology. The District could no t find an example of an SCR i nstallation as a retrofit on an existing MSW facility.

Though a retrofit installation has not been demonstrated in pra ctice, the District conducted a cost effectiveness an alysis to determine if install ing SCR as a retrofit would be reasonable. The District us ed 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 ppm v at 7% O2 (47 ppmv @ 12% CO2)

 Capital cost annualized at 10% interest for 10 years

Cost data was obtained from a p reconstruction approval by the F lorida Department of Environmental Protection (FDEP) issued on December 23, 2010. T he approval was issued for an MSW-fired combusto r equipped with SC R for NOx con trol. The control equipment costs from the FDEP appl ication include uncontrolled NOx emissions of 250 ppmv and controlled NOx emissions of 50 ppmv which represents a n 80% reduction in NOx from the SCR. However, 80% reduction from 165 ppmv @ 12% C O2 would yield controlled emissions of 33 ppmv , which is well below BACT. Ther efore, controlled emissions are evaluated at the BA CT 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 Dis trict reviewed the expected exhaust param eters and found them comparable to the pa rameters for solid fuel-fired boilers in the Valley . Therefore, it is believed th at this cost estimate provides a valid basis for estimating costs for installing SCR on boilers in the Valley.

To maximize the emission reducti ons and economies of scale in e stimating 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 as sumptions 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 siz e 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 BSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-93 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard  SB is the size of equipment B

 SA is the size of equipment A

C B = C A x (S B ÷ S A ) 0.6

It is standard District policy for Best Available Control Techn ology (BACT) analyses to use a 10 year life and 10% interest rate unless information ind icates otherwise; therefore the capital recovery factor (CRF) of 0.1627 will be u sed 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 c an be laid out in a way that minimizes pressure losses , allowing for a smaller ID fan t han may be required for a retrofit. Affected sources hav e provided some estimates for ad ditional electrical costs associated with the larger ID fan required for a retrofit, so t hese have been incorporated into the analysis. In addition, t he 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 re trofit would require at least s ix months of downtime at $118/MW-hr; this will be added to the capital cost. Finally, t he FDEP analysis specifically ignored sales tax on capital equipment on the grou nds it is exempt from sales tax in Florida. This woul d not be the case in California , so 8% sales tax has been included.

The cost effectiveness analysis for installing SCR on a MSW uni t is as follows:

Table C-13 Cost Effectiveness fo r 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 FDEP 48 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 in stallation 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-adjust ed using six-tenths rule from 4 60 MMBtu/hr to 350 MMBtu/hr.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-94 Appendix C: BACM and MSM for Stationary and Area Sources 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 kW 49 ) $0.08848/kWh r 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/hrSan Joaquin Valley Unified Air Polluti on 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 Eff ectiveness 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 inst alling SCR on a MSW fired boiler is $30,806 per ton of NOx reduced. It is important to not e that this calculation is based off of a new installation of SCR, not a retro fit as would be required by Val ley facilities. While some retrofit expenses have been inclu ded, operators would potential ly incur additional costs when retrofitting to incorporate SCR including expenses for add itional ductwork, installation of a new natural gas pipeline to replace the exist ing 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 genera lly equipped with SNCR and alth ough it appears that facilities could possibly achiev e 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 t he SCR technology, with one ex ception. 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, t he District approved the facility’s application to repl ace the existing SNCR (which had become inoperable) with the SCR install ed under the experimental research exemptio n. This modification did not result in any reduction in permitted emissions as the S CR-equipped boiler is only required to comply with the sa me emission limit the SNCR-equipp ed boiler was. This modification was incorporated in to the Title V permit in Septem ber 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 uniq ue to each facility that may inhibit the retrofit of a S CR system. Based on the followi ng analysis, SCR is not cost effective at this time. It is important to note that this cost effectiveness analysis does not take into considerati on 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(equi valent to 85ppmv @ 3% O2)

 SCR provides 80% control effici ency (from the provided cost es timates)

 Capital cost annualized at 10% interest for 10 yearsSan Joaquin Valley Unified Air Polluti on 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 p reconstruction approval by the F DEP issued on December 23, 2010 as described above in the MSW section.

To maximize the emission reducti ons and economies of scale in e stimating the retrofit costs, it is assumed that a 700 MMBtu/hr unit is operating at f ull fire at 100% capacity factor year round is representativ e for the Valley biomass faci lities. 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 Calcul ations 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 siz e using the six- tenths rule, as described in the MSW section above.

C B = C A x (S B ÷ S A ) 0.6

Therefore; C B = $9,672,939/year x (700 MMB tu/hr ÷ 350 MMBtu/hr) 0.6 = $14,661,434/year

It is standard District policy to use a 10 year life and 10% in terest rate; therefore the capital recovery factor (CRF) of 0.1627 will be used to annuali ze the capital costs.

Table C-16 Cost Effectiveness fo r 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 re quiring the installation of SCR would provide a cost e ffectiveness of $54,342/ton for a biomass-fired boiler. The cost effectiveness was ev aluated without taking into accoun t additional potential costs involved in a retrofit of the facility. It should also b e noted that the District’s cost effective analysis is very conser vative since the installation of the SCR technology with an 80% control efficiency assumes a NOx emission level of appro ximately 17 ppmv @ 3% O2. This level is lower than established BACT levels and we ll beyond RACT thresholds. Therefore, even with these conservative assumption s, the installation of SCR is not cost effective for these types of installations.

Furthermore, the emission factor s used above are short-term emi ssion limits on a block 24-hour average basis and in all probability will not be repres entative of actual annual emission rates. Indeed, the post- SCR emission factors for biom ass is 0.022 lb/MMBtu,San Joaquin Valley Unified Air Polluti on 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-te rm emission limits for recently issued biomass-fired boiler ATCs. If, as appears possi ble, the post-SCR emission ra tes are higher than assumed above, then the quantity of emission reductions will be lower and the cost of emission reductions greater. Fi nally, it is vital to remember that the 700 MMBtu/hr boiler assumed for biomass boilers abo ve is an idealized hypothetical chosen to maximize the economies of scale in using the six-tenths rule to scale the co st estimate. For any actual plant within the populati on of solid fuel-fired boilers in the Valley, the boiler rating will be lower (as sma ll as 171.2 MMBtu/hr) and the cost of emis sion reductions will be correspondingly higher.

Cost Effectiveness of SCR fo r Units Using Other Fuels Currently, facilities are equippe d with SNCR and although facil ities may be able to achieve a lower NOx limit beyond the revised proposed rule amen dments, 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 followin g methodology and assumptions f or this cost effectiveness analysis:

Assumptions

 Baseline emission factor is 0. 10 lb-NOx/MMBtu (equivalent to 7 3 ppmv @ 3% O2)

 SCR provides 80% control effici ency (from the provided cost es timates)

 Capital cost annualized at 10% interest for 10 years

Cost data to install the SCR te chnology was obtained from a pre construction approval the FDEP issued on December 23 , 2010 as described above in the MSW section.

To maximize the emission reducti ons and economies of scale in e stimating the retrofit costs, it is assumed that a 700 MMBtu/hr unit operating at full fire at 100% capacity factor year round is representativ e for boilers firing on “othe r” 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 Calc ulations 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 siz e using the six- tenths rule, as described in the MSW section above.

C B = C A x (S B ÷ S A ) 0.6San Joaquin Valley Unified Air Polluti on 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; C B = $9,672,939/year x (700 MMB tu/hr ÷ 350 MMBtu/hr) 0.6 = $14,661,434/year

It is standard District policy to use a 10 year life and 10% in terest rate; therefore the capital recovery factor (CRF) of 0.163 will be used to annualiz e the capital costs.

Table C-18 Cost Effectiveness fo r 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 re quiring the installation of SCR would result in a cos t effectiveness of $59,769/ton for an Other Fuel-fired boiler. The cost effectiveness was ev aluated without taking into accoun t 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 effe ctiveness analysis and did not further evaluate additional c osts associated with a retrofi t. It should also be noted that the District’s cost effectiv e analysis is very conservativ e since the installation of the SCR technology with an 80% contro l efficiency assumes a NOx emi ssion level of approximately 15 ppmv @ 3% O2. Thi s level is lower than establ ished BACT levels and well beyond RACT thresholds. Ther efore, even with these conser vative assumptions, the installation of SCR is not cost effective.

Furthermore, the emission factor s used above are short-term emi ssion limits on a block 24-hour average basis and in all probability will not be repres entative of actual annual emission rates. Indeed, the post- SCR emission factors for “oth er” fuels is 0.020 lb/MMBtu, which is well below th e short-term emission limits fo r recently issued ATCs. If, as appears possible, the post- SCR emission rates are higher than assumed above, then the quantity of emission redu ctions will be lower and the cost of emission reductions greater. Finally, i t is vital to remember that the 700 MMBtu/hr boiler assumed for “other” fuels above is an idealized hypothetical ch osen to maximize the economies of scale in using the six-tenths rule to scale the co st estimate. For any actual plant within the polluti on of solid fuel-fired boilers i n SJVAPCD, the boiler rating will be lower (as sma ll as 171.2 MMBtu/hr) and the cost of emis sion reductions will be correspondingly higher. Based off of this information, it woul d not be cost effective to require Valley facilities to ret rofit with additional NOx reduc tion technology beyond what is currently being used.

Controls for Direct PM2.5 Emissions The District researched the pot ential opportunity of specifying required controls for direct PM2.5 emissions. Three te chnologies were recognized as being able to potentially reduce direct PM2.5 e missions: electrostatic precip itators (ESPs), baghouses, and cyclones.San Joaquin Valley Unified Air Polluti on 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 collecti on device that removes particle s from a flowing gas using the force of an electrostatic charge with a 90- 99.9% control e fficiency of PM2.5 for solid fuel fired boilers within the 100-500 MMBtu/hr size range of Di strict units. 50 A baghouse, on the other hand, is a te chnology in which particula tes are removed from a stream of exhaust gases as the stream passes through a large cl oth bag. Baghouses have a PM2.5 removal effectivene ss of 90-99.9% for solid fuel f ired 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 safe ty risk of the burning embers causing a fire in the baghouse. However, when cyclones are combined with the use of a baghouse, the burning ember s are extinguished and allo w for the use of a baghouse in a biomass facility 52 . 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 eithe r a baghouse or ESP particulate matter removal syst em due to permitting requirement s. Since the control efficiency ranges for both technol ogies are equivalent, there a re currently no other PM controls more effective than current practices.

Controls for SOx Emissions Potential opportunities to reduce SOx emissions from this sourc e category were also researched. Most facilities s ubject to Rule 4352 currently inj ect limestone into the combustion chamber to react wit h fuel sulfur and produce variou s sulfate compounds, which can then be removed by t he ESP or baghouse. This control technology typically achieves around 50% control of SOx emissions 53 ; 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 boilers 54 . The only MSW facility in the Valley currently utilizes a semi-dry scrubber syst em to control SOx emissions. Therefore, the District calculated the average cost eff ectiveness of a scrubber system for biomass and coal/coke facilities.

The District conducted a SOx BACT e valuation for a local power generation facility that was installing a biom ass boiler and determi ned the capital cost s for a wet scrubber

50 Senior, C., Afonso, R. (January 2009). Applicability and Feasibility of NO x, SO2, and PM Emissions Control Technologies for Industrial, Commercia l, and Institutional (ICI) Boilers. Northeast States for Coordinated Air Use Management.
51 Senior, C., Afonso, R. (January 2009). Applicability and Feasibility of NO x, SO2, and PM Emissions Control Technologies for Industrial, Commercia l, 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 Man agement and the EPA Office of Air Qu ality 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 NO x, SO2, and PM Emissions Control Technologies for Industrial, Commercia l, and Institutional (ICI) Boilers. Northeast States for Coordinated Air Use Management.San Joaquin Valley Unified Air Polluti on 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 in stalled equipment cost by the c apital recovery factor of 0.1627.

Annual Capital Costs (AC capital )

AC capital = $5,800,000 X 0.1627 AC capital = $943,660/year

In addition, this system has addi tional costs for the sodium hy droxide reagent used in the scrubber which are estimat ed to be an additional $642,000 p er year. Thus, the total annual cost would be:

Total Annual Costs (AC total )

AC total = Capital Costs + Reagent Cos ts = ($943,660/year) + ($642,000/ year) AC total = $1,585,660/year

Cost effectiveness is calculated by dividing the annual cost by the annual emissions reductions from District standar d emissions. One cost effectiv eness analysis was conducted for the biomass and coal /coke fired units in the Vall ey because the four coal/coke fired units are fired on biomass part of the time.

The average SOx emi ssions limit of these units, based on Distri ct 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/MMb tu at 24 hours per year is assum ed to reflect the time needed for the startup and shutdo wn period, when the exhaust te mperature is not high enough for controls to be fully effective. Therefore, those nu mbers were utilized to calculate annual standard emissions as follows:

Annual Standard Emissions (AE standard )

AE standard = [(0.044 lb/MMBtu) x (341 MMBtu /hour) x (8,760 hour/year)] + [(0.27 lb/MMBtu) x (24 hour/y ear) x (341 MMBtu/hr)] AE standard = 133,644.7 lb/year

Potential emissions, using the te chnologically feasible emissio n limit of 0.012 lb/MMBtu that is achieved by the use o f a wet scrubber system, can be ca lculated as follows:

Annual Emissions with Wet Scrubber System (AE scrubber )

AE scrubber = [(0.012 lb/MMBtu) x (341 MMB tu/hour) x (8,760 hour/year)] + [(0.27 lb/MMBtu) x (24 hour/yea r) x (341 MMBtu/hour)] AE scrubber = 38,055.6 lb/year

Therefore, the cost e ffectiveness would be:San Joaquin Valley Unified Air Polluti on 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 ab ove does not reflect the costs of additional electricit y consumption, additional labor c osts, 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 ef fective option, and therefore, is not feasible.

There are no additional technolog ies available to reduce SOx em issions from solid fuel fired units.

Start-up Periods The possibility of reducing the a llowed start-up period of soli d fuel fired boilers was considered, since facilities are exempt from emissions limits d uring this period. Facilities subject to Rule 4352 are currently subject to a star t-up limit of 96 hours. Operators currently limi t their start-up and shut-down times as much as possible since down time results in reduc ed productivity and profits. H owever, facilities periodically perform “cold repai rs” on their solid fuel fired b oilers for maintenance or trouble-shooting purposes. This r equires operators to complete ly shut down the boilers, which in turn requires a longer sta rt-up period to return to co rrect operating temperature. When the solid fuel fired boilers are starting up, the units ar e not operating with a full load which reduces emissions. Ther efore, this is not a technol ogically feasible option for solid fuel fired facilities given the needs of current work practices.

Evaluation Findings Even though solid fuel fired boile rs, steam generators, and pro cess heaters are not a significant source of P M2.5, NOx, or SOx in the Valley, the Dis trict has evaluated all potential control technologies and all control technologies ach ieved in practice in other areas or included in other state implementation plans. As demo nstrated above, Rule 4352 currently has in place the most stringent measures feasibl e to implement in the Valley and therefore meets or exceeds bot h BACM and MSM require ments for this source category. As the District continues to develop new atta inment plans that address more stringent National A mbient Air Quality Standards, the District will continue to evaluate potential opportuniti es to reduce emissions from so lid fuel fired boilers, steam generators, and proce ss heaters in the Valley.San Joaquin Valley Unified Air Polluti on 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 fur naces in the Valley. The purpose of this rule is to limi t NOx, SOx, volatile organic com pounds (VOC), carbon monoxide (CO), and PM emissions fr om glass melting furnaces.

Rule 4354 was adopted on Septem ber 14, 1994 and has been subseq uently amended six times. Rule 4354 was am ended September 16, 2010 to strengt hen the NOx emission limits in the rule; EPA finalized approval for these a mendments on August 29, 2011. Rule 4354 was subsequently amended again in May 19, 2011 to implement updated start-up requirements; E PA finalized approval of the 20 11 amendments to Rule 4354 on January 31, 2013 and deemed this rule as being as strin gent as, if not more stringent than, established RACT requirements. As a result of this stringent prohibitory rule and continuing efforts on behalf of this ind ustry to reduc e emissions, the Valley is home to glass-making facilities w ith glass melting furnaces tha t utilize the most advanced low-NOx firing technology.

Source Category Industrial glass making is a c ontinuous process with raw materi als supplied to the furnace at the front end, and pr oduct taken off the line at the back end of the process. The raw materials for making gl ass are silica sand and soda ash . Melting these basic materials and forming them into the desired product geometry cr eates the final glass product. The different end products vary widely in raw materia l additives, processing equipment and conditions, and produc t quality requirements. The emission limits of Rule 4354 depend on the type of g lass produced, furnace firing technology and the emission-averaging period.

Rule 4354 is among the most str ingent rules in the nation for g lass melting furnaces. The NOx emission limit s contained within Ru le 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons perSan Joaquin Valley Unified Air Polluti on 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 f or SOx. As identified in the above table, PM2.5 and NOx em issions from glass melting fur naces are lower than the BACM/MSM significance thre sholds. Therefore, the Clean Air Act does not require a control measure evaluation fo r this source category for the p urpose of satisfying BACM/MSM requirements for PM2.5 and NOx; however, the District has still conducted a full control measure evaluati on for glass melting furnaces.

How does District Rule 4354 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG requirements for this source category.

ACT

 EPA-435/R-94-037 (Alter native Control Tec hniques Document—NOx Emissions from Glass Manufacturing)

The District evaluated the requi rements contained within the ab ove ACT and found no requirements that were more str ingent than those already in Rul e 4354.

NSPS

 40 CFR 60 Subpart CC (Standards o f Performance for Glass Manuf acturing Plants)

The District evaluated the require ments contained within 40 CFR 60 Subpart CC and found no requirements that were more stringent than those alrea dy in Rule 4354.

 40 CFR 60 Subpart PPP (Standards o f Performance for Wool Fiber glass Insulation Manufacturing Plants)

The District evaluated the require ments contained within 40 CFR 60 Subpart PPP and found no requirements that were more stringent than those alrea dy 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 am ended February 27, 2014; however , this NESHAP only regulates inorganic arsenic emissions and therefore does n ot apply to this control measure evaluation.

 40 CFR 63 Subpart NNN (National Emission Standards for Hazardo us Air Pollutants for Wool Fiberglass Manufacturing Plants)

The District evaluated the require ments contained within 40 CFR 63 Subpart NNN and found no requirements that were more stringent than those alrea dy in Rule 4354.San Joaquin Valley Unified Air Polluti on 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 (Nati onal Emission Standards for Haza rdous Air Pollutants for Glass Manuf acturing Area Sources)

The District evaluated the require ments contained within 40 CFR 63 Subpart SSSSSS and found no requirement s that were more stringent than those a lready in Rule 4354.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 4354 compar e to rules in o ther air distr icts? 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 require ments contained within SCAQMD ’s Rule 1117 and found no requirements that were more stringent than those alrea dy in Rule 4354.

BAAQMD

 BAAQMD Regulation 9 Rule 12 ( Nitrogen Oxide Emissions from Gla ss Melting Furnaces)

The District evaluated the requi rements contained within BAAQMD ’s Regulation 9 Rule 12 and found no requirements tha t were more stringent than thos e already in Rule 4354.

Additional Emission Re duction Opportunities

SOx Limits for Container Plants The District evaluated the possib ility of lowering the existing SOx limits for container plants from the current limits o f 0.9 and 1.1 lbs of SOx per to n 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 feasib le to lower the SOx limits.

The glass container industry is mandated by the State of Califo rnia to use a minimum quantity of recycled glass (culle t) as part of the production p rocess. The quantity of clear glass cullet available to glass manufacturers is very lim ited; therefore, cullet with a large portion of colored glass is included in each batch. The continued use of mixed color cullet is critically impor tant to meeting California’s re cycling goals. Due to the variable quality of mixed colo r cullet, SOx emissions produced by the melting of recycled cullet are also variable.

Container glass manufacturers c ontrol multiple furnaces as a si ngle unit, meaning that the exhaust from multiple furnac es are ducted together and the total emissions are averaged over the total amount of glass pulled from all furnace s. Because emissions are averaged across furnaces, EPA requires that there be a 10% air quality benefit, meaning that the overall limit fo r multiple furnaces be 10% les s than the limit for a singleSan Joaquin Valley Unified Air Polluti on 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 lowes t SOx emission limit on contain er glass furnaces, but allows operators to install one control device per facility rat her than one add-on control device per furnace. SOx emissions limits for container glass w ere adopted at 1.1 pounds per ton of glass produced i f the operator uses at least 25% by weight of mixed color cullet and a limit of 0.9 pounds per ton of glass produce d for all other container glass manufacturing. If the Dis trict were to lower the limits in the rule to 0.8 lbs/ton, then the 10% required air quality benefit for multiple furnaces exte nd 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 furnac es are not a significant source of PM2.5 or NOx in the Valley, the District has evaluat ed all potential control techno logies and all control technologies achieved in practic e in other areas or included in other state implementation plans. As demons trated above, Rule 4354 current ly has in place the most stringent measures feasible to implement in the Valley and therefore meets or exceeds both BACM and MSM require ments for this source category . As the District continues to develop new attainm ent plans that address more str ingent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emissions from glass melting furnaces i n the Valley.San Joaquin Valley Unified Air Polluti on 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 CONSERVAT ION MANAGEMENT PRACTICES

Discussion Rule 4550 is the District’s C onservation 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 th e reduction of passes of agri cultural equipment and implementation of other conser vation practices. Rule 4550 is u nique because it is based upon a menu approach of cont rol techniques to accommodate the variability of agricultural industries. The se lected CMPs are listed on appli cation forms that are submitted to the District for appr oval as a CMP Plan. Agricult ural operations are required to maintain detailed re cords verifying use of the appr oved Conservation Management Practices. Approved CM P plans are enforced through onsite inspections and operators are required to subm it applications and modify th eir plans when changing their conservation management pra ctices. Through this rule, PM 10 emissions have been reduced by 35. 3 tons per day 55 , which is approximately a 24% reduction for this source category.

The District worked extensivel y with stakeholders, growers, and the Agricultural Technical Committee for the San Joaquin Valley-wide Air Polluti on Study Agency (AgTech) for two years prior to d eveloping the Conservation Man agement Practices (CMP) Rule. Rule 4550 was adopt ed on August 19, 2004 to help b ring the Valley into attainment of federal PM10 st andards. Rule 4550 has served as a model for other regions seeking to reduce fugitive particulate emissions from a gricultural sources.

Upon adoption of Rule 4550, the Dis trict embarked on an ambitio us implementation strategy, working extensively wi th 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 appl ication forms, which were designed to a llow growers to select approved practices from simplifi ed checklists. A special web p age was created that contains answers to frequently asked questions, application for ms, and other forms of assistance for agricultural operations. The District hired add itional staff, including additional Small Business Assist ance (SBA) staff, and took part in over 40 workshops throughout the Valley to assist sour ces in completing and submi tting the required CMP application forms. The workshops were coordinated with agricul tural stakeholders, and tremendous outreach was performed to ensure that as many affect ed sources as possible would attend and receiv e assistance at the workshops. As a result of these efforts, the District's CMP Progr am realized the following nota ble achievements:

 Approximately 4,000 workshop pa rticipants, with many of the pa rticipants submitting CMP Plan applicatio ns during the workshops.

 The District received and proce ssed over 6,000 CMP Plan applic ations 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.pdfSan Joaquin Valley Unified Air Polluti on 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 agr icultural sources encompass 3. 2 million acres of farmland, and over 30,000 miles of unpaved roads.

 The PM10 reductions are quantif iable and enforceable through a pproved CMP plans and inspections.

 The collaborative effort respons ible for the CMP program recei ved US EPA Region IX's "2005 Environmental A ward for Outstanding Achieveme nt."

The District also conducted an additional 60 workshops througho ut the Valley over the last 10 years for the purpose o f assisting sources comply with the CMP and other agrelated rules.

EPA finalized approval of Rule 45 50 on February 14, 2006 and de termined that the rule met BACM requirements. 56 Subsequent to EPA’s approval o f Rule 4550, two separate lawsuits were filed challengi ng EPA’s approval of the rule as s atisfying BACM. The Ninth District Court of Appeals, i n both cases, agreed with EPA ’s approval and reaffirmed EPA’s finding that Rul e 4550 meets BACM requirements

. 57,58

Source Category This rule is applicable to on-fi eld farming and agricultural op eration sites located within the Valley. Rule 4550 limits f ugitive dust emissions from farm ing operations by requiring CMP plans for farms wit h 100 acres or more, dairies w ith 500 or more mature cows, cattle feedlots with 190 or more cows, turkey ranches wit h 55,000 or more turkeys, chicken ranches with 125 ,000 or more chickens, and chi cken egg ranches with 82,000 or more laying hens.

Rule 4550 specifies that agric ultural operations must select at least one CMP from each of the identified app licable CMP categories. Animal feeding ope ration (AFO) sources subject to Rule 4550 that also grow field crops must select CMP s for their field crops, as well as their AFO. There are fi ve CMP categories for the cropl and source category, four CMP categories for the dairy s ource category, four CMP categori es for the feedlot source category, and five CMP c ategories for the poultry source category. The selected CMPs must be noted on the applic ations provided and then submit ted to the District for approval. Completed applications constitute a CMP Plan once ap proved by the District.

Emissions from agricultural operat ions vary by many factors, so me beyond the control of the agricultural operations. P M10 emissions are generated d uring land preparation activities, harvest activities , and post-harvest activities. E missions are caused by the mechanical disturbance of the so il by implements and the tracto rs 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 fo r the Ninth Circuit. Latino Issues Forum v. EPA. Retrieved from http://njlaw.rutgers.edu/collecti ons/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%20 Court%20decision%20favors%20District%20ag %20rule.pdfSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-108 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard resulting in the entrainment of s oil or plant materials into th e air. Wind blowing across exposed agricultural land also c auses the entrainment of PM10 i nto the air. In addition, PM10 emissions can also become ent rained from vehicular travel over unpaved roads and unpaved parking/equipment ar eas. Conservation management p ractices fall into several broad categories and ar e intended to reduce emissions a s follows:

 The reduction of soil or manure disturbance;

 Soil protection from wind erosion;

 Equipment modifications to ph ysically produce less PM10; and

 Application of water or dus t suppressants on unpaved roads and other travel areas to reduce emissions entrai ned by moving vehicles and equi pment.

Emissions Inventory There are no NOx or S Ox emissions attributabl e to the sources s ubject to CMP requirements. The following emi ssions inventory table represen ts 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 si gnificance threshold for source categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts is 4.0 tons per day (tpd) for PM2.5 dust emissi ons. As identified in the above table, annual average emissions from pasture lands are lower than the BACM/MSM signif icance threshold. Therefore, the Clean Air Act does not require a control measure evaluation for that source category for the purpose o f satisfying BACM/MSM requirem ents; however, the District has still conducted a fu ll control measure evaluation for CMPs for all emission categories.

Contribution of PM2.5 to PM10 Em issions from Agricultural Opera tions While Rule 4550 has been successfu l in reducing both PM10 and P M2.5 emissions, recent studies have indicated that the PM2.5 fraction of emissi ons makes up a small portion of the total particulate emissions from agricultural op erations. Additionally, particulate emissions from agricul tural operations are geologic in nature. These geologic particulate emissions m ake up a relatively small porti on of the overall PM2.5San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-109 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard concentrations during the winte r season and have relatively low toxicity relative to the organic carbon fraction of PM2.5 and to re-suspended road dust. 59

Accordingly, particulate emission s from agricultural sources do not play a significant role with regard to attainment of the PM2.5 standards addressed by t his plan, and Rule 4550 is primarily a PM10 reduction strategy. For example, 2004-2006 speciation analyses of PM2.5 from the Specia ted Trends Network in Fresno and Bakersfie ld found that the annual average geologic fraction wa s 4% and 6%, respectively. 60 Given that PM2.5 emissions from agricultural fi eld operations are generally subj ect to deposition near their source, the predominant source o f this geologic PM2.5 would be urban re-suspended road dust with relatively little contribution from agricultural activities.

PM2.5 emissions from agricultu ral field operations have been ge nerally over-estimated in absolute terms due to species differences between the fine a nd coarse fractions of geologic emissions. Using Valley a mbient measurements of trace elements, the PM2.5/PM10 ratios for the predo minant trace elements found in f ugitive dust have been estimated. 61 The average ratio for alumi num and silicon was 0.05 and range d between 0.10 to 0.16 for calcium, titani um, and iron. Based on the rel ative abundances of these elements in fugitive dust, the ov erall PM2.5/PM10 ratio was est imated to be 0.06 (6%). This ratio estimate is substantia lly lower that the ratio of 0. 20 reported previously for agricultural crops nationwide by MRI in 1996 bas ed on limited s upporting data and broad assumptions. 62 Further review of Valley resear ch on PM2.5/PM10 ratios shows a consistent mid-poin t estimate of 0.10. 63 To summarize, PM2.5 comprises a small fraction of total PM10 emissions from field operations, approxi mately 10% in the Valley.

Historically, both grid models an d PM2.5 monitors used in field studies have significantly over-estimated overall PM2.5 em issions from agricultural field operations as well as their contribution to ambient P M2.5 concentrations. In respect to grid modeling biases, there is an expert consensus regar ding the sources of grid mode l overestimation: (1) faulty emission factor algorithm s, (2) imprecise or difficult t o obtain activity data to apply these algorithms (inc luding 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-es timation (especially in the t reatment of particles near their point of emissions). 64

59 Rogge, W. F., Hildemann, L. M., Maz urek, M. A., C ass, G. R. an d 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%2 0Modeling.pdf
61 Countess, R. Reconciling Fugitive Dust Emission In ventories with Ambient Measurements. 12 th 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 Annu al Meeting of the Air and Waste Management Association 63 Pace, T.G, EPA. (2005, April). Examination of the Multiplier Used to Esti mate PM2.5 Fugitive Dust Emissions from PM10. Retrieved from http://www.epa.gov/ttn/chief/c onference/ei14/session5/pace.pdf

. 64 Pace, T.G, EPA. (2005). Methodology to Estimate the Transportable Fr action (TF) of Fugitive Dust Emissions for Regional and Urban Scale Air Quality Analyses

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

C-110 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard In respect to over-estimation o f PM2.5 transport, much of the g round level fugitive dust from soil disturbance is likely to be removed close to the sour ce. 65,66,67 This is due to the low release height and turbul ence which keeps particles tem porarily close to the surface where they are subjec t to removal by impaction on nearb y surfaces, including vegetation and structures. Equally significant in respect to o ver-estimation of PM10 and PM2.5, grid models ignore all re moval processes in the grid cel l where the emissions originate. Given that 4 kilomete rs is a typical grid dimension , a considerable fraction of PM2.5 emitted under normal fiel d operations could and often wou ld be deposited within that cell.

Wind-blown Dust in the Valley The Valley experiences wind-bl own dust events from time to time typically during the spring and fall seasons when weat her disturbances are most comm on. These events are less likely to occur during the long stagnat ion periods of the summer and winter. When soil conditions are dry, s trong wind events often entrain coarse particulate matter into the atmosphere, carrying t he pollution long distances acro ss the Valley. This phenomenon has the potential to cr eate higher concentrations of PM10 in its path of impact.

Although these events primarily cause higher PM10 concentration s, there are rare instances where PM2.5 concentrati ons become elevated. In addit ion to the rarity of elevated PM2.5 concentrations, t he 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 Valle y’s PM2.5 design values are driven primarily by high winter-time concentrations, mos tly due to organic carbon and th e secondary formation of ammonium nitrate. Comparat ively, the geologic component of the Valley’s peak PM2.5 concentrations is only a fraction of the mass formed thro ugh secondary processes and other sources. As a result, the wind events expe rienced in the Valley are not a significant contribut or to the PM2.5 attainment chall enges for the region, and placing further controls on this source would not make a substa ntial difference in the District’s PM2.5 design values.

Continuous Evaluation of Potential CMPs The District evaluates the effe ctiveness of CMPs on a regular b asis, as illustrated on the District’s web page under Requirements for Agri cultural Operations

. 68 Rule 4550 was adopted in August 2004, and dur ing that same year the Ag CMP Handbook , the Poultry CMP Handbook , and a list of conservation managem ent practices were posted t o the same District site. In 2006, t he District prepared and publish ed 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 Repor t 6110.4F. Prepared for U.S. E PA. Retreieved from http://www.epa. gov/ttn/chief/efdocs/fugitivedus t.pdf
66 Slinn, W. “Predictions for Particle Depositions to Vegetative Canopies”, Atmospheric Environment, 16: 1785-1794, 1982.
67 Etyemezian, V. et al., Desert Re search Institut e (2003, Januar y) 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/San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-111 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard for 2005, 69 in which the District provided an explanation of the key compo nents of the CMP program and a deta iled summary of the pr ocess of identifyin g and quantifying the emission reductions achieved through December 31, 2005.

The District also posted a gui dance document entitled, San Joaquin Valley Air Pollution Control District Approval of New Cons ervation Management Practices (CMPs), 70 to the District web page in 2010. This doc ument outlines procedures f or the approval of new CMPs proposed by owners/operators to be used for compliance wit h the requirements of Rule 4550 conservation manag ement practices. In addition, D istrict Rule 4550 is brought up for discussion frequently in the AgTech Committee, w hich consists of various regulatory agencies, agric ultural industry representati ves, and university professors. The AgTech Commi ttee has evaluated proposed CMPs f or inclusion as part of the approved CMP list, including the promotion of conservati on tillage at Valley farms, misting to reduce PM10 generated by disking, and almond harvest ing techniques to reduce emissions.

 Conservation Tillage/Combined Operations Conservation tillage includes ty pes of tillage that reduce loss of soil and water in comparison to conventional till age. Benefits include the reduc tion of passes and soil disturbance and so il improvements becaus e it retains plant residue and increases organic matter. Examp les of conservation tillage inc lude converting to no or low till operations, implem enting reduced till activities , adding soil/water amendments to improve resources , and reducing tillage needs.

In the spring of 2008, EPA and USDA Agricultural Research Servi ce (ARS) in collaboration with the Distric t, NRCS, and other agencies/stake holders performed a study of conservation tillage/co mbined operations and demonst rated significant PM emission reductions from this p ractice. EPA completed the f inal report in June 2013. This report, including the merits of conservation t illage/combined operations were discussed in grea t detail in the AgTech meeting s 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 tw o crop categories consisting o f a “nontillage/chemical tillage” option . Non-tillage requires no dist urbance of soil and can achieve even more reduction s 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 “conservat ion tillage” is already an approved conservation management practice, if an ope rator chose this for the “other” mitigati on measure it would likely be appr oved.

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 Contro l District Approval of New Conservation Management Practices (CMPs) . Retrieved 2/2/2015 from http://www.valleyair.org/policies_per/Policies/SSP_3010.pdf

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

C-112 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard  CSUF Foundation Report: MISTING: A Conservation Management Prac tice 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 Duc t Control Unit manufactured by Diamond E. Manufacturing would reduce emis sions from disking. The final r eport was published in December 2011. In J anuary 2013, Diamond E. Manufa cturing requested that the Diamond E. Manuf acturing Dust Control Unit b e added to the official CMP list. A District review of the report indicated t hat it did not provide sufficient information to demons trate the minimum 10% reduction in PM10 emissions and therefore, was not added to the official CMP list . If sufficient information demonstrating that th e dust control unit achieves t he minimum PM10 reductions is provided in the fu ture, this measure would be all owed to be selected under the existing CM P category: Cropland – Land Preparation/Cultivat ion, Equipment changes/Technological Improv ements.

 Harvesting Equipment to Reduce PM Emissions from Almond Harvest Operations A study was performed in 2010 a nd 2011 by Texas A&M to evaluate a variety of improved almond harvesters and t heir ability to reduce PM emiss ions. A final report was published in January 2013 , demonstrating that the ne wer harvesters achieved significant PM emissi ons compared to their predecessor s. This specific measure was not added to the list o f conservation practices bec ause it was determined that using newer almond harvesters to reduce PM emis sions would be allowed under the existing CM P Category: Cropland-Harvest, E quipment Changes/Technological Improvements.

How does District Rule 4550 compar e with federal and state rule s and regulations? Federal requirements such as NS PS, NESHAP, MACT, CTGs, and ACTs and state regulations are not applicable to this source category.

How does District Rule 4550 compar e to rules in o ther air distr icts and states? The requirements and applicability of Rule 4550 were compared t o analogous rules in other air districts and states to determine th e stringency of R ule 4550 compared to those other rules. BAAQMD and VC APCD do not have rules that ar e analogous to Rule 4550.

SMAQMD

 Rule 215 (Agricultural Permit R equirements and New Agricultura l Permit Review): District Rule 4550 is a t least as stringent as if not more stringent than the analogous rule in SMAQMD.

SCAQMD

 SCAQMD has adopted agricultura l best management practices (BMP ) programs, which were approved by EPA as Bes t Available Control Measures ( BACMs); however, the District’s CMP rule exceeds these standards.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-113 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Imperial County Air Pollution Control District (ICAPCD)

 Rule 806 (Conservation Management Practices)

Imperial County APCD (I mperial) first adopt ed their Regulation VIII rules in 2005 to implement requirements designed to reduce the amount of PM10 en trained in the ambient air as a result of e missions generated from anthropogen ic fugitive dust sources. Rule 806 (Conservation Management Practices) is a par t of this set of rules. EPA did not approve the Regulation VIII rules as amendm ents to the state implementation plan (SIP) in J uly 2010. After a public process and mediation between Imperial and EPA, on Oct ober 16, 2012, a revised rule w as adopted with rule requirements effective on and after January 1, 2013.

Imperial Rule 806 requ ires one conservation practice from each of three categories (land preparation and cultivation , harvesting, and cropland-oth er), but the rule also specifies that if the owner or operator of an Agricultural oper ation site chooses to implement conservation tillage as a conservation practice, then that owner/operator does not need to select any additi onal conservation practices.

As stated earlier, the District’s CMP rule includes conservatio n tillage as a conservation management practice for nine out of the eleven cro p categories, listed as an option under Land Preparation/Cultiv ation and/or under th e Harvest section. The option to select conservation tillage is also available to all crops by program design because each of the three se ctions includes an “Other (a pproved on a caseby-case basis),” thus allowing c onservation tillage to be chose n as a conservation practice by any owner/operator . District Rule 4550 is more str ingent than Imperial Rule 806 where a Valley operator selects “conservation tillage” in one category, but still has to select two additional m easures, resulting in even more emission reductions. Therefore, requirement s in Rule 4550 are equivalen t, if not more stringent than Imperial Rule 806.

Arizona Department of Environmental Quality

 The Arizona Department of Envir onmental Quality adopted agricu ltural BMP
programs.

The Arizona Agricultural Bes t Management Practices Committee wa s established in 1998 by Arizona Revised Statutes ( A.R.S) §49-457 to research an d adopt BMPs for agricultural operations that gener ate dust. The BMPs are desig ned to reduce emissions of PM10 in the Maric opa County Serious PM10 nonattain ment area. In 2006, the Committee reconvened the Technical Workgroup to revie w the current use of BMPs in Maricopa County.

The Arizona rule is not applicab le to dairies, cattle feedlots, turkey ranches, chicken ranches, or chicken egg ranches . District Rule 4550 is more st ringent than the Arizona rule for these categorie s. With regards to measures sp ecific to agricultural crops, the measures offered as cons ervation practices in Arizon a are similar to the conservation practices offer ed within Distric t Rule 4550 and wo uld likely yield similar amounts of emission reductions.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-114 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Evaluation Findings EPA’s approval of Rule 4550 as BAC M and the District’s review o f similar rules in other regions demonstrate that the Dis trict has adopted the most stri ngent rule of its kind. Rule 4550 is more stringent than the Imperial rule and the Ariz ona rule, as both rules are not applicable to dairies, ca ttle feedlots, turkey ranches, broiler ranches, or layer hen ranches. With regards to mea sures specific to agricultural crops, the measures allowed as conservation practic es in Imperial County and Arizon a are similar to the conservation practices allowed under Rule 4550 and yield simila r amounts of emission reductions.

Given the relatively low contri bution that emissions from this category make to the Valley’s PM2.5 concentrations and current stringent requirement s under Rule 4550, the District has not identified any additional rule amendment oppor tunities for further emission reductions from source categories subject to CMP requi rements to include in this plan. As demonstrated above , Rule 4550 currently has in p lace the most stringent measures feasible to implement i n the Valley and therefore meet s or exceeds both BACM and MSM requirements fo r this source category.

Although Rule 4550 already meets BACM and MSM requirements, the District is committing to further evaluate Rule 4550 for additional opportu nities. See Chapter 8 (Commitment to Leave No Stone Unt urned to Evaluate Additional O pportunities) for more information.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-115 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.16 RULE 4692 COMMERCIAL CHARBROILING

Discussion Rule 4692 applies to chain-driven charbroilers used to cook mea t. The purpose of the rule is to limit volatile or ganic compound (VOC ) and PM10 emiss ions from commercial charbroiling. The rule also spec ifies administrat ive, recordke eping requirements, and test methods.

The original rule, adopted in M arch 2002, reduced PM2.5 emissio ns from chain-driven charbroilers by 84%. The Septem ber 2009 rule amendment expande d rule applicability to more chain-driven charbroile rs, reducing 25% of the remainin g PM2.5 chain-driven charbroiler emissions. EPA fi nalized approval for Rule 4692 on November 3, 2011. The District evaluated Rule 4692 in its 2009 Reasonably Available Control Technology Demonstration for Ozone State Impl ementation Plans (2009 RACT SIP) ; however, EPA noted in its Technical Support Doc ument (TSD) for the approval of Rule 4692 that the rule is not subject to RACT becau se it is not subject to CTG re quirements and it does not regulate major sources.

Source Category There are two types of commercial charbroilers: chain-driven an d under-fired. A chaindriven charbroiler is a semi-enc losed broiler that moves food m echanically through the device on a grated grill to cook t he 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 elem ents, or wood under the grid to c ook the food. The smoke and vapors generated by cooking on either type of charbroiler c ontain water, VOCs, and PM. Larger particles and grease are typically captured by the grease filter of the ventilation hood over the charbroi ler. The remaining VOCs and PM2.5 are exhausted outside the restaurant, unless a secondary control is installed

. Currently, District Rule 4692 r educes emissions by requiring ca talytic oxidizers for chain-driven charbroilers that meet rule applicability threshol ds. Charbroiler exhaust is directed through the catalytic ox idizer with little loss of tem perature. As hightemperature exhaust goes thr ough the heated catalyst, PM and VO C are oxidized to carbon dioxide and water vapor. T his chemical reaction release s energy that heats the catalyst and is transferred to a heat recovery system, so no ad ditional fuel is needed for the unit. Controlling emissions fr om under-fired charbroilers has proven to be far more challenging. To date, no cost e ffective technologies have been demonstrated.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-116 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 2.84 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 f ederal and state rules and reg ulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, N ESHAP, or MACT requirements f or this source category.

State Regulations There are no state re gulations applicable to this source catego ry.

How does Rule 4692 compare to rul es 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 require ments contained within SCAQMD ’s Rule 1138 and found no requirements that were more stringent than those alrea dy in Rule 4692.

BAAQMD

 Regulation 6 Rule 2 (Comme rcial Cooking Equipment)

BAAQMD Regulation 6 Rule 2 regulat es both chain-driven and unde r-fired units. Newly installed under-fired units with more than 10 square feet of co oking area are required to limit emissions to 1 lb of PM 10 per 1,000 lbs of cooked beef. Effective January 2013, the same emissions requirements al so apply to pre-existing unit s. However, as the BAAQMD rule is implemented, a si gnificant portion of under-fire d charbroilers are below the applicability thresholds for grill size or amount of food c ooked, 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 46 92 are lower than those in BAAQMD Regulation 6 Rule 2. Theref ore, because BAAQMD Regulati on 6 Rule 2 is not currently being enforced for under-fired charbroilers, Dist rict Rule 4692 is effectively more stringent. Additionally, the District committed in the 2012 PM2.5 Plan to amendSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-117 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Rule 4692 in 2016 to expand appli cability to include under-fire d 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 require ments contained within VCAPCD ’s Rule 74.25 and found no requirements that were more stringent than those alrea dy in Rule 4692.

Additional Emission Reduc tion Opportunities

Chain-Driven Charbroilers Rule 4692 requires emission cont rols for chain-driven charbroil ers that cook 400 pounds of meat or more per week. In 2009, the amended rule was estima ted to apply to about 280 of the 427 chain-driven identi fied charbroilers of the Vall ey. 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 appli cability threshold for chain-driven charbroilers under R ule 4692 could be lowered to m ake smaller facilities subject to the rule. However, these currently-exempt chain-dri ven units are a very small portion of the total inventory for this category. Emissions re ductions 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 req uire emissions controls for und er-fired charbroilers. Catalytic oxidizers are not eff ective for reducing emissions fr om under-fired charbroilers because the exhaust from these dev ices loses too much heat as i t is directed to the control device, and the reactions at the catalyst cannot take p lace under this lower temperature. The following contro l strategies are more effecti ve for under-fired charbroilers:

 High efficiency particulate-arr esting (HEPA) filtration systems : This system adds a HEPA filter to the appliance’ s existing grease filters t o 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. Th ese ionized particles are then collected by one of two oppositely-charged p lates. ESP systems need filtration prior to the ESP itself to remove greas e and larger particles from kitchen exhaus t. These devices are cleaned dail y with a clean-inplace system, and more thorough cl eaning is required once or tw ice a year. Routine maintenance often requi res hiring an outside company, s ince the ESP plates can weigh as much as 75 pounds.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-118 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard  Wet scrubbers: A fine stream of water and deter gent “washes” the particulates from the kitchen exhaust. The parti culate/water/detergent mix is then filtered; the filtered water/detergent mix is recycled through to clean m ore exhaust, and the particulate-laden wash water is discharged to the sewer sys tem. In addition to the cost of the system itself, associated water/sewer usage costs and detergent costs can be high, although recent improvements in de sign are improving system efficiencies.

These controls for under-fired charbroilers were unproven and e xtremely costly during the District’s 2009 amendment of R ule 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 pe r ton of PM2.5 reduced. Howev er, 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 demonstra tion efforts. Since under-fired charbroilers are a lar ger part of the total commerc ial charbroiling inventory, and since these units are curr ently unregulated in the Valley, there is potential to achieve emissions reductions fr om under-fired charbroilers.

In parallel with this plan, SCA QMD has also included a draft co mmitment 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 b e determined. 71 SCAQMD would submit their approach into the SIP once technically feasi ble and cost effective options are confirmed.

The District created and implemen ted a pilot program in 2009, t he Charbroiler Incentive Program (ChIP), to provide grant funding to cover a significant portion of the cost of installing particulate control devices on under-fired charbroil ers. However, there was no stakeholder interest in this pr ogram and no projects were funde d under ChIP. The District released a Request for Qua lifications (RFQ) for its Re staurant Charbroiler Technology Partnership (RCTP) i n 2014 and received several appl ications that were approved to move forward with the contracting process. Multipl e projects are still in the contracting phase and the Distric t expects to begin demonstrati on of some of the above described control tec hnologies by mid-2015.

The District has also been tra cking and involved with technolog y demonstration projects for under-fired charbroilers at o ther agencies, including testi ng of control technologies for under-fired charbroilers at Uni versity of California at Riv erside’s Center for Environmental Research and Tec hnology (CE-CERT). This program began in early 2012 and several tests were compl eted in early 2014. Additiona l tests are ongoing.

According to estimates submitt ed 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 cost s will range from a few thousand dollars to tens of thousands of dollars. As such, i t is yet to be seen whether an y cost effective and

71 SCAQMD. (2012). Draft 2012 AQMP . Retrieved from http://aqmd.gov/aqmp/2012a qmp/draft/Chapters/Ch4.pdfSan Joaquin Valley Unified Air Polluti on 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 identifie d and demonstrated in the next few years. However, as par t of the 2016 rule amendment pr ocess, the District will examine all potentia l opportunities for further emissions reduc tions.

Evaluation Findings The District has evaluated all c ontrol technologies achieved in practice in other areas or included in other state implem entation plans. As demonstrated above, Rule 4692 currently has in place the mos t stringent measures feasible to implement in the Valley at this time and therefore meets or exceeds both BAC M and MSM requ irements for this source category.

Rule 4692 achieves signific ant emissions reductions from chain- driven charbroilers; however, the rule does not require emissions controls for under -fired charbroilers. Analyses indicate that extendi ng the applicabilit y of the rule to include under-fired units could further reduce PM2.5 emissi ons by as much as 20% (0.4 tpd PM2.5) from the baseline inventory for under-fir ed charbroilers upon implementa tion in 2017, thus providing significant health benefits Valley-wide per the Distr ict’s Health Risk Reduction Strategy. Research and demonstrat ion projects are underway to evaluate emission control technologies for under-fir ed charbroilers in support of this measure. As included in the 2012 PM2.5 Plan

, the District will amend Rule 46 92 in 2016 to add requirements for under-fired charbroilers, wit h an anticipated compliance da te of 2017. The District will also consider development of a new incentive program to as sist in the deployment of new technologies upon their development and commercial avail ability.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-120 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.17 RULE 4702 INTERNAL COMBUSTION ENGINES

Discussion Rule 4702 applies to any inter nal combustion (IC) engine rated at 25 brake horsepower (bhp) or greater. The purpose of th is rule is to limit NOx, ca rbon 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 Com bustion Engines – Phase 1), was adopted on May 21, 1992 , superseded by Rule 4702, adopt ed 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-agricultura l operations rich-burn engines and 65-75 ppmv achievi ng 85-90% control for non-agricul tural operations leanburn engines. In its continuous e ffort to improve air quality in the Valley, the District has adopted numerous amendments to Rul e 4702 that have resulted in significant reductions of NOx and PM emissions.

Substantial emission reductions fr om agricultural IC engines ha ve also been achieved through a combination of regulator y efforts and incentive actio ns. Rule 4702 has effectively reduced emissions fr om agricultural engines by 84% since the 2005 amendments to the rule, with subst antial investm ents being made by the affected sources to comply with the rule . The rule was further strength ened in August 2011 when rule amendments implemented more stringent NOx limits as l ow as 11 ppmv for non-agricultural operations spar k-ignited engines. Additional emission reductions are forthcoming under Rule 4702 as com pliance dates for emission co ntrol requirements continue to approach ov er the coming years.

Source Category An internal combustion engine is any engine that operates by bu rning its fuel inside the engine. Engines generate power by the combustion of an air/fue l mixture. The main types of engines are spark-igni ted engines and compression-igni ted (or diesel) engines. In the case of spark-ignited engi nes, 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 nat urally aspirated. Spark-ign ited engines may use one or more fuels, such as nat ural gas, propane, butane, liquef ied petroleum gas, oil field gas, digester gas, landf ill gas, methanol, ethanol, and g asoline.

Compression-ignited engines rely on heating of the inducted air during the compression stroke to ignite the injected diesel fuel. In addition to bein g classified into compressionignited and spark-ignited, IC engines can be further divided in to two-stroke and fourstroke engines. Most diesel engines are four-stroke, while lar ger diesel engines often are two-stroke. Natural gas fir ed spark-ignited engines are us ually four-stroke, but some operators prefer two-stro ke engines for their applications

.
Engines are used by a variety o f private busine sses and public agencies throughout the Valley for a number of purposes, p rimarily for powering pumps, compressors, or electrical generators. Examples of businesses and industries t hat use engines include schools and universities, agric ulture, oil and gas production a nd pipelines, petroleumSan Joaquin Valley Unified Air Polluti on 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 facilitie s, food processing, electrical power generation, landfill and waste water treatment facilitie s, and water districts. Man y engines are limited or low use in nature, such as e mergency standby engines that provi de 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 si gnificance threshold for source categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts is 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from I C engines are lower than the B ACM/MSM significance thresholds. Therefore, the Clean Air Act does not require a co ntrol measure evaluation for this source category for t he purpose of satisfying BACM/MSM requirements; however, the District has still co nducted a full control measur e evaluation for IC engines.

How does District Rule 4702 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA Control Techni que Guidelines (CTG) requirement s for this source category. Rule 4702 is at leas t as stringent as the following applicable federal regulations:

ACT

 EPA – 453/R-93-032 (Alter native Control Techniques Document – NOx Emissions from Stationary Reciprocating Internal Combustion Engines)

The District evaluated the requi rements contained within the EP A – 453/R-93-032 ACT document and found no requirements that were more stringent tha n those already in Rule 4702.

NSPS

 40 CFR 60 Subpart IIII (Standards of Performance for Stationar y Compression Ignition Internal Combustion Engines)San Joaquin Valley Unified Air Polluti on 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 require ments contained within 40 CFR 60 Subpart IIII and found no requirements that were more stringent than those alrea dy in Rule 4702.

 40 CFR 60 Subpart JJJJ (Standards of Performance for Stationar y Spark Ignition Internal Combustion Engines)

The District evaluated the require ments contained within 40 CFR 60 Subpart JJJJ and found no requirements that were more stringent than those alrea dy in Rule 4702.

NESHAP/ MACT

 40 CFR 63 Subpart ZZZZ (NESHAP for Stationary Reciprocating In ternal Combustion Engines)

The District evaluated the require ments 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 Part iculate Emissions from Diesel -Fueled Engines—Standards for Nonv ehicular Diesel Fuel)

 17 CCR 93115 (ATCM for Stationar y Compression Ignition Engines )

The District implements the r equirements of 17 CCR 93114 and 17 CCR 93115 through Rule 4702 and the District’s new source review permitting progr am (Rule 2201).

How does District Rule 4702 compar e to rules in o ther air distr icts?

BAAQMD

 Regulation 9 Rule 8 (Nitrogen Ox ides and Carbon Monoxide from Stationary Internal Combustion Engines)

The District evaluated the requi rements contained within BAAQMD ’s Regulation 9 Rule 8 and found no requirements that w ere more stringent than those already in Rule 4702.

SMAQMD

 Rule 412 (Stationary Internal C ombustion Engines Located at Ma jor Stationary Sources of NOx)

The District evaluated the require ments contained within SMAQMD ’s Rule 412 and found no requirements that were more stringent than those alrea dy in Rule 4702.

VCAPCD

 Rule 74.9 (Stationary Internal Combustion Engines)San Joaquin Valley Unified Air Polluti on 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 require ments contained within VCAPCD ’s Rule 74.9 and found no requirements that were more stringent than those alrea dy in Rule 4702.

SCAQMD

 Rule 1110.2 (Emissions from Gas eous- and Liquid-Fueled Engines )

 Rules 2000 – 2020 (RECLAIM program)

South Coast Air Quality Managemen t District (SCAQMD) regulates the emissions from IC engines through a combination o f control measures. SCAQMD 1 110.2 is directly applicable to IC engines and inclu des emissions limitations for various applications. SCAQMD’s RECLAIM program (Ru les 2000 – 2020) allows most operat ors to purchase credits in lieu of instituting engine emissions controls otherw ise required under SCAQMD 1110.2. Given these overl apping sets of requirements, Rule 4702 must be compared in context of both r egulations. Additionally, many of the engine applications found in the San Joaquin Valley v ary substantially from engine applications in SCAQMD; for example, engines used for agricultural irrigation p umping that exist in the Valley and are no long er found in SCAQMD. While not directly c omparable, the following tables compare the em ission limits between SCAQMD Rul e 1110.2 and District Rule 4702.

Table C-19 Comparison of Distric t and SCAQMD NOx Emission Limit s for NonAgricultural Operations (Non-AO) Spark-Ignited Waste Gas Engine s 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 ECF 72 bhp < 500: 45 x ECF 1

On and after 01-01-16 11 ppmv

Waste Gas Fuel ed (Lean-Burn) 65 ppmv or 90% reduction Until 01-01-16 bhp ≥ 500: 36 x ECF 1 bhp <500: 45 x ECF 1

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 Co de PTC 17 -1973, at the average load of the engine; and 2) the ECF-corrected emission limit is made a condi tion of the engine’s permit to operate. The ECF is never less than 1.0 so in some ca ses the SCAQMD limits could po tentially be less stringen t than the District’s NOx limits.San Joaquin Valley Unified Air Polluti on 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 Distric t and SCAQMD NOx Emission Limit s 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 11 73 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 11 2 Lean-Burn Engine used for gas compression 65 ppmv or 93% reduction 11

Table C-21 Comparison of Distric t and SCAQMD NOx Emission Limit s for Agricultural Operations (AO) Spar k-Ignited Engines Rated >50 bh p (corrected to 15% oxyg en 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 th e South Coast Air Basin are mos t likely part of the South Coast RECLAIM program and are subsequently not required t o meet the engine emission limitations included in Rule 1110.2. All facilities t hat emit over a certain threshold are required to parti cipate in the RECLAIM program. As part of the RECLAIM program certain companies receive emission allocations every ye ar and each allocation is good for 12 months. The por tion of the allocation not neede d to offset the operator’s own emissions can be sold to oth er companies. If the operator does not receive an emission allocation, they must b uy emission credits from operat ors with unused emission allocations. In this way , the RECLAIM program is simi lar 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 l imitations included in Rule 4702.

73 SCAQMD exempt units that operat e less than 500 hours from this limit; District defines “li mited use” units as those operating less than 4, 000 hours and only e xempts engines operat ing less than 200 hours.San Joaquin Valley Unified Air Polluti on 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 lev el of 11 ppm has not yet been p roven as technologically feasible in agr icultural settings and it is unc lear what percentage of facilities are complying with t he current SCAQMD NOx limits for non-ag categories, the District evaluated the cost-effe ctiveness and feasibility of im plementing an 11 ppmv NOx emission limit for the follo wing 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 t he cost-effectiveness and feasibil ity of implementing intermediate NOx emi ssion limits for AO spark-ignited engines t hat more closely match the current NOx emission limits for non-AO limited use rich-bur n and lean-burn engines. The following analyses were conducted:

 25 ppmv NOx emission limit for AO Rich-Burn Spark-Ignited Engi nes

 65 ppmv NOx emission limit for AO Lean-Burn Spark-Ignited Engi nes

To determine potential emissi ons 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 emi ssions 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 usi ng the following equation:

Potential Emissions Reduction = current annual NOx emissions – potential NOx annual NOx emissionsSan Joaquin Valley Unified Air Polluti on 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 technologi cal 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 existi ng waste gas engines can pose si gnificant technical and feasibility challenges. Waste gas includes landfill gas, which is generated at landfills, and digester gas, which is generat ed from anaerobic digestion. Both landfill and digester gas result from the dec omposition of organic matter by microorganisms in the absence of oxygen. Unlike pipeli ne natural gas, the compositio n of waste gas is not consistent or guaranteed. The heat ing value and composition of the gas (e.g. methane and oxygen contents) will vary wit h the type of materials that enter the landfill or digester and can also fluctuat e seasonally or even daily. Both landfill and digester gases contain impurities, such as siloxanes, sulfur compounds, and halides. Landfill gas also contains entrained parti culate matter, and both landfi ll and digester gas may contain particulate that results from combustion of the impurit ies in the gas. The contaminants in waste gas can c oat and/or poison catalysts, ren dering them ineffective. Because of its var iable composition and contamina nts, untreated waste gas is not interchangeable with pipe line-quality natural gas and ex tensive and costly cleanup would be necessary to allo w the use of catalytic emissi on controls needed to achieve 11 ppmv. This is not a p ractical option for most exist ing waste gas-fired engines, which were not designed to include the required gas sy stems and catalytic controls.

In addition to the District’s e fforts to identify additional po tential technology options for this category, SCAQMD has also been evaluating this issue. In February 2008, SCAQMD amended Rule 1110.2 to i nclude an 11 ppmv limit for wast e gas engines rated at >50 bhp. The original c ompliance date for this emissi ons limit was July 1, 2012, with the assumption that SCAQMD would complete a Technology Ass essment to verify the feasibility of available cont rol 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 fr om 2012 to 2016 in order to al low for more time to complete their Final Technology Assessment, which is currently still incomplete and has yet to identify feasible technology options. Additionally, the se sources may also be in a position to avoid installing ad ditional NOx control technologie s through their participation in SCAQMD’s RECLAIM program.

District Rule 4702 contains the mo st stringent limits feasible for existing waste gasfueled engines based on the use of combustion processes that mi nimize emissions without the use of post-combusti on catalytic controls. Therefo re, Rule 4702 meets or exceeds BACM and MSM for non-AO w aste gas fueled spark-ignited engines. Additionally, the District conti nues to investigate potential N Ox and SOx control technologies for waste gas engi nes through its Technology Advan cement Program, with projects currently approved for funding that will continue to d emonstrate new technologies in this sector.San Joaquin Valley Unified Air Polluti on 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 Limitati on for Non-AO Spark-Ignited Engines:

Cyclic Loaded, Field Gas Fueled Cyclic-loaded, field gas fueled engi nes can achieve some level of control, but not the stringent level of control that c an be imposed on engines that operate in a narrow and more stable range of loads. The ex haust gas temperature of cyc lic loaded engines varies as a function of the engi ne load; however, catalyst chem istry is dependent on a minimum temperature to be effe ctive in reducing emissions. Whe n the cyclic load engine is operating in a parti cular engine load range, the exha ust gas temperature can reach the catalyst’s effecti ve range and allow for emissions to be well-controlled; however, as the engine cycles ou t of this load range, the exhau st gas temperature becomes too low for effective em issions control. Since the exh aust temperature fluctuates frequently for this c ategory of units, it is technol ogically infeasible to require a lower NOx limit for cyclic loa ded field-gas fueled engines. Th e current emission limit for this category of engines meets or exceeds BACM and MSM for thes e sources.

Limited Use Engines During the 2011 amendments to Rul e 4702, the District created t his category of engines based on the high costs and cost effectiveness associated with the installation of additional controls for these engi nes (> 4,000 hours of operati on). As discussed in the staff report, t he NOx emission reductions foregone from not low ering the existing NOx limits to 11 ppmv for limited us e engines was insignificant (ab out 0.004 tons per day in 2011). 74

However, since the evaluation was conducted in 2011, the Distri ct re-evaluated the cost effectiveness of lowering the NO x emission limits to 11 ppmv fo r limited use non-AO rich-burn and lean-burn engines . The costs in the analyses bel ow were gathered from information in the District’s Permits database, IC engine manuf acturers, and operators.

Limited Use Lean-Burn Engines When evaluating the ability to l ower NOx emissions to 11 ppmv, an operator can either retrofit the existing lean-burn IC engine with a selective cata lytic reduction (SCR) system or install a new lean-burn engine wit h an SCR system. I n many cases, retrofitting an existing IC engi ne is technologically infeasibl e or may require substantial additional unanticipated costs (such as the in compatibility of an older engine with less sophisticated operating controls with additional control techno logy, additional labor/maintenance costs, etc.). However, for the purpose of ev aluating all potential controls, the District has inclu ded both options in the below a nalysis.

74 SJVAPCD. (2011, August 18). Adopt Revised Proposed Amendments to Ru le 4702 (Internal Combustion Engines). Retrieved from http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agend a/2011/August/Agenda_Item_10_Aug_18_2011. pdfSan Joaquin Valley Unified Air Polluti on 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 Retro fitting an Existing Limited Us e Lean-Burn Engine and Installing a New Limite d Use Lean-Burn Engine with S CR
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, i nstallation, start-up, additional equipment (bel t 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 Equipm ent costs x 20% profit/mark-up $100,974 SCR Installation Costs Start-up and Commissioning Rate $1,500/day; assume 1 day f or each system $1,500
Electrical upgr ade to power
compressor n/a $0
Total SCR Installation Costs $1,500 Total SCR Capital Costs SCR Equi pment 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 standa rd 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 indust rial 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 = dail y meter charge x 365 days Total utility cost = Annual electricity cost + Annual meter charge $18,728San Joaquin Valley Unified Air Polluti on 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 Maintena nce = $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 (equiva lent to 65 ppmvd NOx at 15% O2; assuming 35% thermal efficiency) EF2 = 0.132 g-NOx/bhp-hr (equival ent 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/y r 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/y r 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 Reduc tion = 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 reducti ons achieved, in tons per year. Based on the calculations above, the cost eff ectiveness of retrofitting or r eplacing current limited use lean-burn spark-ignite d 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 reducedSan Joaquin Valley Unified Air Polluti on 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 co st effective to require the retrofit or replacement o f limited use lean-burn engines to achieve 11 ppmv.

Limited Use Rich-Burn Engines When evaluating the ability to l ower NOx emissions to 11 ppmv, an operator will generally retrofit the existing rich-burn IC engine with a nons elective catalytic reduction (NSCR) system. In many cases, r etrofitting an existing IC engi ne is technologically infeasible or may require subs tantial additio nal unanticipated costs (such as the incompatibility of an older engine with le ss sophisticated oper ating controls with additional control technology, add itional labor/maintenance cos ts, etc.). However, for the purpose of evaluat ing potential controls in this category, the District has included the less costly, potentially feasible scenario of retrofitting an e xisting rich- burn engine with NSCR in the below analysis.

Table C-23 Annual Costs for Retro fitting an Existing Limited U se 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 (equiva lent to 25 ppmvd NOx at 15% O2; assuming 35% thermal efficiency) EF2 = 0.132 g-NOx/bhp-hr (equival ent 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 Polluti on 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 reducti ons achieved, in tons per year. Based on the calculations above, the cost eff ectiveness of retrofitting or r eplacing current limited use rich-burn spark-ignite d engines is as follows:

 Retrofitted limited use rich- burn non-AO engine with new catal yst: $66,015/ton of NOx reduced

As demonstrated in the analysis and summary above, it is not co st effective to require the retrofit or replacement o f limited use rich-burn engines to achieve 11 ppmv, even without including additional substa ntial costs, such as annual operating and maintenance costs.

Two-Stroke, Gaseous Fueled Engines 50-100 bhp There is no control technology co mpatible with two-stroke, gase ous fueled engines, including SCR, which will allow these units to achieve a NOx em ission limit below 75 ppmv. An 11 ppmv NOx emission limit is not technologically fea sible for these engines; the current limit imp lements BACM and MSM fo r two-stroke, gaseo us fueled engines less than 100 bhp.

Lean-Burn Engines Used in Gas Compression Similar to the “Limited Use” engine category, during the 2011 a mendments to Rule 4702, the District created this c ategory of engines based on th e technological infeasibility to control t hese types of engines. Lean-burn eng ines used in gas compression in the Valley are us ed in natural gas distribution and storage service, and these engines frequently experienc e changing load conditions. As noted in EPA’s Stationary IC Engine T echnical Support Document 75 , SCR use is problematic for these engines due to the fluctuations over a broad range of condition s. For this reason, EPA states that there is an insuffi cient basis to conclude that SCR is an appropriate technology for large lean-burn engi nes used for gas compression . The current emission limit is achievable through low- NOx combustion technology, whic h includes changes to the engine’s timing, enhanced cont rol of the air-fuel ratio, an d other changes that lower NOx emissions. Due to the technolog ical complexities associate d with lean-burn engines used in gas compression , the current emissions limit im plements BACM and MSM for these units.

75 EPA. (2003, October). Stationary Reciprocating Internal Combusti on Engines Technical Support Document for NOx SIP Call

.San Joaquin Valley Unified Air Polluti on 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 Limita tion for AO Spark-Ignited Engines:

Potential methods for reducing NO x emissions from Agriculture O peration (AO) sparkignited engines inclu de retrofitting them with emission control technologies or replacing them. As the below analysis dem onstrates, given the high costs and limited seasonal nature of operation of AO spar k-ignited engines, requiring addi tional controls beyond the existing stringent requirement s is not cost-effective and o ften technologically infeasible. Despite the technological feasibility issues asso ciated with retrofitting or replacing existing AO spark-i gnited engines, the District evalu ated the cost effectiveness and feasibility o f achieving an 11 ppmv NOx emiss ion limit for the following scenarios:

 Installing a new IC lean-burn engi ne with SCR as a replacement for an existing unit

 Retrofitting an existing l ean-burn IC engine with SCR

 Installing a new rich-burn engine with a three-way catalyst sy stem as a replacement for an existing unit

The District also evaluated the cost effectiveness and feasibil ity of achieving intermediate NOx emi ssion limits of 25 ppmv for AO rich-burn sp ark-ignited engines and a 65 ppmv for lean-burn spark-i gnited engines, similar to the c orresponding limited use engine limits for non-AO engines . The scenarios evaluated inc lude:

 Installing a new IC lean-burn engine as a replacement for an e xisting unit to meet 65 ppmv

 Installing a new rich-burn engine with a three-way catalyst sy stem as a replacement for an existing unit to meet 25 ppmv

The costs in the analyses below w ere gathered from information in the District’s Permits database, IC engine manufacturers, and agricultural industry re presentatives.

AO Lean-Burn Engines (11 ppmv) When evaluating the ability to l ower NOx emissions to 11 ppmv, an agricultural operator can either retrofit the existi ng lean-burn IC engine with a sel ective catalytic reduction (SCR) system or install a new lean-burn engine with an SCR syst em.San Joaquin Valley Unified Air Polluti on 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 Retro fitting an Existing AO Lean-Bu rn Engine with SCR and Installing a New A O 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, i nstallation, start-up, additional equipment (bel t 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 Equipm ent costs x 20% profit/mark-up $100,974 SCR Installation Costs Start-up and Commissioning Rate $1,500/day; assume 1 day f or each system $1,500
Electrical upgr ade to power
compressor $43.22/foot; avg. 1,020 feet to e xtend electrical line $44,084
Total SCR Installation Costs $45,584 Total SCR Capital Costs SCR Equi pment 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 standar d 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 Maintena nce = $0.02 per bhp per hour of operation Annual cost = $0.02 x 241 bhp x 2500 hr $12,050San Joaquin Valley Unified Air Polluti on 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 Reduc tion = 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 reducti ons achieved, in tons per year. Based on the calculations above, the cost eff ectiveness of retrofitting or r eplacing current AO leanburn spark-ignited en gines is as follows:

 Retrofitted lean-burn engine wi th SCR: $55,118/ton of NOx redu ced

 New lean-burn engine with S CR: $76,209/ton of NOx reduced

In addition to the unique feasibi lity issues that AOs face with regards to the installation and maintenance of IC engines (s ee below), the cost effectivene ss values above demonstrate that it is not cost e ffective to retrofit or replac e existing AO lean-burn engines with new more controlled engines.San Joaquin Valley Unified Air Polluti on 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 l ower NOx emissions to 65 ppmv, an agricultural operator would have to replace the existi ng lean-burn IC engine with a n ew lean-burn engine certified to meet 65 ppmv.

Table C-25 Annual Costs for Inst alling a New AO Lean-Burn Engi ne 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, i nstallation, start-up, additional equipment (bel t 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 b hp 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 Reduc tion = 0.57 tons/yearSan Joaquin Valley Unified Air Polluti on 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 reducti ons achieved, in tons per year. Based on the calculations above, the cost eff ectiveness 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 feasibi lity issues that AOs face with regards to the installation and maintenance of IC engines (s ee below), the cost effectivene ss value above demonstrates that it is not cost e ffective to replace existing AO lean-burn engines with newer less polluting engines.

AO Rich-Burn Engines (11 ppmv) When evaluating the ability to l ower NOx emissions to 11 ppmv, an agricultural operator can install a new rich-burn engi ne with 3-way catalyst.

Table C-26 Annual Cost for Insta lling a New AO Rich-Burn Engin e 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: engi ne 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 Maintena nce = $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 $30,770San Joaquin Valley Unified Air Polluti on 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 Reduc tion = 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 reducti ons achieved, in tons per year. Based on the calculations above, the cost eff ectiveness of replacing current AO rich-burn engines is as follows:

 New rich-burn engine with a 3-wa y catalyst to meet 11 ppmv: $5 9,754/ton of NOx reduced

In addition to the unique feasibi lity issues that AOs face with regards to the installation and maintenance of IC engines (s ee below), the cost effectivene ss 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 Polluti on 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 Insta lling a New AO Rich-Burn Engin e 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: engi ne 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 Maintena nce = $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) / 453.6San Joaquin Valley Unified Air Polluti on 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 Reduc tion = 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 reducti ons achieved, in tons per year. Based on the calculations above, the cost eff ectiveness of replacing current AO rich-burn engines is as follows:

 New rich-burn engine with a 3-wa y catalyst to meet 25 ppmv: $6 9,521/ton of NOx reduced

In addition to the unique feasibi lity issues that AOs face with regards to the installation and maintenance of IC engines (s ee below), the cost effectivene ss values above demonstrate that it is not cost e ffective to replace existing A O spark-ignited engines with new controlled engines.

Other Feasibility Considerati ons AO Spark-Ignited Engines In addition to the high cost-effe ctiveness and pot ential infeas ibility associated with retrofitting or replacing existi ng AO spark-ignited engines cur rently regulated under Rule 4702, requiring additional costly c ontrols on AO engines is eco nomically 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 capita l to retrofit and replace thous ands of irrigation pump and other engines reducing emissions by over 80% in this category, and continue to do so as emission limitations and asso ciated complianc e deadlines mat erialize 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 staff ing. With seasonal labor and minimal year-round staffing, i t is difficult for AOs to pro vide the frequent and complex maintenance required for retrofitted or new engines equ ipped with advanced emission controls. The oil produ ction industry is the only oth er major industry in the Valley that has IC engines located in remote locations; however , with the highly technical nature of oil producti on and refining as compared to agricultural production and additional economic resources , it is feasible for the oil a nd gas production industry to hire qualified staff dedicat ed to maintaining and operating IC engines and other equipment on-site.San Joaquin Valley Unified Air Polluti on 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 Re duction Opportunities

SOx and PM limitations Rule 4702 contains stringent requ irements requiring the combust ion 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 engi ne and the annual operating ho urs. 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 thr ough the use of particulate fil ters. Given the low PM2.5 and SOx emissi ons from IC engines and existing rule requi rements, the District determined that no further requi rements were needed to address PM2.5 and SOx emissions.

Emission limitation exemptions f or emergency standby engines an d low-use engines The existing requirements are cons istent with Air Resources Boa rd (ARB) RACT/BARCT Determination for Spar k-Ignited Engines and ARB Airb orne Toxics Control Measures (ATCM). Since these units are used only for e mergencies or in very limited capacities, emissions from these units are relatively m inor, and requiring additional emissions controls wou ld likely not be cost effectiv e.

Non-Regulatory Actions The District implements a stati onary agricultural irrigation pu mp 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 a nd PM-emitting Tier 4 engines and for the electrificat ion of diesel engines, as the D istrict highly prioritizes electrification efforts to ach ieve zero and near-zero emissions from engines. The District’s legislative platform 76 includes support for incentive funding through the Carl Moyer Program. Continued sup port of this funding stream will c ontinue to provide incentives for accelerated reductions from IC engines.

Meeting air quality standards requires transformative measures and technologies to achieve near zero emissions. In o rder to further develop techn ology to close the gap in required emissions reductions, t he District operates a Technolo gy Advancement Program (TAP). Along with its own resources, the District seek s state and federal assistance through its legislativ e platform to advance technolo gies to reduce emissions in the Valley. District TAP proj ects seek innovations in sever al areas of technology including IC engines. While no technologies to reduce emission s from IC engines have been achieved in practice yet, thes e projects may provide the b asis for future feasible, SIP-creditable emission reductions.

76 SJVAPCD. (January 2015). Legislative Platform 2015. http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agend a/2015/January/final/10.pdfSan Joaquin Valley Unified Air Polluti on 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 s ignificant source of PM2.5 or SOx in the Valley, the District has evaluated all potentia l control technologies and a ll control technologies achieved in practice in other ar eas or included in other state implementation plans. As demonstrated above, Rule 4702 curr ently has in place the most s tringent measures feasible to implement in the Va lley and therefore meets or exce eds both BACM and MSM requirements for this sour ce category. As the District con tinues to develop new attainment plans that address mo re stringent National Ambient A ir Quality Standards, the District will continue to e valuate potentia l opportunities to reduce NOx emissions from IC engines in the Valley.San Joaquin Valley Unified Air Polluti on 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 ar e applicable to all stationary ga s turbine systems, which are subject to District permitting r equirements, and with electrica l generation ratings equal to or greater than 0.3 megawatt ( MW) or a maximum heat input ra ting of more than 3 million British Therma l Units per hour (MMBt u/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 r ule amendment in September 2007 strengthened the rule by establishing more stri ngent NOx limits for existing sta tionary gas turbines. EPA finalized approval for Rule 4 703 on October 21, 2009 and deemed this rule as being at least as stringent as established RACT requirements. NOx emiss ions have been controlled by over 86% for this source category.

Source Category The requirements of Rule 4703 af fect owners and operators of st ationary gas turbine systems used to pump, compress, generate electricity, or perfor m other tasks. The four major industry groups are oil and gas production, utilities, ma nufacturing, and government.

In complying with the rule, all affected entities are required to control NOx and CO emissions by installing approved emissions control devices. Ea rly in the rule development process, the District identified five different emi ssions control technologies that could be used to achieve p roposed limits for stationary ga s turbines. Of the five options, four mainly control NO x emissions, while the other one controls CO emissions. The four NOx control technologies are:

 Dilutant (water or st eam) injection systems,

 Dry, low-NOx,

 Selective catalytic reduction, and

 SCONOx

Costs associated with different c ompliance options vary a great deal depending on technologies and avail able products. Depen ding on the size of the existing turbine systems, engine model and make, ty pe of existing emissions cont rol equipment, and many other factors, owners and operators of stationary gas turb ine systems face different compliance costs. T he impacts of Rule 4703 have been concentrated in the oil and gas production sector and utilities sect or of the Valley, a s they own and operate the vast majority of stationary gas turbines subject to the rule.San Joaquin Valley Unified Air Polluti on 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from s tationary gas turbines are low er than the BACM/MSM significance thresholds. Theref ore, the Clean Air Act does not require a control measure evaluation for this sour ce category for the purpose of satisfying BACM/MSM requirements; however, the Distr ict has still conducted a full control measure evaluation for stationary gas turbines.

How does District Rule 4703 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG requirements for this source category.

ACT

 EPA–435/R-93-007 (Alternative Cont rol Techniques Document—NOx Emissions from Stationary Gas Turbines)

The District evaluated the requi rements contained within the AC T for NOx Emissions from Stationary Gas Turbines a nd found no requirements that wer e more stringent than those already in Rule 4703.

NSPS

 40 CFR 60 Subpart GG (Standards of P erformance for Stationary Gas Turbines)

The District evaluated the require ments contained within 40 CFR 60 Subpart GG and found no requirements that were more stringent than those alrea dy in Rule 4703.

 40 CFR 60 Subpart KKKK (Standard s of Performance for Stationar y Combustion Turbines)

The District evaluated the requi rements contained within above NSPS and found no requirements that were more str ingent than those already in Rul e 4703.San Joaquin Valley Unified Air Polluti on 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 fo r Stationary Combustion Turbi nes)

The District evaluated the require ments contained within 40 CFR 63 Subpart YYYY and found no requirements that were more stringent than those alrea dy in Rule 4703.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 4703 compar e to rules in o ther air distr icts?

SCAQMD

 Rule 1134 (Emissions of Oxides of Nitrogen from Stationary Gas Turbines)

The District evaluated the require ments contained within SCAQMD ’s Rule 1134 and found no requirements that were more stringent than those alrea dy in Rule 4703.

BAAQMD

 Regulation 9 Rule 9 (Nitrogen Ox ides from Stationary Gas Turbi nes)

The District evaluated the requi rements contained within BAAQMD ’s Regulation 9 Rule 9 and found no requirements that w ere more stringent than those already in Rule 4703.

SMAQMD

 Rule 413 (Stationary Gas Turbines)

The District evaluated the require ments contained within SMAQMD ’s Rule 413 and found no requirements that were more stringent than those alrea dy in Rule 4703.

VCAPCD

 Rule 74.23 (Stationary Gas Turbines)

The District evaluated the require ments contained within VCAPCD ’s Rule 74.23 and found no requirements that were more stringent than those alrea dy in Rule 4703.

Additional Emission Reduc tion Opportunities The District has adopted numerous rule amendments to the turbin e rule that have successfully and significantly r educed emissions from this sour ce category. The emissions inventory for NOx fr om turbines has been reduced from 31.9 tpd in 1994 to 2.77 tpd in 2015. Significan t emission reductions have been ac hieved through the implementation of the most str ingent regulations in the nation for this source category and significant investments by s takeholders to implement effect ive and innovative emission control technologies. Gi ven the significant efforts a nd investments already made to reduce emissions from thi s source category, there are l ittle remaining feasible opportunities for obtaining addit ional emissions reductions.San Joaquin Valley Unified Air Polluti on 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 rang ed from 3-5 ppmv, whereas the BACT limits ranged from 2-3 ppmv. For units less t han 3 MW, the District’s NOx limit was 9 ppmv, whereas t he BACT limit was 5 ppmv. The B ACT guidelines list SCR and SCONOx as the emissions c ontrol technologies used to ac hieve emission limits in the range of 2-5 ppmv . Although lower emission limit s are potentially achievable for this source cat egory, BACT require ments are impo sed on new or modified turbine installations w here ultra-low NOx controls can be installed and the equipment and the facility can be designed to function with thi s new technology. Rule 4703 is a prohibitory rule tha t has undergone several generatio ns of NOx limits for existing units in the Valley; fac ilities comply with these limi ts by retrofitting their existing equipment. Requiring the installa tion 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 a chieve the 5 ppmv limits in place. Therefore, the District evaluated the potenti al 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 exh aust stream and reacts with the nitrogen. Due to the hi gh cost of SCR systems, they a re 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 u sed to calculate the cost effectiveness of SCR in the August 2011 Staff Report fo r Rule 4702. The tables belo w present the total annual costs for a new SCR syst em and a retrofit system.San Joaquin Valley Unified Air Polluti on 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 T urbine
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 R ule 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 $141,992San Joaquin Valley Unified Air Polluti on 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 $233,994San Joaquin Valley Unified Air Polluti on 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 po tential annual NOx emissions were calculated us ing 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 emis sions (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% oxyg en 0.00366 = Conversion factor used : 0.00366 lb/MMBtu per ppmv NOx

The estimated annual NOx emissions reduction was calculated usi ng the following equation:

NOx Emissions Reduction = Curren t NOx emissions - Potential NOx emissions

Potential Emissions Reduction Calculation

The emissions reduction calculat ions below utilized the followi ng information:

Loading factor = 0.75 Heat input rating for a 1 MW unit = 15 MMBtu/hr Annual Hours of O peration = 7884 hours Current Emission Factor in Rule 4703 = 9 ppmv Potential Emissions Factor th rough 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 N Ox emissions - Potential NOx em issions = 0.65 tons/yearSan Joaquin Valley Unified Air Polluti on 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 throu gh the use of SCONOx. This multifaceted technology r educes 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 is sue with the use of SCONOx is that it requires steam to operate and simple cycle pl ants do not generate steam. Ther efore, a simple cycle facility would have to add a bo iler to their facility to genera te steam for the SCONOx system, making the addition of this technology more costly. Th e 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 know n as the EMx system, for turbi nes in a recent Final Determination of Complianc e (FDOC) for the Oakley Generat ing Station. The FDOC states that EMx could potent ially be an improvement over S CR as an add-on control device for achieving NO x reductions – assuming it can a chieve 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 th e atmosphere to form ammonium nitrate, which can be a form of PM2.5. However, based on the implementation of EMx at a fac ility in Shasta County, BAAQMD vo iced some concerns for its use.

EMx has never been used on a la rge utility-scale turbine and so there is no data on which to make a direct evaluatio n of how well the technology wo uld work on larger turbines. EMx has been used on a smaller aeroderivitive turbin e at the Redding Power Plant Unit No. 5, a 45-MW combi ned-cycle facility in Shasta Cou nty, CA. The Shasta County Air Quality M anagement District eval uated EMx at the Red ding facility under a demonstration NOx limi t of 2.0 ppm, which SCR can consistently achieve. After three years of operation, the Shasta C ounty AQMD evaluated whether th e facility was meeting this demonstration limi t with EMx, and concluded that “ Redding Power is not

77 Brian K. Lusher, Bay Area Air Quality Management District. (Ju ne 2010). Final Determination of Compliance: Marsh Landing Generating Station.San Joaquin Valley Unified Air Polluti on 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 t he NOx demonstration limit of 2.0 ppmvd @ 15% O2. ” 78

The FDOC states that although the EMx manufacturer maintains th at such problems have been overcome, concerns rem ain about how consistently the technology would be able to perform. Communication s between BAAQMD and Shasta Coun ty Air District confirmed that the earlier conc lusions about the achievability of a lower limit remain valid. 79 In addition, monthly reports o f Continuous Emissions Monitori ng System (CEMS) data submitted by Reddi ng Power Plant to Shasta County A ir District during 2007 and 2008 indicated that emi ssions have often been substant ially higher. 80 Furthermore, the data from Reddi ng is from a smaller aeroderivi tive turbine, and there is no guarantee that if it were scale d up for uses on utility-size turbines that it would even be able to achieve the performanc e required from larger turbine s. For these reasons, BAAQMD concluded that EMx is not as developed as SCR and cannot achieve the same level of emissions performa nce that SCR is capable of.

SCAQMD is funding a research pro ject that will study and demons trate the feasibility of control technologies to reduce PM 2.5 and ultrafine particulate emissions from natural gas-fired turbine power plants . EMx is one of the two technolo gies that were selected for demonstration. The findings of this report could potential ly be beneficial for evaluating the feasibility of E Mx applications for turbines in the future.

SOx The District considered implement ing sulfur dioxide (SO2) limit s at least as stringent as the requirements in 40 CFR 60 Subpart KKKK (S tandards of Perfor mance for Stationary Combustion Turbines). Fuel treat ment sulfur removal systems we re recognized as being able to reduce SO x emissions from turbines, other than th ose fired on Public Utilities Commission (PUC) quality natural gas. One Valley fac ility installed SCR onto their digester gas-fired turbi ne to meet the Rule 4703 limit. To do this, they installed a fuel pretreatment system that rem oves H2S and siloxanes, as the y can damage the SCR catalyst if not removed. Other landfill and digester-gas t urbines outside the District are also using these systems.

There are only seven units at s ix facilities in the Valley that utilize a fuel other than natural gas. Four units are fir ed on diesel gas, while the oth er three units utilize digester gas. However, the fac ilities with diesel-fired units utilize natural gas the majority of the time and utiliz e diesel fuel onl y during emerge ncies. Due to California Diesel Fuel requirements, the di esel facilities in the Valley a re limited to a sulfur content of 0.0016 lb-SO2/MMBtu. PUC-qualit y 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 Qualit y District Manager, Shasta Coun ty Air Quality Management District, to R. Bennett, Safety & Environmental Coordina tor, Redding Electric Utility, J une 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 Polluti on 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 KKK K limit is much higher at 0.060 lb-SO2/MMBtu and all o f the units in the Valley are ac hieving much lower SO2 limits. Adding a SO2 limit sim ilar 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, ele ctrostatic precipitators, and scrubbers were examined since these technologies can be us ed to remove PM2.5 emissions from exhaust gas streams.

As previously mentioned, every u nit in the Valley subject to Ru le 4703 operates on strictly natural gas , with the exception of seven facilities th at operated on an alternate fuel part-time or during emer gencies. Based on District Permit s records and information in the BAAQMD FDOC for the Oakley Generating Station, electrost atic 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 us ed in natural gas-fired applic ations, which have inherently low PM emissions. The District is not aware of any gas turbine that has ever been required to use add-on contro ls such as these. BAAQMD rev iewed the EPA BACT/LAER Clearinghouse and confi rmed that EPA has no record ofany postcombustion particulate contro ls that have been required for nat ural gas-fired gas turbines. 81

Furthermore, these devices would not be technologically feasibl e to implement for certain facilities. As noted in the BAAQMD FDOC, if add-on cont rol equipment were installed, it would create signi ficant backpressure that would significantly reduce the efficiency of a power plant and wo uld 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 e ffect on the low-PM emissions streams from natural g as-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 effi ciently. This low level of ab atement efficiency (if any) also means that these types of con trol devices would not be cos t effective, even if they could feasibly be applied to this type of source. For these re asons, post-combustion particulate control equipment i s not technologically feasible f or units subject to Rule 4703.

As previously mentioned, SCAQMD is funding a research project t hat will study and demonstrate the feasibility o f control technologies to reduce P M2.5 and ultrafine particulate emissions from natural gas-fired turbine power plan ts. Sulfur removal and the EMx multi-polluta nt 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 Polluti on 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 b e beneficial for evaluating the cost effectiveness and feasib ility of applying these emergi ng technologies to turbines in the future.

Evaluation Findings Even though stationary gas turbines are not a significant sourc e of PM2.5, NOx, or SOx in the Valley, the District has eva luated all potential control technologies and all control technologies achieved in practic e in other areas or included in other state implementation plans. As demons trated above, Rule 4703 current ly has in place the most stringent measures feasible to implement in the Valley and therefore meets or exceeds both BACM and MSM require ments for this source category . As the District continues to develop new attainm ent plans that address more str ingent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emissions from stationary gas turbines in the Valley.San Joaquin Valley Unified Air Polluti on 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 lim it sulfuric acid emissions fr om any sulfuric acid production unit that was construc ted or modified before August 17, 1971. The rule was adopted on May 21, 1992 to limit s ulfuric acid mist to 0.30 pou nds per short ton of acid produced and only applies to one facility in the Valley. EPA a pproved Rule 4802 into the SIP on June 8, 1999.

Source Category A sulfuric acid production unit i s any facility producing sulfu ric acid by the contact process by burning elemental sul fur, alkylation acid, hydrogen sulfide, organic sulfides, or acid sludge. It does not incl ude acid plants used as sulfur dioxide (SO2) control systems, chamber process plants, a cid concentrators, or petrole um 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from s ulfuric acid mist are lower th an the BACM/MSM significance thresholds. Theref ore, the Clean Air Act does not require a control measure evaluation for this sour ce category for the purpose of satisfying BACM/MSM requirements; however, the Distr ict has still conducted a full control measure evaluation for sulfuric acid mist.

How does District Rule 4802 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, ACT, NESHAP, o r MACT requirements for thi s source category.San Joaquin Valley Unified Air Polluti on 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 Gu idelines and Compliance Time s for Sulfuric Acid Production Units)

The District evaluated the require ments contained within 40 CFR 60 Subpart Cd and found no requirements that were more stringent than those alrea dy in Rule 4802.

 40 CFR 60 Subpart H (Standards of P erformance for Sulfuric Aci d Plants)—last amended on February 27, 2014, but t he revisions only included c orrections for source testing procedures.

The District evaluated the require ments contained within 40 CFR 60 Subpart H and found no requirements that were more stringent than those alrea dy in Rule 4802.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 4802 compar e to rules in o ther air distr icts? There are no analogous rules for this source category in SMAQMD or VCAPCD.

SCAQMD

 Rule 469 (Sulfuric Acid Units)

The District evaluated the require ments 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 requi rements contained within BAAQMD Regulation 9 Rule 1 and found no requirement s that were more stringent than those a lready in Rule 4802.

 Regulation 12, Rule 6 (Acid Mis t from Sulfuric Acid Plants)

The District evaluated the requi rements contained within BAAQMD Regulation 12 Rule 6 and found no requirements that w ere more stringent than those already in Rule 4802.

Additional Emission Reduc tion Opportunities Only one facility in the Valley—a sulfuric acid plant—is subjec t to Rule 4802 (Sulfuric Acid Mist). This facility wa s in operation before 1971 and is limited by this rule to 0.30 pounds of acid mist per ton of aci d produced. The facility uses a mist eliminator to remove fine particles from the ac id gas stream, which has been determined to meet BACT requirements. By definit ion of Rule 4802, no new facility within the Valley will be subject to this rule. Instead, a ll new facilities would be subj ect to Rule 2201 (New and Modified Stationary So urce Review Rule) an d would be required t o implement BACT level controls.San Joaquin Valley Unified Air Polluti on 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 pot ential opportunity to reduce emis sions from this source category by lowering the limit fo r sulfur emissions from 0.30 p ounds per ton produced to 0.1 pound per ton produced, consis tent with EPA’s BACT determin ation. Source tests conducted in 2010 and 2011 at the single facility permitted und er Rule 4802, showed an actual sulfuric acid mist emi ssion rate of 0.09 pound per ton u sing existing technology. Hence, the facility is meeting the current national BACT standa rd with the most advanced technology currently ava ilable and enfor ced through ex isting permit requirements, despite the fact that their current permit and Ru le 4802 do not set that requirement. Therefore, the Dis trict has determined that there are no potential opportunities to further reduce em issions from this source cate gory.

Evaluation Findings Even though sulfuric acid mist i s not a significant source of P M2.5, NOx, or SOx in the Valley, the District has evaluat ed all potential control techno logies and all control technologies achieved in practic e in other areas or included in other state implementation plans. As demons trated above, Rule 4802 current ly has in place the most stringent measures feasible to implement in the Valley and therefore meets or exceeds both BACM and MSM require ments for this source category . As the District continues to develop new attainm ent plans that address more str ingent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emissions from sulfuric acid mist in th e Valley.San Joaquin Valley Unified Air Polluti on 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 FIR EPLACES AND WOOD BURNING HEATERS

Discussion Rule 4901 limits emissions from wood burning fireplaces, wood b urning heaters, and outdoor wood burning devices thr ough wood burning curtailments in areas with natural gas service. Rule 4901 also restr icts the sale and transfers o f non-compliant wood burning devices, and limits the installation of wood burning de vices in new residential developments.

Through the Check Before You Bu rn program, which is based on Ru le 4901, the District has declared and enforced episodi c wood burning curtailments, a lso called “No Burn” days, since 2003. Check Before Y ou Burn and District Rule 4901 reduce harmful species of PM2.5 when and where those reductions are most neede d: in impacted urbanized areas when the local w eather is forecast to hamper PM dispersion.

Rule 4901 was first adopted in 1993 and has been subsequently a mended three times. The 1993 adoption of Rul e 4901 established a public education p rogram on techniques to reduce wood burning emissions . It also enforced EPA Phase I I 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 req uest voluntary curtailment of wood burning on days when the am bient air quality was unhealthy

.

The 2003 rule amendm ents added episodic wood burning curtailmen ts when air quality was forecast to be at 150 or hig her on the air quality index (A QI), which is equivalent to a PM2.5 concentration of 65 μg/ m3, and added restrictions on th e installation of wood burning devices in new resident ial development s, based on housi ng density. The 2008 rule amendments lowered the ma ndatory curtailment level to a PM 2.5 concentration of 30 μg/m3, and added a contingency m easure to lower the wood bur ning curtailment level to 20 μg/m3 in the event t hat EPA finds that the Valley d oes not attain the 1997 PM2.5 air quality st andard in 2014.

The 2014 amendments to Rule 4901 lowe red the No Burn threshold for high polluting wood burning heaters and fi replaces from 30 μg/m 3 to 20 μg/m 3 . The amendments doubled the number of No Burn da ys for high polluting units tha t are the source of over 95% of the wintertime residential wood smoke emissions. By con trast, under the newly amended rule, clean certified units are subject to a minimal nu mber of No Burn days ranging from zero to six days d epending on the location in the Valley during the winter season because the No Burn thres holds for these units were rais ed to 65 μg/m 3

.San Joaquin Valley Unified Air Polluti on 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from w ood burning fireplaces and woo d burning heaters are lower than the BACM/MSM signific ance thresholds for NOx and SOx . Therefore, the Clean Air Act does not require a N Ox and SOx control measure ev aluation for this source category for the purpose o f satisfying BACM/MSM requirem ents; however, the District has still conducted a fu ll control measure evaluation for wood burning fireplaces and wood burning heaters.

How does District Rule 4901 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTGs, A CTs, NESHAPs, or MACT guidelines for th is source category.

NSPS

 40 CFR Part 60 Subpart AAA (St andards of Performance for New R esidential Wood Heaters)

On February 3, 2014, EPA published proposed amendments to 40 CF R Part 60 Subpart AAA. 83 The proposed rule was finalized by EPA on February 3, 2015. District Rule 4901 points to the NSPS for emi ssion limits and is therefore as stringent as the newly promulgated NSPS.

1988 NSPS Under the 1988 NSPS, only those w ood or pellet-burning units me eting the following criteria require certification and all other units are not requ ired 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 Polluti on Control District April 16, 2015

C-158 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard 1. Units that have an air-to-f uel 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 ra te less than 5 kilograms per hou r (11 pounds per hour); and 4. Units that weigh 1,760 pounds or less.

For wood heaters meeting these r equirements, the current certif ication emissions limits are 4.1 grams per hou r (g/hr) of PM for uni ts equipped with a c atalytic combustor and 7.5 g/hr for units wit hout a catalytic com bustor. Units certif ied to these emission limits are said to be Phase-II Certified and will maintain that certifica tion until the certification expires, which is up to 5 year s from the issuance date.

Under the current NSPS, pellet sto ves are not explicitly exempt from required certification; however, most m odels currently sold fall outside the regulation because they operate on an air-to-fuel r atio greater t han 35-to-1. Sin gle burn rate wood heaters are also not explicitly exemp t from the current NSPS, but are n ot regulated by it because they operate below the bur n rate criteria of 5 kilogram s per hour.

2015 NSPS The 2015 NSPS significantly lower s the certification emission l imits for wood-burning heaters that are currently requir ed to be certified and sets ce rtification limits for a broader range of wood-burni ng heaters by remov ing the existing certification criteria (1 through 4 above). New standards will apply not only to adjusta ble burn rate wood heaters (the focus of the origin al regulation), but also to sin gle burn rate wood heaters/stoves, pellet heaters/st oves, and any other affected a ppliance as defined in revised Subpart AAA as a “room heater.”

Although they do not require EPA certification under the 1988 N SPS, 96% of pellet heaters meet the proposed Step 1 PM emissions limit of 4.5 gram s per hour. Single burn rate wood heaters are incapabl e of operating at the lowest burn rates, and it is the lower burn rates that result in the highest level of PM emissio ns; therefore, most single burn rate wood heaters will also m eet the proposed Step 1 PM em issions limit. Manufacturers of such units will not initially be required to m odify their design if they already meet the emissions stand ard and will automatically be d eemed as certified to meet the Step 1 em ission limits.

EPA promulgated a two-step complia nce approach that applies to all new adjustable burn rate wood heaters, single bu rn rate wood heaters and pelle t heaters/stoves. Under this approach, Step 1 emission lim its for these sources will ap ply to each source manufactured on or after the effe ctive date of the final rule o r sold at retail on or after December 31, 2015. Step 2 emissi on limits for these sources wi ll 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 opti on for manufacturers who choose to certify using cord w ood (rather than crib wood) to me et the Step 2 limits.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-159 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard 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 5 years after effective date of final rule 2.5 g/hr (Cord wood alternative compliance option)

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 4901 compar e to rules in o ther air distr icts? There are no analogous rules for this source category in VCAPCD

.

SCAQMD

 Rule 445 (Wood Bu rning Devices)

Rule 445 was last amended on May 3, 2013 to lower the curtailme nt threshold from 35 to 30 μg/m3. District Rule 4901 is more stringent than Rule 44 5, as the District lowered the No Burn threshold for high polluting wood burning heaters a nd fireplaces from the 30 μg/m 3 to 20 μg/m 3 in 2014. The District evaluated the requirements contained wi thin SCAQMD Rule 445 and found no require ments that were more string ent than those already in Rule 4901.

BAAQMD

 Regulation 6 Rule 3 (W ood-Burning Devices)

The District evaluated the requi rements contained within BAAQMD Regulation 6 Rule 3 and found no requirement s that were more stringent than those a lready in Rule 4901.

SMAQMD

 Rule 417 (Wood Burning Appliances)

The District evaluated the require ments contained within SMAQMD Rule 417 and found no requirements that were more stringent than those already in Rule 4901.

 Rule 421 (Mandatory Episodic C urtailment of Wood and other Sol id Fuel Burning)

The District evaluated the require ments 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 o f Ecology Regulation Chapter 17 3-433 WAC (Solid Fuel Burning Devices)

The District evaluated the requi rements contained within the ab ove regulation and found no requirements that were more stringent than those already in Rule 4901.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-160 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard  Colorado Air Quality Contro l Commissions Regulation No. 4

The District evaluated the require ments contained within Colora do’s rule and found no requirements that were more str ingent than those already in Rul e 4901.

 Spokane Regional Cle an Air Agency Regulation I Article VIII

The District evaluated the requi rements contained within the Sp okane rule and found no requirements that were more str ingent than those already in Rul e 4901.

 Oregon Department of Environment al Quality Divis ion 262 (Heat Smart Program for Residential Woodstoves and Other S olid Fuel Heating Devices)

The District evaluated the requi rements contained within Oregon ’s rule and found no requirements that were more str ingent than those already in Rul e 4901.

 Yolo-Solano AQMD Rule 2. 40 (Wood Burning Appliances)

The District evaluated the require ments contained within Rule 2 .40 and found no requirements that were more str ingent than those already in Rul e 4901.

Additional Emission Reduc tion Opportunities

2014 Amendments to the District’s Residential Wood Burning Prog ram The District takes a multidimens ional and proactive approach to reducing emissions in the Valley. This philosophy is especially true for reducing em issions from residential wood burning with a combination of regulatory controls through Rule 4901, public outreach and education , and the District’s Burn Cleaner Wood St ove Change-out Program (Burn Cleane r Program). The District’s approach to red ucing emissions from residential wood burni ng empowers Valley residents to play a ma jor role in reducing emissions at almost no cost, and , in many cases, with savings i n heating-related energy costs. Valley residents are encouraged to transition from olde r more polluting wood burning heaters and wood burning fireplaces (also commonly call ed open hearth fireplaces) to cleaner alternat ives, by decreasing the number o f allowable burn days for high polluting wood burning heater s and fireplaces while at the same time increasing the number of burn da ys allowed for regi stered clean wood burni ng heaters through a tiered episodic wood burning cu rtailment program. Emissions re duced through the 2014 amendments to the program are significantly greater than t hose 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 emissi ons by increasing the number of “No Burn” days. Lowering the curtailmen t level below the 30 μg/m 3 level has reduced the build-up of emissions during the long stagna tion periods experienced in the Valley during the 2014- 15 winter season, and helped avoid exceedances of the PM2.5 sta ndard.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-161 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard During the September 2014 rule a mendment project, the District estimated the average number of additional No Burn da ys likely to occur in future yea rs as a result of lowering the curtailment level from the pr evious threshold level of 30 μ g/m3 to the threshold level of 20 μg/m3. The average increase in No Burn days in future ye ars in each county was calculated by averaging the hist orical data from the past five wood burning seasons of the number of days P M2.5 concent rations were forecasted to be equal to or exceed 30 μg/m3 versus 20 μg/m3. This anal ysis is summarized in the tabl e below. The estimated average increase in No Burn da ys in future years was determined to be 34 days per county (an average of the last c olumn in the table below) per w ood burning season. However, the estimation of 34 addi tional No Burn days per wood burning season in the future will vary. No Burn days are called based on the air qua lity forecast for each day and are dependent on several variabl es. As a result of this an alysis, the District amended Rule 4901 to lower the cu rtailment threshold to 20 μg/m 3 in September 2014.

Table C-32 Average Number of Da ys Forecast Above Curtailment T hresholds*

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 fr om the 2009-10, 2010-11, 2011-12, 2 012-13, 2013-14 wood-burning seasons

Although a No Burn da y can potentially incr ease a resident’s na tural gas costs from using a central heating system i n lieu of a wood burning heater , this potential cost is offset by the central heating system since a central heating sy stem more efficiently heats the whole home, resulting in less money being spent on fi rewood based on the increase in No Burn days. Compa red to other District rules, cu rtailing residential wood burning under Rule 4901 is the most cost effective rule for red ucing directly emitted PM2.5 emissions.

Wood Burning Season During the 2014 amendment, the Dis trict evaluated the potential opportunity for further reducing emissions from the resi dential wood burning source cat egory by extending the wood burning curtailment season . The current wood-burning seas on 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 increase d the number of No Burn days in each wood-burning season.

Measured Valley concentrations of levoglucosan, a primary indic ator for wood burning, are not nearly as high in October or March as found to be durin g the current woodSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-162 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard burning season of November thr ough February. Additionally, a s ix-year average was calculated for the number of No Bu rn days in each county from 2 008 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 s eason would not significantly benefit air qualit y in the Valley due to the comb ination of less extensive burning activity and the minute number of additional No Burn da ys.

Table C-33 Days with PM2.5 ≥ 30μg/m 3 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 furt her limiting the installation of wood burning fireplaces and heaters in new res idential developments by strengthening Se ction 5.3 of Rule 4901, which sets limits for the quant ity of wood burning fireplaces o r wood burning heaters that can be installed in new res idential developments. South C oast Rule 445 prohibits the installation of wood burning devices in any development tha t has natural gas service. However, since most of the Valley’s new developments are already subject to restrictions based on their hous ing densities, the emissions re duction potential is minimal.

As a part of the 2014 amendments to Rule 4901, the District ame nded Section 5.3. Previous rule language was not c ompletely clear as to the numbe r of heaters allowed to be installed if that number falls between two whole numbers. T he rule language was strengthened by clarifying the num ber of heaters allowed for in stallation in a given area, in addition to the language being c larified with regards to the applicability of the density requirements by the removal of th e term “new” from rule languag e.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-163 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Section 5.3.1 (Effecti ve 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: m ax 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: m ax 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 fi replace in a residential development with a density great er than two dwelling units per acre. While this could be misinterpreted as being less stringent than a similar requir ement in SCAQMD Rule 445, in reality it is more str ingent because Rule 4901 does not afford the same flexibilities as the SCAQMD rul e does. While SCAQMD Rule 445 h as language prohibiting the installation of a permanently installed wood bu rning device into any new development, this requirement is not applicable to new developm ents where there is no existing infrastructure for natur al gas service within 150 feet of the property line or those 3,000 or more feet above mean s ea 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 l imited to no more than two per acre. Additionally, Rule 4901 does not exempt any homes from any aspect of rule requirem ents based on elevation.

Encouraging the Transition to Clean Bu rning Heaters through Non-Regulatory Measures Upgrading a home’s wood burning device reduces air pollutant em issions on days when wood burning is allowed. By operat ing more efficiently, these devices can also lowerSan Joaquin Valley Unified Air Polluti on 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 proh ibits nor requires wood burning device upgrades. Howev er, the District encourages such upgrades through its public outreach and th rough its Burn Cleaner Program, which pro vides funding to Valley residents to upgrade their curr ent wood-burning devices and ope n fireplaces to natural gas or propane gas devices, to certified wood stoves or inserts , or to pellet devices. The District’s webpage 84 has more information on progr am eligibility and qualified devices.

There are several types of wood burning devices and device inse rts available. Wood stoves, especially newer models, are generally safe and efficie nt 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 fro m 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 bur n compressed pellets made of ground, dried wood and ot her biomass wastes. Pellet st oves are generally more expensive than wood stoves and require electricity for ope ration; however, they are typically more efficient t han wood stoves due to the better fuel-to-air ratio in the combustion chamber.

Wood burning fireplaces include tr aditional masonry fireplaces built into brick or stone, constructed in the home, and “low mass” fireplaces that are pre -fabricated prior to installation. Most fireplaces a re 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 av ailable to reduce emissions. EPA does not certify f ireplaces or fireplace insert s, but does have a voluntary program for devices th at meet qualifications to be co nsidered cleaner burning than typical fireplaces and fir eplace inserts. While these dev ices reduce emissions relative to uncontrolled firepl aces, their emissions are still relatively higher than certified wood stoves and pellet stoves.

Gas stoves and gas fireplaces b urn natural gas or propane, emit very little air pollution, and require little maintenance. G as devices are not subject to the requirements of Rule 4901, so they can be used on “No Burn” days. For more informat ion about the various types of wood burning devices available, see EPA’s Burn Wise pr ogram webpages 85

. The following figure illustrates the average PM2.5 emissions ba sed on various heat

sources.

84 www.valleyair.org/Grant_Program s/GrantPrograms.htm#WoodStoveCha ngeOut
85 www.epa.gov/burnwiseSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-165 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Figure C-9 Average PM2.5 Emissi ons Based on Wood Burning Heate r Type 86

A third party survey of Valley residents (see Appendix E) revea led that the majority of Valley residents do not have wood burning heater s or wood burni ng fireplaces. However, of those that do have wood burning heaters and wood bu rning fireplaces, the majority have wood burning fir eplaces, refer to Figure C-10 (Pr oportion of Residents with a Wood-Burning Fireplace, W ood 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.

86 EPA. (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 Polluti on Control District April 16, 2015

C-166 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Figure C-10 Proportion of Reside nts with a Wood-Burning Firepl ace, Wood Stove or Pellet Stove

EPA reports that 75% of wood stoves (also called wood burning h eaters) in the United States are non EPA-certified stov es. EPA certified wood burnin g heaters produce 70% less particle pollution then thei r older dirtier counterparts.

Survey results indicate the most effective ways to encourage tr ansition to clean burning heaters is to allow more wood bur ning days for less polluting w ood burning heaters and update the District’s Burn Cleane r Program to increase incentiv e amounts. By encouraging Valley residents to tr ansition to clean wood burnin g heaters, emissions will not only be reduced on No Burn days but also on days when burni ng is allowed. This health and air quality benefit w ill occur because cleaner alter natives such as EPA Phase II Certified wood burning heaters and pellet-fueled wood burning heaters, and gaseous-fueled heaters will be in u se instead of the older more polluting wood burning heaters and wood burning fireplaces.

Many Valley residents have upgra ded their homes with these newe r devices, including through programs such as the District’s Burn Cleaner Program and federal tax incentives. Given their much low er relative emissions, allowed use of these devices during a lower curtailment lev el still achieves the goal of sig nificantly reducing the overall emissions that ultimatel y lead to violations of the sta ndard. 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 c ontinue 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%San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-167 Appendix C: BACM and MSM for Stationary and Area Sources 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 mo re polluting wood burning heaters and fireplaces to cleaner wood burning heaters. Since 2006, the Burn Cleaner Program has been helpin g residents overcome some of the financi al obstacles in purchasing cleaner alternatives. There are currently more than 30 hearth retailers in the Valley that have part nered with the District to successfully im plement the Burn Cleaner Program.

The Burn Cleaner Progr am offers multiple le vels of incentive fu nding, increased as of the 2014-2015 wood bur ning season:

 Up to $1,000 to replace a qualif ying unit with a certified woo d insert/freestanding stove, certified pellet insert/f reestanding stove, or natural g as insert/freestanding stove

 Up to $2,500 of any eligible dev ice if the applicant is eligib le for Low-Income

 Up to $500 as an additional incen tive towards gas devices (for both standard and low-income)

The District continuously reevaluat es the Burn Cleaner Program and implements enhancements to the program. In addition to increased incentiv e amounts, the District has also recently implemented the following enhancements:

 Reducing a substantial portion of the upfront, out-of-pocket c ost of a new qualifying unit for low-income qualified applicants. The Distr ict has partnered with contracted hearth retailers to allow low-income qualified applicants to make the purchase at a reduced price by deducting the incentive amou nt from the invoice at the point of purchase . Allowing the incentive fundi ng to be directly applied when purchase is made makes it more feasible for additi onal low-income applicants to take advantage of the program.

 Refining the low-income eligib ility form to streamline the det ermination process and identifying the heart h retailers that provide the reduced u pfront cost option.

 Program documents are now ava ilable in Spanish to further exte nd the outreach efforts to the local community.

 Updates to program documents to m ake them more user-friendly a nd to improve the process during t he application, installation, and claim for payment request phases.

 The document submittal proce ss has been updated to allow appli cations and claim for payment requests to now be emailed to the District fo r faster processing. Also, supplemental forms have been developed furth er streamline the review process and help keep the retailers and applicants i nformed on the status of projects.

The upgrades to processing, applic ations, and incentive amounts , combined with effective and proactive public outreach and educ ation campaign and the assistance of District retail partner s, the initial funding for the Burn Clea ner Program was quicklySan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-168 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard exhausted. At the November 13, 2014 Governing Board meeting, t he District Governing Board approved an addi tional $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 fundin g was allocated quickly and efficiently to the residents in the Valley. Given this pro gram’s critical role in supporting the District’s effort s to reduce the impact of resid ential wood burning and continued high demand in the program the District went back to the Governing Board at the December 18, 2014 public h earing to request additional fund ing and other amendments to the program, and an additional $3.6 million in fu nding was allocated along with programmatic changes p roposed by staff including low ering the voucher incentive amount for non-low inco me applicants from the then $1 ,500 to $1,000, limiting the number of vouchers per househol d, and directing funding bas ed upon demand for any surplus remaining in each county.

Collaboration with participating hearth retailers The District has renewed its cont racts with the hearth retailer s and hosted informational meetings to discuss program changes in order to ensure a smooth roll out of the enhancements. As part of the Distri ct’s initiative to increase the effectiveness of the program, District staff has worke d closely with the participati ng hearth retailers on outreach efforts and provided them with promotional tools, such as flyers and quick screens with information about t he Burn Cleaner Program.

Public Outreach and Education The District has an extremely su ccessful outreach and education program with regards to residential wood burning and educating Valley residents abou t air quality, the effects of air pollution on the populati on’s health, and on options the y can take to reduce emissions. In the 2013-14 wood-burni ng season the District too k part in 51 media interviews about extreme w eather and wood burning.

The District’s informational Check Before You Burn program minimizes elevated PM2.5 concentrations throughout the winte r. The PM2.5 air quality im provements that the Valley has experienced since the adoption of Rule 4901 have bee n assisted by strong multimedia outreach by the Distr ict and a resultant increase in public awareness and participation in winte r District programs.

During the wood-burning season of 2013-14, the District Outreac h staff received hundreds of public calls and emails specific to residential woo d burning. An interesting new trend has surfaced regarding public opinion, an increased n umber of the phone calls were in support of an outri ght ban on residential wood bu rning year-round (with the exception of residents for whom wood burning is the sole source of heat). This is attributed to height ened 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 N etwork (RAAN) and the “Valley Ai r” smart phone app, have continued to gain in popular ity. Annual public call and w ebsite “hit” statistics, plus growth in the District’s Fac ebook page activity, also illustrat e continued growth in wood-San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-169 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard burning awareness. Survey resu lts also showed an increased pub lic awareness with eight out of ten respondents being aware of the District’s Check Before You Burn program, 78% of whom confirmed r educed wood-burning activities as a direct result of the program.

The District also incorporates wood-burning messaging into othe r public outreach products, including Healthy Air Living Schools materials, “Blue Sky, Brown Sky ... It’s Up to You!” elementary curri culum and other materials.

Multimedia Advertising Campaign The District’s seasonal public outreach advertising campaign is retooled each year to include timely and relevant m essaging. In the past few seasons , this messaging has been delivered by the District’s Go verning Board members, with billboards in English and Spanish strategically plac ed throughout the Valley, radio a nd 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 Twi tter posts. Facebook “likes” have nearly dou bled from the 2012-13 season, t o more than 1,100 at the end of the 2013-14 season. Thi s has proven to be a valuabl e way to deliver immediate messaging regarding w ood-burning statuses, in additio n to providing a platform for direct, two-way interaction with the public.

Strengthening Media Partnerships The District maintains partnersh ips with television, newspaper, radio, outdoor and print, as well as more non-traditional media, such as on-screen messag ing in local movie theaters, internet advertising and video loops in medical offic es. During seasonal Check Before You Burn campaigns, the District runs medi a on 11 broadcast television stations in the Fresno and Bakers field markets, including four Spanish stations, as well as 10 cable networks in four cabl e markets including zoned cabl e in Stockton, Modesto, Turlock and Manteca. In the Sacr amento market, which includes the District’s northern counties, the wood-burning message runs on two English language broadcast television stations and one Span ish language broadcas t 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 (includin g large-format vinyl billboards) and smaller “one-sheet s” in Environmental Justice c ommunities throughout the Valley. With these purchas es come added value in the form of bonus spots, news sponsorships, and extra billboa rds and overages in outdoor mess aging. Outdoor messaging is strategically placed in high-traffic areas as well as neighborhood and rural communities to ensure a wide r each in those areas where residen tial wood burning might be common.

The District’s print campaign incl udes major papers such as the Bakersfield Californian

, Fresno and Modesto Bees and Stockton Record , but also rural newspapers such as theSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-170 Appendix C: BACM and MSM for Stationary and Area Sources 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 J ournal, which offers the opportuni ty to promote seasonal campaigns. Media buys allow le veraging buying power that typic ally returns an additional $100,000+ in media placement. The related Cinemedia campaign is also regularly featured on 100 movie screens from Stockton to Bakers field, with more than 25,000 spots that reach more than 475,000 people.

Evaluation Findings Even though wood burning firepl aces and wood burning heaters ar e not a significant source of NOx or SOx in the Va lley, the District has evaluated all potential control technologies and all control tec hnologies achieved in practice in other areas or included in other state implementation pl ans. As demonstrated above, Ru le 4901 currently has in place the most stringent measur es feasible to implement in t he Valley and therefore meets or exceeds bot h BACM and MSM requir ements for this source category. As the District continues to develop new attainment plans that address more stringent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emissions from wood burning fireplaces and wood burning heaters in the Valley.San Joaquin Valley Unified Air Polluti on 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 rat es less than or equal to 75,000 Btu/hr. The original rule enforced a NOx emissions limi t of 40 nanograms of NOx per Joule of heat output (ng/J)

. Since its adoption, t he rule has been amended once. The March 2009 amendments st rengthened the rule by enfor cing a limit of 10 ng/J for new or replacement wat er heaters and a limit of 14 ng/ J for instantaneous water heaters. NOx emissions have been c ontrolled by approximately 8 8% for this source category. EPA finalized approval for Rule 4902 on May 5, 2010.

Source Category As a point-of-sale rule, Rul e 4902 affects water heater manufac turers, plumbing wholesalers, retail home supply stores, plumbers and contractor s, and homeowners.

This source category encompasses several types of water heaters , including conventional storage water heaters, demand water heaters, heat pump water he aters, solar water heaters, and tankles s coil and indirect w ater heaters. Water h eater options also vary by fuel type which includes electric ity, fuel oil, ge othermal ener gy, natural gas, propane, and solar energy.

Conventional storage water heaters are the most common. They h ave an insulated tank sized from 20 to 80 gallons and natural gas fired units have a gas burner under the tank regulated by a therm ostat. 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 burne r heats cold water as it trave ls through a pi pe in the unit. Natural gas fired units provide hot water a t a rate upwards of 5 gallons per minute.

A tankless coil water heater heat s water flowing through a heat exchanger installed in a furnace or boiler. Similar to t he tankless coil water heater a n indirect water heater uses a furnace or boiler. Fluid heat ed by the furnace or boiler is circulated through a heat exchanger in a st orage tank.

Manufacturers have focused on com bustion modification to meet t he lower NO x limit as required in other California air districts. Combustion modific ation systems are designed to reduce thermal NO x formation by changing the flame characteri stics to reduce peak flame temperature. Combustion modifica tion for residen tial water hea ters is achieved by different burner designs such as l ow NOx and ultra-low NOx burn ers. Some o f the design principles used in low NOx and u ltra-low NOx bur ners include st aged air burners, staged fuel burners, pre-mix burners, int ernal recirculation, and radi ant burners.San Joaquin Valley Unified Air Polluti on 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from r esidential water heaters are l ower than the BACM/MSM significance threshol ds. Therefore, the Clean Air Act does not require a control measure evaluation for this source category for the pur pose of satisfying BACM/MSM requirements; however , the District has still conducte d a full control measure evaluation for re sidential water heaters.

How does District Rule 4902 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, N ESHAP, or MACT requirements f or this source category.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 4902 compar e to rules in o ther air distr icts?

SCAQMD

 Rule 1121 (Control of Nitrogen Oxides from Residential Type, N atural Gas-Fired Water Heaters)

The District evaluated the require ments contained within SCAQMD Rule 1121 and found no requirements that were more stringent than those alrea dy in Rule 4902.

BAAQMD

 Regulation 9 Rule 6 (Nitrogen Ox ides Emissions from Natural Ga s-Fired Boilers and Water Heaters)

The District evaluated the requi rements contained within BAAQMD Regulation 9 Rule 6 and found no requirement s that were more stringent than those a lready in Rule 4902.San Joaquin Valley Unified Air Polluti on 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, Boile rs and Process Heaters Rated Les s than 1,000,000 BTU Per Hour)

The District evaluated the require ments 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 require ments contained within VCAPCD Rule 74.11 and found no requirements that were more stringent than those alrea dy in Rule 4902.

Additional Emission Reduc tion Opportunities Units subject to Rule 4902 are fired on PUC qual ity natural gas , and are inherently lowemitters of SOx and PM2.5 emis sions. Given the significant eff orts and investments already made to reduce emissions from this source category, the re are little remaining opportunities for obtaining addit ional emissions reductions.

Electric Water Heaters The District evaluated the pot ential opportunity to replace nat ural gas and propane water heaters with electric units . A comparison of three water heaters that utilize the different fuel types with an emi ssions reductions and cost effe ctiveness analysis for these units is summarized below.

Table C-34 Emissions Reductions and Cost Effectiveness of Wate r Heaters by Fuel Type

Fuel Type Low NOx Propane Electricity Natural Gas Capacity 1 50 gallons 50 gallons 50 gallons Shipping Weight 1 180 lbs 151 lbs 109 lbs Energy Factor 1 0.62 0.59 0.91
Purchase Price 1 $902.00 $899.00 $473.25
Estimated Life Expectancy 2 13 years 13 years 13 years

Lifetime Energy Use 2 3,133 therms 2,867 gallons of LP 62,439 kWh
Lifetime Energy Costs 3 $3,568 $7,176 $9,834
Lifetime NOx Emissions 4 30.60 lbs 48.09 lbs 0.00 lbs

Annual NOx Emissi ons 2.35 lbs 3.70 lbs 0.00 lbs Comparing Natural Gas a nd Propane to Electricity N/A Annualized capital cost 5 $76.99 $76.99San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-174 Appendix C: BACM and MSM for Stationary and Area Sources 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 NO x $237.87 $76.07 Cost per ton NOx $475,736 $152,135

1 Unit specifications and prices acquired from Grainger Industri al 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 co st of units of energy in 2010 according to the US E nergy Information Administration. http://www.eia.gov/
4 Emissions factors derived from A ppendix EA-1 of US Department of Energy’s Energy Assessment for Proposed Energy Conservation Standards fo r Residential Clothes Washers
5 The annualized capital equipmen t cost is calculated by multipl ying the installed equipment cost by the capital recovery factor of 0.1627.

The operating cost for electric water heaters is higher than fo r propane and natural gas units, due to the higher cost of e lectricity compared to propan e and natural gas. However, the initial purchase pr ice is lower for electric units . Converting to an electric water heater also may require m odifications to the residence an d have associated costs.

Evaluation Findings Although residential wa ter heaters are not a significant source of PM2.5, NOx, or SOx in the Valley, the District has eva luated all potential control te chnologies and all control technologies achieved in practic e in other areas or included in other state implementation plans. As demons trated above, Rule 4902 current ly has in place the most stringent measures feasible to implement in the Valley and therefore meets or exceeds both BACM and MSM require ments for this source category . As the District continues to develop new attainm ent plans that address more str ingent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emissions from residential water heater s in the Valley.San Joaquin Valley Unified Air Polluti on 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 rul e that applies to any person wh o sells, offers for sale, installs or solicits the insta llation of natural-gas-fired, fan -type central furnaces, for use within the Valley with a rat ed heat input capacity of less than 175,000 Btu/hour, and for combination heating a nd cooling units with a rated cooling capa city of less than 65,000 Btu/hour.

The rule was adopted on Octobe r 20, 2005 to establish NOx limit s for residential central furnaces supplied, sold, or inst alled in the Valley. The rule set a NOx emission limit of 0.093 pounds per million Btu of h eat output (lb/MMBtu). EPA fi nalized approval for Rule 4905 on May 30, 2007. Rule 4905 was amended on J anuary 22, 201 5 to:

 Lower the NOx emission limit fo r 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 install ed 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 amendment s exceeded SCAQMD R ule 1111 requireme nts and made Rule 4905 the most stringen t rule in the nation for this s ource category.

Source Category Affected parties include furnac e manufacturers, residential hea ting wholesalers, supply stores, contractors and end-user s. The point-of-sale approach has allowed the District to achieve NOx reductions with out placing an undue financial bu rden on the residents, operators and businesses that se ll these units in the Valley.

Applicable units are used in approximately 71% of Valley reside nces and are not labeled for retail as “residentia l” or “commercial” furnaces. Units used in commercial buildings, which are subject to the requirements of Rule 4905 a s of the January 2015 amendments, are essentially the same as resident ial units with the exception of possible differences in usage patterns and indoor/outdoor locat ion. Research for the analyses in the January 2015 amendm ents estimated 1,252,190 res idential and commercial units will be operat ing in the Valley in 2017. Repl acement will occur gradually as these units reach th e end of the 20-year useful li fe.

The most common residential and c ommercial heat sources are boi lers and furnaces; other heating options include h eat pumps, active solar heating, electric heating, wood or pellet stoves, portable and direc t vent wall heaters, and firep laces. 87 Heat distribution systems are either central heat ing, 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-he ating

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

C-176 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard distributed throughout the building , or point-of-use or space h eating, meaning supplemental heat is provided to a specific room. Types of cen tral heating systems include forced air, steam radi ant, radiant, hot water baseboard s, and electric baseboards. Types of space heaters include wood or pellet stov es, portable and direct vent wall heaters, and firepl aces. Fuel types include natural gas, propane, heating oil, electricity, and solid fuel s 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, whi ch generally determines the ty pe of distribution system used, is selected based on many factors. The most important fa ctor is geographical location, which determines the climate and types of available f uel. 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 a vailable.

Rule 4905 applies to furnaces f ueled by natural gas that use fo rced air distribution, the most common type of heating syst em for residential and commerci al buildings. Central furnaces are controlled by a ther mostat, 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 burner s, which combust the gas direc tly into the heat exchangers. A blower pulls air fr om outside the building throu gh 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 separa te duct. Condensing units use an additional heat exc hanger to extract the latent he at in the flue (exhaust) gas by cooling the combustion ga sses to near ambient temperatur e 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 manu factured homes utilize the same types of materials and operating principles as commercial and resi dential units; however, signif icant 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 conc entric vent where the combust ion air is drawn in through the outer ring, while e xhaust gases are vented through the inside core of the vent pipe. The air is pre-heat ed because the cold outside air does not mix well with the fuel, while pre-heated air blends well and allows for quieter i gnition and combustion. Furnaces installed in manufactured homes also have to comply wi th 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-conservati on-standards-for-residential

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

C-177 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 0.20 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from n atural gas-fired, fan-type cen tral furnaces are lower than the BACM/MSM significance thresholds. Therefore, the Clea n Air Act does not require a control measure evalua tion for this source category f or the purpose of satisfying BACM/MSM requirement s; however, the District has sti ll conducted a full control measure evaluation for natural gas-fired, fan-type cent ral furnaces.

How does District Rule 4905 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, N ESHAP, or MACT requirements f or this source category.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 4905 compar e to rules in o ther air distr icts?

SCAQMD

 Rule 1111 (Reduction of NOx Emi ssions from Natural Gas-Fired, Fan-Type Central Furnaces)

The District evaluated the require ments contained within SCAQMD Rule 1111 and found no requirements that were more stringent than those alrea dy in Rule 4905.

BAAQMD

 Regulation 9 Rule 4 (Nitrogen Ox ides from Fan Type Residential Central Furnaces)

The District evaluated the requi rements contained within BAAQMD Regulation 9 Rule 4 and found no requirement s that were more stringent than those a lready in Rule 4905.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-178 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard SMAQMD

 Rule 414 (Water Heaters, Boile rs and Process Heaters Rated Les s than 1,000,000 BTU Per Hour)

The District evaluated the require ments 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 require ments contained within VCAPCD Rule 74.22 and found no requirements that were more stringent than those alrea dy in Rule 4905.

Evaluation Findings Even though natural gas-fired, fan- type central furnaces are no t a significant source of PM2.5, NOx, or SOx in the Valle y, the District has evaluated al l potential control technologies and all control tec hnologies achieved in practice in other areas or included in other state implementation pl ans. As demonstrated above, Ru le 4905 currently has in place the most stringent measur es feasible to implement in t he Valley and therefore meets or exceeds bot h BACM and MSM requir ements for this source category. As the District continues to develop new attainment plans that address more stringent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emissions from natural gas-fired, fan-t ype central furnaces in the Valley.San Joaquin Valley Unified Air Polluti on 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, requi rements, administrative requi rements, recordkeeping requirements, and test methods se t forth in this rule are appli cable to all rules under District Regulation VIII (Fugitive PM10 Prohibitions). The Reg ulation VIII series was adopted in November 2001, and s ubsequently amended in 2004. Th e rules were developed pursuant to EPA guideli nes for serious PM10 nonattain ment areas. In 2004, the District adopted amendments to Regulation VIII to upgrade e xisting RACM level rules to meet the more stringent BACM level required in serious PM10 nonattainment

areas.

Emissions Inventory There is no specific emissions i nventory associated with Rule 8 011.

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 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, N ESHAP, or MACT guidelines for this source category. The following federal r egulations apply to sources co vered under Rule 8011:

 Rule 57 FR 13498 (General Pre amble for Title I of CAA)

The District evaluated the requi rements contained within the Ge neral Preamble and found no requirements that were more stringent than those alrea dy in Rule 8011.

 EPA-450/2-92-004 (Fugitive Dust Background Document and Techni cal Information Document for Best Ava ilable Control Measures (BACM) )

The District evaluated the requi rements contained within the Fu gitive Dust Background Document and Technical Informati on Document for BACM and found no requirements that were more stringent than th ose already in Rule 8011.San Joaquin Valley Unified Air Polluti on 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 re gulations applicable to this source catego ry.

How does District Rule 8011 compar e to rules in o ther air distr icts? There are no analogous rules fo r this source category in BAAQMD

.

SCAQMD

 Rule 1156 (Further Reductions o f Particulate Emissions from Ce ment Manufacturing Facilities)

The District evaluated the require ments contained within SCAQMD Rule 1156 and found no requirements that were more stringent than those alrea dy in Rule 8011.

 Rule 1157 (PM10 Emission Reduc tions form Aggregate and Related Operations)

The District evaluated the require ments contained within SCAQMD 1157 and found no requirements that were more str ingent than those already in Rul e 8011.

SMAQMD

 Rule 403 (Fugitive Dust)

The District evaluated the require ments 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 require ments 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 requi rements contained within CCDAQ Section 41 and found no requirements that were more stringent than those already in Rule 8011.

Additional Emission Reduc tion Opportunities This rule is administrative in nature, and is intended to be a supplementary rule to the other District Regulation VIII ru les. Opportunities for emissi on reductions would be found with each of the other Regulation VIII r ules and would no t be identified as a possibility for this rule. As su ch, there are no emission redu ction opportunities for Rule 8011.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-181 Appendix C: BACM and MSM for Stationary and Area Sources 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 imple mentation plans. As demonstrat ed above, Rule 8011 currently has in place the mos t stringent measures feasible to implement in the Valley and therefore meets or exceeds b oth BACM and MSM requirements f or this source category. As the District conti nues to develop new attainment plans that address more stringent National Ambient Air Q uality Standards, the District will continue to evaluate potential opportunities to reduce emissions from outdoor fugiti ve dust sources in the Valley.San Joaquin Valley Unified Air Polluti on 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 re lated disturb ances of soil, including land clearing, grubbing, scraping, excavation, extraction, land leveling, grading, cut and fill operations, travel on the si te, travel access roads to and from the site, and demolition activities. The rule also applie s to construction of new landf ill disposal sites or modifications to existing landfi ll disposal sites prior to comm encement of landfilling activities.

In 2004, the District adopted amendm ents to Regulation VIII to upgrade existing RACM level rules to meet the more str ingent BACM level required in s erious PM10 nonattainment areas. Rule 80 21 was amended to add dust suppres sion requirements, and to require submittal of Dust Control Plans on residential c onstruction 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 4.0 tons per day (tpd) for PM2.5 dust, 13.1 t pd for NOx, and 1.0 tpd for SOx . As identified in the above table, emissions from constr uction, demolition, excavatio n, 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 o f satisfying BACM/MSM requirem ents; however, the District has still conducted a fu ll control measure evaluation for construction, demolition, excavation, extraction, and ot her earthmoving activities.

While District Regulation VIII was critical in the District’s a ttainment of the PM10 standards, a variety of studies have been conducted which may i ndicate 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 quant ification of the PM2.5 fract ion is required to develop a more accurate emissions invent ory for the various activities under Rule 8021 and to indicate the level of signific ance of those PM2.5 emissions. A t this time, PM2.5 emission control factors are no t well defined and it is not kno wn if PM10 controls areSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-183 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard effective for reducing PM2.5 fo r earthmoving activities. Modeli ng results show that the geologic fraction of PM2.5 found in the Valley makes a relative ly small contribution to overall PM2.5 mass. In addition, s tudies have shown that geolo gic dust alone has relatively low toxicity.

How does District Rule 8021 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, N ESHAP, or MACT requirements f or this source category. The following federal regulations apply to sources c overed under Rule 8021:

 Rule 57 FR 13498 (General Pre amble for Title I of CAA)

The District evaluated the requi rements contained within the Ge neral Preamble and found no requirements that were more stringent than those alrea dy in Rule 8021.

 EPA-450/2-92-004 (Fugitive Dust Background Document and Techni cal Information Document for BACM)

The District evaluated the requi rements contained within the Fu gitive Dust Background Document and Technical Informati on Document for BACM and found no requirements that were more stringent than th ose already in Rule 8021.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 8021 compar e to rules in o ther air distr icts? There are no analogous rules fo r this source category in BAAQMD

.

SCAQMD

 Rule 1156 (Further Reductions o f Particulate Emissions from Ce ment Manufacturing Facilities)

The District evaluated the require ments contained within SCAQMD Rule 1156 and found no requirements that were more stringent than those alrea dy in Rule 8021.

 Rule 1157 (PM10 Emission Reduc tions form Aggregate and Related Operations)

The District evaluated the require ments contained within SCAQMD Rule 1157 and found no requirements that were more stringent than those alrea dy in Rule 8021.

SMAQMD

 Rule 403 (Fugitive Dust)

The District evaluated the require ments contained within SMAQMD Rule 403 and found no requirements that were more stringent than those already in Rule 8021.San Joaquin Valley Unified Air Polluti on 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 require ments 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 C ontrol for Construction Activ ities)

The District evaluated the requi rements contained within CCDAQ Section 94 and found no requirements that were more stringent than those already in Rule 8021.

Additional Emission Reduc tion Opportunities District analysis identified one potential opportunity for this source category; to require signs to be posted at certain siz e work sites, asking the publi c to contact the District if the work site is producing si gnificant dust emissions. While t his potential opportunity would increase the awareness of the workers and the public, the re is no conclusion that it would result in reduced emi ssions. If emissions are reduced , it is not likely to result in quantifiable emission reductions.

Evaluation Findings Even though construction, demolit ion, excavation, extraction, a nd other earthmoving activities are not a significan t source of PM2.5, NOx, or SOx i n the Valley, the District has evaluated all potential cont rol technologies and all contro l technologies achieved in practice in other areas or include d in other state implementati on plans. As demonstrated above, Rule 8021 curr ently has in place the most s tringent measures feasible to implement in the Va lley and therefore meets or exce eds both BACM and MSM requirements for this sour ce category. As the District con tinues to develop new attainment plans that address mo re stringent National Ambient A ir Quality Standards, the District will continue to e valuate potentia l opportunities to reduce emissions from construction, demolition, excav ation, extraction, and other ear thmoving activities in the Valley.San Joaquin Valley Unified Air Polluti on 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 outsi de storage and handling of any un packaged material, which emits or has th e potential to emit dust when stored or ha ndled. Rule 8031 requires bulk handling and storage facilities to restrict dust from material transfer, and reduce emissions from transport m aterial and storage piles that emit dust. Facilities subject to Rule 8031 ar e required use contro l measures to ensur e that visible dust emissions are limited to 20% opac ity or less. These control me asures can include application of water or other dus t stabilizers, covering of bul k materials, construction of wind barriers, covering of haul trucks, and other measures.

In 2004, the District adopted amendm ents to Regulation VIII to upgrade existing RACM level rules to meet the more str ingent BACM level required in s erious PM10 nonattainment areas. Rule 8031 was amended to require construc tion 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 4.0 tons per day (tpd) for PM2.5 dust, 13.1 t pd for NOx, and 1.0 tpd for SOx . As identified in the above table, emissions from bulk ma terials are lower than the B ACM/MSM significance thresholds. Therefore, the Clean Air Act does not require a co ntrol measure evaluation for this source category for t he purpose of satisfying BACM/MSM requirements; however, the District has still co nducted a full control measur e evaluation for bulk materials.

Also, while District Regulation VIII was critical in the Distri ct’s attainment of the PM10 standards, a variety of studies have been conducted which may i ndicate 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 quant ification of the PM2.5 fract ion is required to develop a more accurate emissions invent ory for the various activities under Rule 8031 and to indicate the level of signific ance of those PM2.5 emissions. A t this time, PM2.5 emission control factors are no t well defined and it is not kno wn if PM10 controls are effective for reducing PM2.5 fo r bulk materials. Modeling resu lts show that the geologicSan Joaquin Valley Unified Air Polluti on 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 Vall ey 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 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, NESH AP, or MACT requirements f or this source category. The following federal regulations apply to sources c overed under Rule 8031:

 Rule 57 FR 13498 (General Pre amble for Title I of CAA)

The District evaluated the requi rements contained within the Ge neral Preamble and found no requirements that were more stringent than those alrea dy in Rule 8031.

 EPA-450/2-92-004 (Fugitive Dust Background Document and Techni cal Information Document for BACM)

The District evaluated the requi rements contained within the Fu gitive Dust Background Document and Technical Informa tion Document for BACM and found no requirements that were more stringent than th ose already in Rule 8031.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 8031 compar e to rules in o ther air distr icts? There are no analogous rules fo r this source category in BAAQMD

.

SCAQMD

 Rule 1156 (Further Reductions o f Particulate Emissions from Ce ment Manufacturing Facilities)

The District evaluated the require ments contained within SCAQMD Rule 1156 and found no requirements that were more stringent than those alrea dy in Rule 8031.

 Rule 1157 (PM10 Emission Reduc tions form Aggregate and Related Operations)

The District evaluated the require ments contained within SCAQMD Rule 1157 and found no requirements that were more stringent than those alrea dy in Rule 8031.

SMAQMD

 Rule 403 (Fugitive Dust)

The District evaluated the require ments contained within SMAQMD Rule 403 and found no requirements that were more stringent than those already in Rule 8031.San Joaquin Valley Unified Air Polluti on 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 require ments 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 requi rements contained within CCDAQ Section 41 and found no requirements that were more stringent than those already in Rule 8031.

Additional Emission Reduc tion Opportunities Rule 8031 currently employs the best dust mitigation techniques ; there are no additional potential opportunities for fu rther emissions reductions from t his source category. Rule 8031’s requirement of limiting opac ity to 20% is as or more str ingent than any other district’s rule and compliance with the standard requires signi ficant mitigation efforts from sites that store bulk materials.

Evaluation Findings Even though storage and handling of bulk materials are not a si gnificant source of PM2.5, NOx, or SOx in the Valle y, the District has evaluated al l potential control technologies and all control tec hnologies achieved in practice in other areas or included in other state implementation pl ans. As demonstrated above, Ru le 8031 currently has in place the most stringent measur es feasible to implement in t he Valley and therefore meets or exceeds bot h BACM and MSM requir ements for this source category. As the District continues to develop new attainment plans that address more stringent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emissions from bulk materials handling in the Valley.San Joaquin Valley Unified Air Polluti on 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 CAR RYOUT AND TRACKOUT

Source Category Rule 8041 applies to the prev ention 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 con tains requirements for: removing carryout and trackout a t the end of each workday; thre sholds for any site with 150 daily vehicle trips; addressi ng carryout and trackout in Du st Control Plans; removing carryout and trackout i n urban areas; paved interior r oads; and prevention of carryout and trackout.

In 2004, the District adopted amendm ents to Regulation VIII to upgrade existing RACM level rules to meet the more str ingent BACM level required in s erious PM10 nonattainment areas. Rule 8041 was amended to require a thresh old for vehicles with three or more axles to takes ac tions for carryout/trackout. Am endments included a threshold for projects located in rural areas, a provision requ iring actions within half an hour if specified measures are i nsufficient to prevent carryout /trackout, and specifications for dust collect ors, gravel pads, and paved surf aces.

Emissions Inventory The emissions from this source c ategory are incl uded in Rule 80 61 (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 a ttainment of the PM10 standard, a variety of studies have been conducted which may in dicate 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 quant ification of the PM2.5 fract ion is required to develop a more accurate emissions invent ory for the various activities under Rule 8041 and to indicate the level of signific ance of those PM2.5 emissions. A t this time, PM2.5 emission control factors are no t well defined and it is not kno wn if PM10 controls are effective for reducing PM2.5 fo r carryout and trackout. Modeli ng results show that the geologic fraction of PM2.5 found in the Valley makes a relative ly small contribution to overall PM2.5 mass. In addition, s tudies have shown that geolo gic dust alone has relatively low toxicity.San Joaquin Valley Unified Air Polluti on 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 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, NESH AP, or MACT requirements f or this source category. The following federal regulations apply to sources c overed under Rule 8041:

 Rule 57 FR 13498 (General Pre amble for Title I of CAA)

The District evaluated the requi rements contained within the Ge neral Preamble and found no requirements that were more stringent than those alrea dy in Rule 8041:

 EPA-450/2-92-004 (Fugitive Dust Background Document and Techni cal Information Document for BACM)

The District evaluated the requi rements contained within the Fu gitive Dust Background Document and Technical Informa tion Document for BACM and found no requirements that were more stringent than th ose already in Rule 8041.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 8041 compar e to rules in o ther air distr icts? There are no analogous rules fo r this source category in BAAQMD

.

SCAQMD

 Rule 1156 (Further Reductions o f Particulate Emissions from Ce ment Manufacturing Facilities)

The District evaluated the require ments contained within SCAQMD Rule 1156 and found no requirements that were more stringent than those alrea dy in Rule 8041.

 Rule 1157 (PM10 Emission Reduc tions form Aggregate and Related Operations)

The District evaluated the require ments contained within SCAQMD Rule 1157 and found no requirements that were more stringent than those alrea dy in Rule 8041.

SMAQMD

 Rule 403 (Fugitive Dust)

The District evaluated the require ments 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 Polluti on 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 require ments 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 C ontrol for Construction Activ ities)

The District evaluated the requi rements contained within CCDAQ Section 94 and found no requirements that were more stringent than those already in Rule 8041.

Additional Emission Re duction Opportunities Two potential opportunities to r educe emissions were identified , evaluated, and determined to not be feasible.

The first potential emission r eduction opportunity would be to reduce the threshold for daily trips per worksite that requi res a carryout and trackout prevention system (currently 150 trips). Reducing this threshold would require s maller worksites to install costly trackout prevention equip ment like wheel washers, metal grates, and gravel pads. At these smaller worksites the emission reductions that would b e 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 distan ce from the nearest unpaved exit point of a site at w hich trackout must be immediat ely cleaned (currently 50 feet). Lowering this threshold would significantly increase th e use of street sweepers and their associated emissions, whi ch are more toxic to human h ealth (see Chapter 3). Therefore, this opport unity has been determined to not be feasi ble.

Evaluation Findings The District has evaluated all potential control technologies a nd all control technologies achieved in practice in other ar eas or included in other state implementation plans. As demonstrated above, Rule 8041 curr ently has in place the most s tringent measures feasible to implement in the Va lley and therefore meets or exce eds both BACM and MSM requirements for this sour ce category. As the District con tinues to develop new attainment plans that address mo re stringent National Ambient A ir Quality Standards, the District will continue to e valuate potentia l opportunities to reduce emissions from carryout and trackout of mud and di rt onto public paved roads i n the Valley.San Joaquin Valley Unified Air Polluti on 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 urb an areas, or 3.0 acres or more within rural areas tha t contains at least 1,000 square feet of disturbed surface area. The rule has requirements for limiting visible dust emis sions (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 are as.

In 2004, the District adopted amendm ents to Regulation VIII tha t upgraded existing RACM level rules to meet the more stringent BACM level required in serious PM10 nonattainment areas. Rule 80 51 was amended to add applicabilit y 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 4.0 tons per day (tpd) for PM2.5 dust, 13.1 t pd 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 co ntrol measure evaluation for this source category for t he purpose of satisfying BACM/MSM requirements; however, the District has still co nducted a full control measur e evaluation for open

areas.

Also, while District Regulation VIII was critical in the Distri ct’s attainment of the PM10 standard, a variety of studies have been conducted which may in dicate 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 quant ification of the PM2.5 fract ion is required to develop a more accurate emissions invent ory for the various activities under Rule 8051 and to indicate the level of signific ance of those PM2.5 emissions. A t this time, PM2.5 emission control factors are no t well defined and it is not kno wn if PM10 controls are effective for reducing PM2.5 for open areas. Modeling results s how that the geologic fraction of PM2.5 found in the S an Joaquin Valley makes a relat ively small contribution to overall PM2.5 mass. In addition , studies have shown that geo logic dust alone has relatively low toxicity.San Joaquin Valley Unified Air Polluti on 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 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, NESH AP, or MACT requirements f or this source category. The following federal regulations apply to sources c overed under Rule 8051:

 Rule 57 FR 13498 (General Pre amble for Title I of CAA)

The District evaluated the requi rements contained within the Ge neral Preamble and found no requirements that were more stringent than those alrea dy in Rule 8051.

 EPA-450/2-92-004 (Fugitive Dust Background Document and Techni cal Information Document for BACM)

The District evaluated the requi rements contained within the Fu gitive Dust Background Document and Technical Informati on Document for BACM and found no requirements that were more stringent than th ose already in Rule 8051.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 8051 compar e to rules in o ther air distr icts? There are no analogous rules fo r this source category in BAAQMD

.

SCAQMD

 Rule 1156 (Further Reductions o f Particulate Emissions from Ce ment Manufacturing Facilities)

The District evaluated the require ments contained within SCAQMD Rule 1156 and found no requirements that were more stringent than those alrea dy in Rule 8051.

 Rule 1157 (PM10 Emission Reduc tions form Aggregate and Related Operations)

The District evaluated the require ments contained within SCAQMD Rule 1157 and found no requirements that were more stringent than those alrea dy in Rule 8051.

SMAQMD

 Rule 403 (Fugitive Dust)

The District evaluated the require ments 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 Polluti on 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 require ments 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 requi rements contained within CCDAQ Section 90 and found no requirements that were more stringent than those already in Rule 8051.

Additional Emission Re duction Opportunities The District’s analysis did not i dentify any pot ential opportun ities to further reduce emissions from this source cat egory beyond those emissions that are already being reduced by rule requirements. A s a part of due diligence effor ts in seeking addition emission reduction opportunities , the following two potential o pportunities have been identified to improve rule cl arity. 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 ut ilizing mowing and/or cutting. A dding language to specify that weed abatement by tilling is not exempt would also add cla rity to the rule. While these opportunities could clarif y rule language, neither would likely generate emissions reductions from this source category.

Evaluation Findings Even though open areas are not a s ignificant source of PM2.5, N Ox, or SOx in the Valley, the District has evaluat ed all potential control techno logies and all control technologies achieved in practic e in other areas or included in other state implementation plans. As demons trated above, Rule 8051 current ly has in place the most stringent measures feasible to implement in the Valley and therefore meets or exceeds both BACM and MSM require ments for this source category . As the District continues to develop new attainm ent plans that address more str ingent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emissions from open areas in the Valley

.San Joaquin Valley Unified Air Polluti on 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 f or the construction of new and modified paved roads in accordance with published gui delines by the American Associa tion of State Highway and Transportation Officials fo r road construction and applies to any paved, unpaved, or modified public or private r oad, street highway, freeway, alley way, access drive, access easement, or driveway. The rule a lso allows alt ernative 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 amendm ents to Regulation VIII to upgrade existing RACM level rules to meet the more str ingent BACM level required in s erious PM10 nonattainment areas. Rule 8061 was amended to replace the exis ting 75 maximum daily vehicle trip threshold wi th a 26 annual average daily veh icle trips (AADT) threshold on unpaved roads, and require all new unpaved roads within urba n 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 a ttainment of the PM10 standard, a variety of studies have been conducted which may in dicate 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 quant ification of the PM2.5 fract ion is required to develop a more accurate emissions invent ory for the various activities under Rule 8061 and to indicate the level of signific ance of those PM2.5 emissions. A t this time, PM2.5 emission control factors are no t well defined and it is not kno wn if PM10 controls are effective for reducing PM2. 5 for paved and unpaved roads. Mode ling results show that the geologic fraction of PM2.5 found in the San Joaquin Valley makes a relatively small contribution to overall PM2.5 ma ss. In addition, studies have shown that geologic dust alone has relatively low toxicity.

How does District Rule 8061 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, NESH AP, or MACT requirements f or this sourceSan Joaquin Valley Unified Air Polluti on 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 c overed under Rule 8061:

 Rule 57 FR 13498 (General Pre amble for Title I of CAA)

The District evaluated the requi rements contained within the Ge neral Preamble and found no requirements that were more stringent than those alrea dy in Rule 8061.

 EPA-450/2-92-004 (Fugitive Dust Background Document and Techni cal Information Document for BACM)

The District evaluated the requi rements contained within the Fu gitive Dust Background Document and Technical Informa tion Document for BACM and found no requirements that were more stringent than th ose already in Rule 8061.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 8061 compar e to rules in o ther air distr icts? There are no analogous rules fo r this source category in BAAQMD

.

SCAQMD

 Rule 1156 (Further Reductions o f Particulate Emissions from Ce ment Manufacturing Facilities)

The District evaluated the require ments contained within SCAQMD Rule 1156 and found no requirements that were more stringent than those alrea dy in Rule 8061.

 Rule 1157 (PM10 Emission Reduc tions form Aggregate and Related Operations)

The District evaluated the require ments contained within SCAQMD Rule 1157 and found no requirements that were more stringent than those alrea dy in Rule 8061.

SMAQMD

 Rule 403 (Fugitive Dust)

The District evaluated the require ments 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 require ments contained within VCAPCD Rule 55 and found no requirements that were more stringent than those already in Rule 8061.San Joaquin Valley Unified Air Polluti on 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 requi rements contained within CCDAQ Section 91 and found no requirements that were more stringent than those already in Rule 8061.

 Section 93 (Fugitive Dust from P aved Roads and Street Sweeping Equipment)

The District evaluated the requi rements contained within CCDAQ Section 93 and found no requirements that were more stringent than those already in Rule 8061.

Additional Emission Re duction Opportunities The following potentia l opportunity to reduce emissions from pa ved and unpaved roads was determined to be infeasible . Section 5.2.1 of the rule req uires dust control measures for any unpaved road s egments with 26 or more annual a verage daily trips. A potential opportunity to reduce emissions would be to lower t his threshold. This would require more ow ners/operators to implement at least one c ontrol measure to reduce fugitive emissions.

Analysis of the emission inventor y indicates that the majority of the particulate emissions attributable to unpav ed roads are generated from unpa ved roads already subject to the mitigation require ments of Rule 8061. Therefore , the remaining portion of emissions associated with unpaved roads (less than 26 AADT) doe s not provide an opportunity for additional e missions reductions.

Additionally, emissions from unpav ed roads are lowest in the wi nter months, when the District’s PM2.5 24-hour exceedan ces occur. District staff bel ieves the winter average PM2.5 emission inventory is ove restimated for the following rea sons:

 ARB methodology assumes that rai nfall of at least 0.01 inch on any day mitigates unpaved road dust for 24 hours

 71% of the days with precipitati on occur during the winter mon ths.

 Many US Forest and Park Roads are inaccessible during winter m onths due to increased amounts of rain and s now, yet emissions from these ro ads 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 a nd all control technologies achieved in practice in other ar eas or included in other state implementation plans. As demonstrated above, Rule 8061 curr ently has in place the most s tringent measures feasible to implement in the Va lley and therefore meets or exce eds both BACM and MSM requirements for this sour ce category. As the District con tinues to develop newSan Joaquin Valley Unified Air Polluti on 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 mo re stringent National Ambient A ir Quality Standards, the District will continue to e valuate potentia l opportunities to reduce emissions from paved and unpaved roads in the Valley.San Joaquin Valley Unified Air Polluti on 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 unpav ed vehicle/equipment areas, par king, fueling and service areas, and shipping, rec eiving, and transfer areas. Th e rule contains requirements for when vehicle tr affic reaches or exceeds specif ied thresholds, limitations on visible dust emi ssions (VDE), compliance require ments with the conditions of a stabilized surface, and lists control technique s, which could be implemented to limit VDE and to comply with the conditions of a stabilized surface.

In 2004, the District adopted amendm ents to Regulation VIII to upgrade existing RACM level rules to meet the more str ingent BACM level required in s erious PM10 nonattainment areas. Rule 8071 wa s amended to remove the 1.0 a cre or larger threshold; change the vehicle thre shold from 75 vehicle daily t rips to 50 annual average daily trips; add a single day peak threshold of 150 VDT or requ ire control for sources that exceed the 150 VDT thres hold limit on at least 30 days per year; and add a requirement whenever 25 or more three-axle vehicle trips will o ccur 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 4.0 tons per day (tpd) for PM2.5 dust, 13.1 t pd for NOx, and 1.0 tpd for SOx . As identified in the above table, emissions from unpav ed vehicle/equipment traffic a reas are lower than the BACM/MSM significance threshol ds. Therefore, the Clean Air Act does not require a control measure evaluation for this source category for the pur pose of satisfying BACM/MSM requirements; however , the District has still conducte d a full control measure evaluation for unpaved v ehicle/equipment traffic areas.

Also, while District Regulation VIII was critical in the Distri ct’s attainment of the PM10 standard, a variety of studies have been conducted which may in dicate 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 quant ification of the PM2.5 fract ion is required to develop a more accurate emissions invent ory for the various activities under Rule 8071 and to indicate the level of signific ance of those PM2.5 emissions. A t this time, PM2.5San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-199 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard emission control factors are no t well defined and it is not kno wn if PM10 controls are effective for reducing PM2.5 for unpaved vehicle/equipment traf fic areas. Modeling results show that the geologic fr action of PM2.5 found in the S an Joaquin Valley makes a relatively small contribution to overall PM2.5 mass. In addit ion, studies have shown that geologic dust alone has relatively low toxicity.

How does District Rule 8071 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, NESH AP, or MACT requirements f or this source category. The following federal regulations apply to sources c overed under Rule 8071:

 Rule 57 FR 13498 (General Pre amble for Title I of CAA)

The District evaluated the requi rements contained within the Ge neral Preamble and found no requirements that were more stringent than those alrea dy in Rule 8071.

 EPA-450/2-92-004 (Fugitive Dust Background Document and Techni cal Information Document for BACM)

The District evaluated the requi rements contained within the Fu gitive Dust Background Document and Technical Informa tion Document for BACM and found no requirements that were more stringent than th ose already in Rule 8071.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 8071 compar e to rules in o ther air distr icts? There are no analogous rules fo r this source category in BAAQMD

.

SCAQMD

 Rule 1156 (Further Reductions o f Particulate Emissions from Ce ment Manufacturing Facilities)

The District evaluated the require ments contained within SCAQMD Rule 1156 and found no requirements that were more stringent than those alrea dy in Rule 8071.

 Rule 1157 (PM10 Emission Reduc tions form Aggregate and Related Operations)

The District evaluated the require ments contained within SCAQMD Rule 1157 and found no requirements that were more stringent than those alrea dy in Rule 8071.

SMAQMD

 Rule 403 (Fugitive Dust)San Joaquin Valley Unified Air Polluti on 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 require ments 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 require ments 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 Storag e Areas)

The District evaluated the requi rements contained within CCDAQ Section 92 and found no requirements that were more stringent than those already in Rule 8071.

Additional Emission Re duction Opportunities Section 5.2.1 of current rul e language requires dust control me asures for any unpaved traffic area with 50 or more annual average daily trips. Analy sis of lowering this threshold to determine if it is a feasible option to reduce emi ssions determined that this is not a cost effective opportuni ty. Lowering the trip thresho ld of Rule 8071 would result in direct PM emission reductions , but would also result in the requirement that owners and/or operators implem ent a dust control measure. The most co mmon control measures are watering and cove ring with gravel. Local cost est imates indicate that installing a 2 inch gravel bas e with another 2 inches of top gr avel would cost approximately $1.90 per square foot, or around $83,000 per acre . Based on the small size of the emissions from this s ource category, and the estima ted mitigation costs, requiring control measures for ar eas with such minimal activity is not a cost effective option.

Evaluation Findings Even though unpaved vehicle/equipm ent traffic areas are not a s ignificant source of PM2.5, NOx, or SOx in the Valle y, the District has evaluated al l potential control technologies and all control tec hnologies achieved in practice in other areas or included in other state implementation pl ans. As demonstrated above, Ru le 8071 currently has in place the most stringent measur es feasible to implement in t he Valley and therefore meets or exceeds bot h BACM and MSM requir ements for this source category. As the District continues to develop new attainment plans that address more stringent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emission s from unpaved vehicle/equipmen t traffic areas in the Valley.San Joaquin Valley Unified Air Polluti on 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 AGRI CULTURAL SOURCES

Source Category Rule 8081 applies to “off-field” a gricultural sources including , but not limited to, unpaved roads, unpaved vehicle/equipment tr affic areas, and bulk materi als. The rule contains requirements to limit visible dust emissions (VDE) and/or to co mply with the conditions of a stabilized surface, and lis ts control techniques which cou ld be implemented to limit VDE and to comply with the conditi ons of a stabilized surface.

In 2004, the District adopted amendm ents to Regulation VIII to upgrade existing RACM level rules to meet the more str ingent BACM level required in s erious PM10 nonattainment areas. The amend ments 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; expan ded rule applicability by updatin g 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 o ccur 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 4.0 tons per day (tpd) for PM2.5 dust, 13.1 t pd for NOx, and 1.0 tpd for SOx . As identified in the above table, emissions from agricul tural sources are lower than the BACM/MSM significance thresholds. Theref ore, the Clean Air Act does not require a control measure evaluation for this sour ce category for the purpose of satisfying BACM/MSM requirements; however, the Distr ict has still conducted a full control measure evaluation for agricultural sources.

Also, while District Regulation VIII was critical in the Distri ct’s attainment of the PM10 standard, a variety of studies have been conducted which may in dicate 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 quant ification of the PM2.5 fract ion is required to develop a more accurate emissions invent ory for the various activities under Rule 8081 and to indicate the level of signific ance of those PM2.5 emissions. A t this time, PM2.5 emission control factors are no t well defined and it is not kno wn if PM10 controls areSan Joaquin Valley Unified Air Polluti on 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 fo r agricultural sources. Modelin g results show that the geologic fraction of PM2.5 found in the San Joaquin Valley make s a relatively small contribution to overall PM2.5 ma ss. In addition, studies have shown that geologic dust alone has relatively low toxicity.

How does District Rule 8081 compar e with federal and state rule s and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, NESH AP, or MACT requirements f or this source category. The following federal regulations apply to sources c overed under Rule 8081:

 Rule 57 FR 13498 (General Pre amble for Title I of CAA)

The District evaluated the requi rements contained within the Ge neral Preamble and found no requirements that were more stringent than those alrea dy in Rule 8081.

 EPA-450/2-92-004 (Fugitive Dust Background Document and Techni cal Information Document for BACM)

The District evaluated the requi rements contained within the Fu gitive Dust Background Document and Technical Informa tion Document for BACM and found no requirements that were more stringent than th ose already in Rule 8081.

State Regulations There are no state re gulations applicable to this source catego ry.

How does District Rule 8081 compar e to rules in o ther air distr icts? There are no analogous rules fo r this source category in BAAQMD

.

SCAQMD

 Rule 1156 (Further Reductions o f Particulate Emissions from Ce ment Manufacturing Facilities)

The District evaluated the require ments contained within SCAQMD Rule 1156 and found no requirements that were more stringent than those alrea dy in Rule 8081.

 Rule 1157 (PM10 Emission Reduc tions form Aggregate and Related Operations)

The District evaluated the require ments contained within SCAQMD Rule 1157 and found no requirements that were more stringent than those alrea dy in Rule 8081.

SMAQMD

 Rule 403 (Fugitive Dust)

The District evaluated the require ments contained within SMAQMD Rule 403 and found no requirements that were more stringent than those already in Rule 8081.San Joaquin Valley Unified Air Polluti on 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 require ments 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 requi rements contained within CCDAQ Section 91 and found no requirements that were more stringent than those already in Rule 8081.

Additional Emission Re duction Opportunities The District’s analysis did not i dentify any pot ential opportun ities to further reduce emissions from this source category. However, a potential oppo rtunity to improve enforceability of this for this source category has been identi fied. Section 5.4 of the rule references California Vehicl e Code section 23112-23113 for prev ention of carryout and trackout. This section could be removed and replaced with spec ific language from the vehicle code, however, as previ ously stated, this amendment wou ld not result in emissions reductions.

Evaluation Findings Even though off-field agricultura l sources are not a significan t source of PM2.5, NOx, or SOx in the Valley, the District has evaluated all potential con trol technologies and all control technologies achieved in p ractice in other areas or inc luded in other state implementation plans. As demons trated above, Rule 8081 current ly has in place the most stringent measures feasible to implement in the Valley and therefore meets or exceeds both BACM and MSM require ments for this source category . As the District continues to develop new attainm ent plans that address more str ingent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emissions fr om off-field agricultural s ources in the Valley.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-204 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.31 SC 001 LAWN AN D GARDEN EQUIPMENT

Source Category This source category includes t he commercial and residential la wn and garden sectors. The commercial sector includes l arger businesses that employ li censed contractors, public agencies and organizations t hat maintain their own prope rties or provide landscape services, and small bu sinesses serving residential pr operties. The residential sector of lawn and garden equipment includes equipm ent purchased by the public for personal use. A surve y conducted in 2003 by the Cal ifornia Air Resources Board (ARB) estimated that ther e are approximat ely 13 million p ieces of lawn and garden equipment statewide: 12% i n the commercial sector and 88 % in the residential sector. Although there are more pieces of equipment used by th e residential sector, the survey showed that the commercial sector accounts for 68% of an nual use of all lawn care equipment.

Lawn and garden equipment includes the following: chainsaws, ch ippers, commercial turf equipment, front mowers, l awn and garden tractors, lawn mo wers, leaf blowers and vacuums, rear-engine riding mowe rs, shredders, snow blowers, ti llers, trimmers, edgers, brush cutters, wood splitte rs, and other lawn and garde n equipment.

Handheld lawn and garden tools (s uch as leaf blowers) typically use two-stroke engines, while larger machines ( such as lawn and garden tractor s) use four-stroke engines. Lawn mowers are availa ble with either type of engine. Two-stroke engines rely on oil mixed with the gaso line to lubricate the engine com ponents. Much of this oil is not completely combusted by the engine thus creating high ex haust emissions. The major pollutants from a two-stro ke engine, for example, are oil -based particulates, PM2.5, NOx, and a mixture of hyd rocarbons, which combine with o ther gases in the atmosphere to form ozone, carbon monoxide, and other toxic air contaminants. Overall, four-stroke engines emit signifi cantly lower emissions than the ir two-stroke counterparts, with significantly l ower levels of hydrocarbons a nd 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 inc rease fugitive emissions including PM, toxic air contamin ants (TAC) and ultrafine partic les (UFP) resulting in a negative health impact on those in proximity to the activity.San Joaquin Valley Unified Air Polluti on 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from l awn care equipment are lower t han the BACM/MSM significance thresholds. Theref ore, the Clean Air Act does not require a control measure evaluation for this sour ce category for the purpose of satisfying BACM/MSM requirements; however, the Distr ict has still conducted a full control measure evaluation for lawn care equipment.

How would District SC 001 compar e with federal and state rules and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, NESH AP, or MACT requirements f or this source category. The following federal regulations apply to sources c overed under SC 001:

 EPA Rule 40 CFR Part 90 (Small Non-Road Spark-Ignition Engine Rule)

The EPA regulation r equired 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 compar e to rules in oth er air distric ts? There are no analogous rules fo r this source category in BAAQMD , SMAQMD, or VCAPCD.San Joaquin Valley Unified Air Polluti on 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 require ments contained within SCAQMD ’s Rule 1623 and found it was not approved by EPA and is not currently being imp lemented.

Additional Emission Reduc tion Opportunities ARB and EPA have regul atory authority ov er engine standards. A RB and EPA rules rely on natural turnover and do no t push zero emissions technol ogy; therefore, there are still opportunities to reduce emissi ons by closing the emission s gap and accelerating the use of zero emissions technology. While the District cannot es tablish new engine standards, it could regulate the use of lawn and garden equipme nt. 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 ana lysis of potential opportunities to reduce emissions includes evaluations of emerg ing technologies and potential control strategies suc h as an in-use rule, best manag ement practices, episodic controls, and zoning.

Emerging Technologies There have been recent improvem ents in the availability and app lications of zero emissions lawn care technology. Manufacturers are producing mo re electric lawn care equipment options and are developing ways to allow for this equ ipment to be used in the commercial sector, such as carrying additional battery pack s. 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 sig nificantly improved in recent years, the viability of c ordless electric technology has not been proven in the commercial sector. This is l argely due to the need for a longe r battery life and durability to allow for more frequent and pr olonged equipment use. On Mar ch 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 oper ators expressed concerns about the cost and reliability of cordless electric equipmen t, and how this equipment might af fect productivity and competition with ot her operators.San Joaquin Valley Unified Air Polluti on 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 f unded with State Air Quality Improvement Program and District program funds and prov ided eligible cordless zero-emission commercial lawn and garden equipment to commercia l landscape professionals who conduct business withi n the boundaries of the San Joaquin Valley. The final report was submitted to A RB in 2013 with plans to all ocate future incentive funds for cordless zero-emission lawn and garden equipment.

Potential Strategies to Reduce Emissions In evaluating potential contro l strategies, the District’s anal ysis identified a number of potential regulatory and outreach opportuni ties. However, ther e are no recommended regulatory actions at this time due to the need to revise the e missions inventory. The District will continue evaluating which o f the following regula tory approaches are feasible from a regulatory standpoi nt as well as from a public health standpoint.

In-Use Rule One potential control strategy would be to require the use of t he cleanest available equipment by prohibiting the use of gas combustion equipment. This could be achieved through a point-of-sale rule im plementing a tiered approach or by phasing in restrictions as lower or zero-emissions techno logy becomes more available in the future. This type of control measure could potentia lly eliminate the portion of e missions resulting from the combustion of fuel. There mi ght also be a need to bifurcate th is type of regulation due to the varying availability o f low or zero-emitting equipment i n the residential sector versus commercial sector.

Best Management Practices Another potential control stra tegy would be to require operator s to implement Best Management Practices (BMPs) usi ng a menu approach for the use o f 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, si dewalks, or neighboring propertie s)

 Particulate prevention practice s (e.g. no leaf blower use on b are dirt surfaces or very dusty paved surfaces, etc.)

This BMP option would focus on providing education on safety an d more efficient use of equipment. Enforcing this type of rule could be challenging du e to the large number of operators, variation in size o f businesses, and the widespread distribution of operator activities. Operators could be re quired to complete a certific ation course so that they can be educated on pr oper work practices. The District could also require operators to show a certificate of completi on to purchase gas equipment afte r a certain date, to ensure contractors operating gas equipment are using the most e ffective work practices to protect public health and decrease emissions.San Joaquin Valley Unified Air Polluti on 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 wh ere use of gas equipment could be limited or prohibited during high-pollution days. The re has also been precedence set throughout Californi a with numerous cities and c ounties adopting ordinances banning or prohibiting the use of leaf blowers on sp ecified days, times, distances from residential areas , or noise levels. The Distric t could create a model ordinance for cities and count ies to adopt throughout the Valle y to limit or prohibit the use of gas equipment and/or leaf b lowers. One example was foun d 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 futu re regulatory control in the Va lley 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 oper ations restrictions

Foster City Los Angeles Palo Alto Restrictions on distance fr om residential unit and hours allowed to operate

Sacramento Sunnyvale Restrictions on decibels, hour s of operations, and distance from residential areas Berkeley Beverly Hills Claremont Lawndale Los Altos Santa Barbara Bans gas blowers

Burlingame Restrict commercia l use to one day per week dependen t on determined city districts; Resi dential areas restricted by days and hours of operation Menlo Park Prohibited on Sundays , observed federal holidays, an d on "Spare the Air" days as declared by the BAAQMD Laguna Beach Santa Monica Bans all blowers

Zoning Another potential opp ortunity to reduce emissions could be thro ugh the promotion of “zones,” where gas equipment would be prohibited or limited in designated zones, such as those close to schools, par ks, etc. This approach, known as “greenzoning,” is currently being pione ered in Los Angeles C ounty. Greenzoning c ould potentially be included as a part of the Health y Air Living outreach program t o individual businesses, schools, cities, and counties. A related option could be limit ing gas powered equipment use in certain zones to designat ed days of the week, similar to days allowed to water residential yards. This approach was recently adopted by the c ity of Burlingame for leaf blower use only. Cleaner ele ctric equipment would have an adva ntage by still being able to be operated on the days or areas that gas powered equip ment is limited. This strategy would also be a win-win by reducing noise nuisances in neighborhoods andSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-209 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard near schools. The District could provide model ordinances to c ities 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 ad vancement programs at this time. The recommendati on 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 cap able of reducing emissions in th e 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 Co rdless Zero-Emission Commercia l Lawn and Garden Equipment evaluation to ARB in June 2013.

Evaluation Findings Even though lawn and gar den equipment are not a significant sou rce of PM2.5, NOx, or SOx in the Valley, the District has evaluated all potential con trol technologies and all control technologies achieved in p ractice in other areas or inc luded in other state implementation plans. The Dis trict cannot establish new engine standards; therefore, it is recommended the District conti nue current incentive programs in order to close the emissions gap and accelerate the us e of zero emissions technolo gy, ultimately exceeding both BACM and MSM require ments for this source catego ry. As the District continues to develop new attainm ent plans that address more str ingent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emission s from lawn and garden equipmen t in the Valley.San Joaquin Valley Unified Air Polluti on 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 ENERG Y EFFICIENCY

Source Category This category does not include specific emissions inventory sou rces in the Valley, but rather the opportunity to reduc e emissions from all Valley sect ors through the promotion of energy efficiency and conserva tion measures. Generally, emi ssions reductions could be obtained from reductions in el ectrical power generation or f uel through the implementation of suc h measures. Potential areas of focus incl ude residential and commercial buildings, manufacturi ng and industrial facilities, agricultural operations, and oil/gas production and processing facilities.

Additional Emission Reduc tion Opportunities Energy use is not a regulated activity; however, emissions from the generation of electricity are regul ated at power plants. Overall, electricit y generation in C alifornia is relatively clean when compared to emission factors (criteria po llutants and greenhouse gases (GHG)) from other states . California has been on the for efront of developing renewable energy sources, and has implemented regulations to en sure cleaner nonrenewable energy. Whereas coal-fi red electricity generation pr ovides a significant percentage of electricity in other parts of the country, especi ally the eastern states, California relies more heavily on natural gas-fired power plant s, which have lower emission rates for criteria pollutants and GHGs.

California imports 30% of its e lectricity from surrounding stat es (2010 data from California Energy Commission (CEC )). The state’s four major ut ility companies use this electricity, as well as resource s from around the state to supp ly continuous, reliable electricity to its customers. The inter-related nature of Cali fornia’s electricity transmission leads to a complex r elationship between local ener gy efficiency programs and emissions reductions. Ener gy 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 (peake r) power plants with in the Valley. Likewise, Valley demand may be me t with electricity from margin al power plants outside the Valley. To complicate matters , which marginal plant is use d can depend on the time of day, the minute-by-minute energ y market, or other highly var iable factors.

In 2010, the CEC commissioned an ev aluation of energy usage and potential reductions from energy efficiency and renew able energy measures. Using so phisticated dispatch modeling, Synapse Energy Economi cs Inc. (Synapse) was able to e stimate NOx emissions reductions for renewab le energy and energy efficiency projects within California and within each of the four major utility companies. 89 In preliminary model runs, Synapse showed that appr oximately 45 pounds of NOx could be reduced for each gigawatt of displaced base load electricity. Likewise, 76 poun ds 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 Polluti on Control District April 16, 2015

C-211 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard reduced for each gigawatt of dis placed peak load electricity di splaced by targeted energy efficiency efforts dur ing peak demand hours.

In 2012, EPA released a roadmap manual 90 to assist state, tribal , and local air agencies with quantifying and incl uding emissions redu ctions from energy efficiency and renewable energy in St ate Implementation Pl ans (SIPs). The doc ument focuses on emission benefits from energy p olicies and programs in the elec tric power sector. The complex nature of electricity t ransmission and dispatch, combin ed with import and export of electricity into and out of the District and Californ ia, will require sophisticated energy modeling to pinpoint emiss ions reductions attributable t o potential energy efficiency and renewable ener gy control measures.

The District’s involvement in energy efficiency and renewable e nergy is guided by its Regional Energy Efficiency Strat egy (REES), which was adopted i n January 2010. 91 This policy document identifies the District’s commitment to fo stering energy efficiency and clean energy alternatives as opportunities for emissions re ductions. The District has initiated several projects that exemplify this policy guida nce.

Non-Regulatory Actions The District currently has inc entive and technology advancement programs aimed at reduced energy use in the Valley . To date, the projects includ e the following:

 The administration of approxim ately $4 milli on in federal and state Energy Efficiency and Conservation Bl ock Grant funds made available to 37 small jurisdictions in the Valley. The majority of the funding was u sed to retrofit municipal facilities with light ing and other cost effective ene rgy efficiency retrofits, resulting in about 1.8 MkWh of e lectricity savings per year.

 The funding of an innovative pi lot program to assess the poten tial to operate more efficiently, thus saving money and using less energy.

 The funding of an outreach progr am showing governmental and se rvice organizations the benefits of “goi ng green.” This program star ted in Stockton through the Stockton Chamber of C ommerce, and with the District ’s help has expanded to the central and s outhern San Joaquin Valley.

 The allocation of $4 million for the District’s Technology Adv ancement Program. Two of the three focus areas fo r FY 2014–2015 ar e renewable ene rgy and waste solutions, which take into a ccount energy efficiency.

While there are no recommendations for new incentive programs a t this time, the District will continue supporting existing incentive and techno logy advancement
programs.

90 EPA. (2012) Incorporating Energy Efficiency/Renewable Ener gy 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 fr om http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agend a/2010/January/Agenda_Item_7_Jan_21_2010. pdf

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

C-212 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Evaluation Findings The District has evaluated all potential control technologies a nd all control technologies achieved in practice in other ar eas or included in other state implementation plans. The District cannot regulate energy use; therefore, it is recommend ed the District continue current incentives and technology advancement programs in order to close the emissions gap and accelerate the use of energy efficient techno logies. As the District continues to develop new attainm ent plans that address more str ingent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities for improving energy efficiency to reduce emissio ns in the Valley.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-213 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.33 SC 003 FIREWORKS

Source Category This category consists of firewo rks sold and/or used in the Val ley. This includes consumer fireworks for home disp lays, as well as professional p roducts for use by licensed operators in public displays.

Emissions Inventory The emissions inventory for th is category has not been quantifi ed.

How would District SC 003 compar e with federal and state rules and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, NESH AP, or MACT requirements f or 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 o f Regulations, Chapter 6 (Regulatio n)

How would District SC 003 compar e to rules in oth er air distric ts? There are no references to the us e of fireworks or pyrotechnics for entertainment purposes in BAAQMD, SMAQMD, or VCAPCD.

SCAQMD

 Rule 219 (Equipment not Requiri ng a Written Permit Pursuant to Regulation II)

Rule 219 exempts pyrotechnic eq uipment, special effects, or fir eworks paraphernalia equipment used for entertainment purposes from permit requireme nts.

 Rule 444 (Open Burning)

Fireworks and fireworks displays and pyrotechnics used for crea tion of special effects at theme parks are excluded from t he open burning requi rements of Rule 444.

 Rule 401 (Visible Emissions)

 Rule 402 (Nuisance)

Rules 401 and 402 do no t explicitly exempt fireworks displays.

Additional Emission Reduc tion Opportunities Fireworks usage in the Valley is limited to occasional displays at a small number of entertainment venues (minor league s porting events, for example ) and Independence Day (July 4 th ). On July 4 th , with widespread cons umer fireworks use, the Valley’s airSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-214 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard monitors typically show peak PM2 .5 concentrations for several h ours on the evening of July 4 th and into July 5 th . These hourly PM2.5 concentrations are much higher than normal PM2.5 concentrations dur ing the summer, although 24-hour average PM2.5 concentrations on July 4 th and 5 th do not always go above the level of EPA’s standard. In addition, exceedances of the air quality standard due to fir eworks qualify as an exceptional event under federal r egulations and, with proper do cumentation and EPA concurrence, do not count agains t an area’s attainment status. 92 However, the clear relationship between fireworks ac tivity and ambient PM2.5 level s; the location of emissions in populated areas; and the fact that the PM2.5 speci es associated with fireworks are health-impacting me tals and carbons all demonstra te the value of reducing emissions from fireworks as part of the District’s Hea lth-Risk Reduction Strategy. Fireworks emissions a re reduced by limiting the use of fireworks. For several years, the District has utilized pu blic education to inform res idents of the risks associated with firework emissions, and the dangers to sensitiv e populations. Enhancements to future outreach efforts may include partnering with other state and local agencies’ outreach efforts.

Despite the strong public affinity for July 4 th fireworks, many parts of the country are moving away from pyrotechnic fire works displays and towards las er light-based shows – particularly in regions with severe drought conditions and extr eme fire danger. According to the Inte rnational Laser Display Association, laser -light-based shows are gaining popularity steadily as more and more communities are mo ving in this direction. Several companies in Californ ia and throughout the country are engaged in the business of incorporating la ser-light based shows into 4 th of July celebrations.

Some fireworks are lower-emitti ng than others. Disneyland Them e Park started using a patented air launch pyrotechni cs system in 2004 to reduce noise and pollution. Use of such a system appears to be limit ed, and is likely most effecti ve in situations where fireworks displays are frequen t enough to justify the cost and permanent installation.

Non-Regulatory Action In 2012, the District launched an in centive program for municip al laser-light shows to replace fireworks displays. D ue to timing, the District was un able to fund shows that year, and has yet to reevaluate t he program for implementation in future years.

On August 16, 2012, the District’s Governing Board voted to ado pt a position in opposition of Californi a Senate Bill (SB) 146 8 (Calderon), whic h would have allowed for the sale of safe and sane firewo rks during the period of Decemb er 6 th to January 2 nd for two years, as a pilot for cons idering whether such an expanded use of fireworks should continue. This legislation woul d have thus expanded the use of fireworks to winter months when the Valley experie nces stagnant conditions that tra p particulates for extended periods of time. Given the potential for extreme adve rse 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 Da ta Influenced by Exceptional Events

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

C-215 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard financial reasons associated with the data collect ion and analy sis associated with the bill.

Evaluation Findings The District has evaluated all potential emission reduction opp ortunities for fireworks achieved in practice in other ar eas or included in other SIPs. As the District continues to develop new attainment plans that address mo re stringent Nat ional Ambient Air Quality Standards, the District will continue to evaluate poten tial opportunities to reduce emissions from fireworks in the Valley.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-216 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.34 SC 004 SAND AN D GRAVEL OPERATIONS

Source Category Particulate matter emissions fr om sand and gravel operations oc cur 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 4.0 tons per day (tpd) for PM2.5 dust, 13.1 t pd for NOx, and 1.0 tpd for SOx . As identified in the above table, emissions from sand and gravel operations are lowe r than the BACM/MSM significance thresholds. Theref ore, the Clean Air Act does not require a control measure evaluation for this sour ce category for the purpose of satisfying BACM/MSM requirements; however, the Distr ict has still conducted a full control measure evaluation for sand and gravel operations.

How would District SC 004 compar e with federal and state rules and regulations?

Federal Regulations There are no EPA CTG, ACT, NESHAP, a nd MACT requirements for th is source category.

NSPS

 40 CFR Part 60, Section 111 o f the Clean Air Act (40 FR 58416)

State Regulations There are no state re gulations applicable to this source catego ry.

How would District SC 004 compar e to rules in oth er air distric ts? There are no analogous rules fo r this source category in in BAA QMD, SMAQMD, or VCAPCD.

SCAQMD

 Rule 1157 (PM10 Emission Reduc tions from Aggregate and Related Operations)

 Rule 403 (Fugitive Dust)San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-217 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard The District evaluated the require ments contained within SCAQMD ’s Rules 1157 and 403 and found no requirements tha t were more stringent than tho se already in District Rules 8011, 2201, and 4101.

Additional Emission Reduc tion Opportunities Generally, sand and aggregate mate rials are wet or moist when h andled and emissions are often negligible. For proce sses where water is not an appr opriate method for minimizing emissions, baghouse and filter technology and achiev ed-in-practice controls are generally sufficient to limi t visible dust emissions to les s than 20 percent opacity, as required by District Rule 8011 (G eneral Requirements for Regula tion VIII) and District Rule 4101 (Visible Emissions).

While other districts have spec ific rules for aggregate and rel ated operations (SCAQMD Rule 1157), the ultimate limits for dust emissions is the same as opacity and visible emissions standards used for Dis trict operations. SCAQMD provi des guidance for specific activities (e.g. loading, conveying, crushing, screeni ng, and storage), but the emissions limits are the same a s the District’s limits. The Di strict reviews any new or modified stationary source under Rule 2201 (New and Modified St ationary Source Review), which in most cases will trigger BACT r equirements, th us requiring operators to apply the best controls to redu ce emissions during operation al activities including crushing, screening, and conveying.

Evaluation Findings Even though sand and gravel operati ons are not a significant so urce of PM2.5, NOx, or SOx in the Valley, the District has evaluated all potential con trol technologies and all control technologies achieved in p ractice in other areas or inc luded in other state implementation plans. As demons trated above, Rules 2201, 8011 and 4101 currently have in place the most stringen t measures feasible to implement in the Valley and therefore meet or ex ceed both BACM and MSM requirements for thi s source category. As the District continues to devel op new attainment plans that address more stringent National Ambient Air Quality Standards, the District will conti nue to evaluate potential opportunities to reduce emission s from sand and gravel operatio ns in the Valley.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-218 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.35 SC 005 ASPHALT/CONCRETE OPERATIONS

Source Category This source category includes e missions from asphalt and concre te production operations. Cement concrete production includes cement manufac turing and concrete production. There are only a few ce ment plants in California, but none within the Valley. However, many operations contri bute to potential emissions asso ciated with concrete production, which include the bl ending of cement powder, water, sand, and coarse aggregate. Similarly, there are operations producing asphalt c oncrete, which is primarily used for paving parki ng lots and on-road surfaces and is commonly made by hot-mixing asphalt with size-gr aded aggregate in dr ums or batch es. If a cement production plant were to be buil t within the Valley, it would b e reviewed and evaluated under District Rule 2201 (New and Modified Stationary Source Re view) and would trigger BACT requirem ents for equipment and processes associate d 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 min eral processes for asphalt/concrete production. As phalt mixing and application pr ocesses only generate VOC emissions, which occur via o ff-gassing. There would be NOx emissions from the combustion equipment used for asphalt mixing and application; h owever, those emissions are accounted for in District Rule 4309 (Dryers, Dehy drators, and Ovens) and off-road equipment.

As detailed in Chapter 5, the si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 1.4 tons per day (tpd) for PM2.5 combustion, 13.1 tpd for NOx, and 1.0 tpd f or SOx. As identified in the above table, emissions from a sphalt/concrete operations are lower than the BACM/MSM significance threshol ds. Therefore, the Clean Air Act does not require aSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-219 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard control measure evaluation for this source category for the pur pose of satisfying BACM/MSM requirements; however , the District has still conducte d a full control measure evaluation for asphalt/concrete operations.

How would SC 005 compare with f ederal and state rules and regul ations?

Federal Regulations There are no EPA CTG, ACT, or MACT requirements for this source category.

NSPS

 40 CFR 60 Subpart OOO (Standards o f Performance for Nonmetalli c Mineral Processing Plants)

 40 CFR 60 Subpart I (Standards of P erformance for Hot Mix Asph alt Facilities)

 40 CFR 60 Subpart UU (Standards of Performance for Asphalt Pro cessing and Asphalt Roofing Manufacturing)

The District evaluated the requi rements contained within the ab ove NSPSs and found no requirements that were more stringent than those already in Rules 4101 (Visible Emissions), 2201 (New and Modifi ed Stationary Source Review), a nd 4309 (Dryers, Dehydrators, and Ovens).

NESHAP

 40 CFR 63 Subpart LLLLL (Asphal t Processing and Asphalt Roofin g Manufacturing for Major Sources)

 40 CFR 63 Subpart AAAAAAA (As phalt Processing and Asphalt Roof ing Manufacturing for Area Sources)

The District evaluated the requi rements contained within the ab ove NESHAPs and found no requirements that were more stringent than those alrea dy in Rule 4101 (Visible Emissions), Rule 2201 (N ew and Modified Stationary Sou rce Review), and Rule 4309 (Dryers, Dehydrators, and Ovens).

State Regulations There are no state re gulations applicable to this source catego ry.

How would SC 005 compare to rules in other air districts? There are no analogous rules fo r this source category in BAAQMD , SMAQMD, and VCAPCD.

SCAQMD

 Rule 1157 (PM10 Emission Reduc tions from Aggregate and Related Operations)

The District evaluated the require ments contained within SCAQMD Rule 1157 and found no requirements that were more stringent than those alrea dy in District Rule 4101 (Visible Emissions), Rule 2201 (N ew and Modified Stationary Sou rce Review), and Rule 4309 (Dryers, Dehydrators, and Ovens).San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-220 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard  Rule 403 (Fugitive Dust)

The District evaluated the require ments contained within SCAQMD Rule 403 and found no requirements that were more stringent than those already in District Rules 4101 (Visible Emissions), 2201 (New a nd Modified Stationary Source R eview), and 4309 (Dryers, Dehydrators, and Ovens).

Additional Emission Reduc tion Opportunities Liquid asphalt is unworkable a t ambient temperatures, so most a sphalt mixtures are manufactured, spread, and compac ted at temperatures higher than 300°F (>150°C) to temporarily reduce the viscosity , thereby making the mixture wo rkable. Working at these high temperatures produc es greenhouse gases and other cri teria and hazardous air pollutant emissions, in addi tion to creating an undesirable working environment. These emissions are minimized by a chieved-in-practice controls meeting the opacity requirements of District Rule 4101 (Visible Emissions) and Rule 2201 (New and Modified Stationary Source Rev iew). Additionally, new technolo gies allowing for warmmix asphalt techniques provide be tter emissions control at lowe r temperatures.

Achieved-in-Practice Controls for Concrete and Asphalt Processes For concrete production operations, achieved-in-practice contro ls include baghouses for screens, crushers, and concrete weight batchers; bin vent filte rs for concrete and fly ash silos; and water spray for other emissions points. For asphalt operations, achieved-inpractice controls include oil mi st collectors and “blue smoke” control with electrostatic precipitators or filter packs . Dryers used for drying aggregat e in the asphalt production process are regulated under District Rule 4309 (Dryers, Dehydra tors, and Ovens), which limits NOx and CO to 4.3 and 42 ppmv, respectively, for g aseous-fuel fired units.

Warm-mix Asphalt (WMA) Asphaltic concrete, or pavement, is used worldwide for road con struction. An asphaltic concrete mix consists of aggregate and liquid asphalt. Liquid asphalt, also termed asphalt cement, is a natural hydro carbon substance primarily de rived from the heaviest part of petroleum crude oil. The aggregate, which is basically rocks of different size, angularity, and hardne ss, is bound with the liquid asphalt to m ake the strongest and most durable pavement combinati on for expected road conditions.

The performance of liquid asphalt depends on the chemistry of t he crude oil source and how it was refined. The physical properties of the liquid asph alt can also be adjusted with various additives, such as polymers or hydrated lime. The performance of the aggregate depends on the physical c hemistry of the rock as well as its shape and size. The performance of the final as phalt mixture depends on the qua lity and proportions of the components and the quality of the construction. Asphalt pa vements are typically 95% by weight aggregate and 5% asphalt binder. 93

93 MyAsphaltPavingProject.Com. (2011). “What are the Specificatio ns?” Retrieved from http://www.myasphaltpavingproject.com/whatisasphalt/what-are-th e-specifications/

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

C-221 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard The high viscosity 94 inherent to liquid asphalt make s it suitable for paving projec ts, but requires added heat dur ing mixing and applic ation. Liquid asph alt is unworkable at ambient temperatures, so most as phalt mixtures are manufactured , spread, and compacted at temperatures higher than 300°F (>150°C) to tempora rily reduce the viscosity, thereby making the mixture workable. Working at the se high temperatures produces greenhouse gases and other criteria and hazardous air pollutant emissions, in addition to creating an undesir able working environment. 95

Heating and mixing takes place at a batch or drum plant where d ry, and sometimes heated, aggregate is mixed with heated liquid asphalt. Once mi xed, 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 compac ted with rollers to reduce air v oids.

European and American com panies have develope d several techniqu es, collectively known as warm-mix asphalt (WMA), to increase the workability of asphalt by lowering the viscosity at temperatures a s much as 100°F below that of ho t-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, speci fically foaming and water injection, and the use o f 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. I n all cases however, WMA technologies may require mor e finesse in controlling moistu re in the aggregate and in the overall syst em operation, such as tuning of the burn er to run efficiently at lower temperatures. Improper burner adjustment can cause the b urner to not add enough air to burn all the fuel and may cause mix contamination

.

Mechanical methods for WMA hav e been shown to reduce the produc tion temperature by 25-90°F. These methods include, but are not limited to, add ing water-containing products, water-based foaming processes, and using hot coarse a ggregate mixed with wet sand. Chemical additives for WMA have been shown to reduce the production temperature by 59-86°F. The addi tives include, but are not lim ited 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 we ight. 96

WMA has shown potential for redu cing emissions associated with the production of asphalt for paving projects when compared to HMA. Lower temper atures required for production, storage, transport, and application translates to l ower fuel consumption, which in turn reduces the criter ia air pollutant emissions asso ciated with combustion. In a 2013 California Department of Transportation (Caltrans) repor t 97 , WMA was

94 Viscosity is a material’s resistance to gradual deformation wh en stress is applied.
95 Rubio et al. (2013). “Comparative Analysis of Emissions from t he Manufacture and Use o f 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/docume nts/Caltrans_ClimateChangeRprtFinal_April_2013.pdfSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-222 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard recognized as potentially yield ing 25–35% fuel savings and thus contributing to a significant level of emissions r eductions from manufacturing, m ixing, and laying the asphalt.

Asphaltic concrete production plan ts are regulated by District Rule 2201 (New and Modified Stationary So urce Review Rule), R ule 4301 (Fuel Burnin g Equipment), Rule 4309 (Dryers, Dehydrators, and Ov ens), and Rule 4641 (Cutback, Slow Cure, and Emulsified Asphalt, Paving and Ma intenance Operations), which h ave all been approved by EPA to meet or exceed RACT requirements.

Benefits of WMA The use of WMA was initially p romoted as a means of reducing em issions from road projects, especially in nonattainment areas 98 . However, after extensive research and numerous case studies, the potenti al benefits of WMA have expan ded beyond reduced emissions. Benefits include, but a re not limited to the follow ing:

 Improved performance : WMA improves workability and ease of compaction, which is critical to long-ter m performance of the mixture. 99

 Energy Savings : By lowering the production, sto rage, transport, and applicati on temperatures, manufacturers requi re less energy to heat aggrega te and liquid asphalt. Energy savings could po tentially offset the added cos t of additives or needed modifications to plants, es pecially where energy costs a re high. Reduced plant temperatures may a lso cause less wear on plant eq uipment, 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 t he mixture with no effect on ultimate pavement performance. The use of RAP is less expensive than producing an asphalt mixture from raw materials, and addit ional 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 WM A projects. One cost assessme nt indicated $3,000-$6,000 in savings per lane mile. 101 Life cycle assessments have shown reduced agency costs, user cost s, 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 Citie s Public Works Officers Instit ute. Sacramento, Califor nia.” Retrieved from http://www.cacities.o rg/UploadedFiles/Lea gueInternet/f2/f257a42 c-2d27-47d1-a641-068a32289b71.pdf

. 99 MyAsphaltPavingProject.Com. (2011). “What are the Specificatio ns?” Retrieved from http://www.myasphaltpavingproject.com/whatisasphalt/what-are-th e-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/docume nts/Caltrans_ClimateChangeRprtFinal_April_2013.pdf
101 Leng & Al-Qadi. Illinoi s Center for Transportation, University of Illinois at Urbana-Cham paign, Champaign, Illinois. (2011). “Comparative Life Cycle Assessment between Warm SMA and Conventional SMA.”San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-223 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard  Extended paving season : A smaller difference between the asphalt temperature and ambient temperat ure reduces the rate of cooling , which means paving can take place during colder weather.

 Longer transport time : Lower temperatures requir ed for storage allow the asphalt to be transported to more remote locations and introduc es more flexibility in transportation schedules.

 Shorter cooling time : The lower temperature allo ws cooling to take place in a shorter time, increasing the pr oject completion rate and openin g roads to traffic more quickly.

 Safer working conditions : VOC and other hazardous emissions are significantly reduced with WMA, a s is a potential burn hazard.

Potential Emissions Reductions from WMA As previously mentioned, WMA pr oduction has the potential to re duce combustion emissions by reducing the amoun t of energy (fuel) needed to hea t 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 saving s 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 su mmarizes the range of NOx emissi on reductions expected from the use of WMA; h owever, actual emissions reducti ons for U.S. production of WMA will vary dependi ng on the fuel used for comb ustion, control technology, and local regulations.

Table C-36 NOx Emis sion Reductions for Warm-mix Asphalt Vaitkus et

al. 103,104 Larsen, O.R. 105 D’Angelo et al.
106 Evotherm 107

NO x Reduction 60–70% 62% 60–70% 58%

The emissions inventory for asphaltic concrete production in th e Valley includes emissions from asphalt plants, dry ers, storage piles, and vehic le traffic. As evidenced by the emissions inventory tabl e for this source category, the NOx emissions from this source category are extremely sm all. In addition, only 88% of these NOx emissions are

102 California Asphalt P avement Association. ( 2013, March 28). “W arm-mix Asphalt. Presentat ion to the League of California Cit ies Public Works Officers Institute. Sacramento, California.” Retrieved from http://www.cacities.o rg/UploadedFiles/Lea gueInternet/f2/f257a42 c-2d27-47d1-a641-068a32289b71.pdf.
103 Vaitkus, A., Cygas, A., Laurinavicius, A. Perveneckas, Z. (200 9a). Analysis and Evaluation of possibilities for the use of Warm Mix Asphalt in Lit huania. The Baltic Journal of Ro ad and Bridge Engineering, 4(2), 80–86.
104 Vaitkus, A., Vorobjovas, V. Ziliut, L. (2009b). The Research o n the Use of Warm Mi x Asphalt for Asphalt Pavement Structures. Road Depart ment, Vilnius Gediminas Techni cal University, Vilnius, Lithuania.
105 Larson, O.R. (2001). Warm Asphal t Mix with Foam—WAMTMFOAM. In ternational Road Federation, 2001 Partie B: Themes Techniques, S.00469. Kolo Veidekke, Norway.
106 Vaitkus et al., 2009a,b.
107 Evotherm® (2010, March). Stack Em issions & Jobsite Fumes Redu ctions using Evothe rm® Warm Mix Asphalt. Available at: http://www.meadwestvaco.com/mwv/groups/content/documents/docume nt/mwv017395.pdfSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-224 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard from production processes, as about 12% of these emissions acco unt for associated vehicle traffic. 108

Feasibility of WMA As more tests and case studies a re run in the U.S., WMA is prov ing to perform as effective as or better than HMA . Caltrans and the University o f California Pavement Research Center have been evaluat ing WMA technology and its per formance by testing rutting and cracking performance, m oisture sensitivity, durabil ity, aging, emissions, and stability of multiple types of WMA production. 109 WMA has so far been shown to have equal or better overall performanc e 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 o f WMA has grown from laying a bout 67,000 tons of WMA between 2006 and 2009, to jus t over 2 million tons by 2012. 111 To further encourage the use of WMA, in Ju ne 2012 Caltrans issued a direct ive that provided guidance for implementing a cont ractor-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 plac ed 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 a irport runways for Boston Logan and Chicago O’Hare airports.

WMA is on the uptake and will become more wi dely used over time . The U.S. Department of Transportation Federal Highway Administration (FH WA) 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 e fforts, the use of WMA is continuing to grow in the Valley with the current backing from state and national transportation agencies.

Despite the technological feasib ility of using WMA as a substit ute for HMA, the cost of converting equipment to produce WM A remains a potential barrier to adoption. Certain facilities would incur more cos ts than others to employ this te chnology. More research into the capital costs of conv erting production equipment is ne eded to determine

108 EPA, 2000,Table 1; excludes mobile source emissions; average f or 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 Citie s Public Works Officers Instit ute. Sacramento, Califor nia.” Retrieved from http://www.cacities.o rg/UploadedFiles/Lea gueInternet/f2/f257a42 c-2d27-47d1-a641-068a32289b71.pdf.
110 Rubio, M.C., Martínez, G., Baen a, 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, Jun e 7). Contractor Option for Use of Warm Mix Asphalt Technologies in Hot M ix 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 Mi x Asphalt. Presentation to the League of California Citie s Public Works Officers Instit ute. Sacramento, California. Available at: http://www.cacities.o rg/UploadedFiles/Lea gueInternet/f2/f257a42 c-2d27-47d1-a641-068a32289b71.pdfSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-225 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard whether WMA is cost effective for asphalt production facilities in the Valley. In addition, some applications may not be su itable for WMA. Just as with HM A use and application, WMA use is not a one-size-fits- all product. Cont inued studies and field tests are showing which product, mix, and application are best for specif ic uses and conditions.

While the benefits of WMA are far-r eaching, more research into the capital costs associated with converting produc tion equipment to handle WMA a nd other feasibility issues is still needed to fully determine whether WMA would be feasible and cost effective to require for all Va lley asphalt production faciliti es. Therefore, as discussed in Chapter 8 (Commitment to Leave No Stone Unturned to Evaluate Ad ditional Opportunities), the District is co mmitting 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 cu tback (medium cure) asphalt where the National Weather Service official forecast of the high temperature for the 24-hour period foll owing application is below 50°F. The us e 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 emissi on reduction opp ortunity for this 2015 PM2.5 Plan . Although the use of cutback as phalt has declined in recent y ears, Rule 4641 maintains the exempti on based on the following:

 The exemption for cutback aspha lt during colder ambient temper atures, which occurs during winter (non-oz one) season, is analogous to EPA’s Blue Book on Cutback and Emulsified Asphalt r ecommended seasonal exemptions (i.e. outside of the ozone season).

 During colder ambient temperat ures, VOCs do not evaporate rapi dly, especially from medium cure asphalt that i s limited by Rule 4641 to no mor e than 5% organic compounds that evaporate at 500°F.

 Road construction and road repairs using asphalt are very mini mal during the colder winter months, except fo r emergency road repairs. In ad dition, during winter months, the Valley exper iences the majority of rainfall, including long periods of fog. In these conditi ons, asphalt will not properly cure or harden due to the increased moisture on t he surfaces or areas where asphal t is applied and therefore, this type of a ctivity is minimal.

Evaluation Findings Although asphalt/concrete operati ons are not a significant sour ce of PM2.5, NOx, or SOx in the Valley, the District e valuated the feasibility of al l potential emissions reductions measures for this s ource category. As demonstrated in the above control measure evaluation, existing District regulations for this sour ce category (Rules 4309 and 4641) currently implement BAC M and MSM for these sources.

In addition, as discussed above, W MA is potentially a viable al ternative to HMA and the benefits obtained by swit ching from HMA to WMA have contributed to the fast growing use of WMA throughout Californi a and the Valley. FHWA’s goal o f achieving 50% ofSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-226 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard WMA paving by 2015 has further acce lerated the widespread adopt ion of this technology throughout the country and will likely further incre ase the use of WMA in the Valley in future years.

Although current District rules already meet BACM and MSM requi rements for this source category, as previously mentioned, the District is commi tting to further evaluate warm mix asphalt for additional o pportunities. See Chapter 8 f or more information.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-227 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.36 SC 006 ALMOND HULLING/SHELLING OPERATIONS

Source Category This control measure source c ategory would apply to almond hull ing and shelling operations. Almonds are harvest ed from orchards and transporte d 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. Processe s for removing the debris and almond hulls and shells are potential sources of air emi ssions. The Valley harvests 86 % of the almonds produced in California. Produc tion 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 4.0 tons per day (tpd) for PM2.5 dust, 13.1 t pd 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 threshol ds. Therefore, the Clean Air Act does not require a control measure evaluation for this source category for the pur pose of satisfying BACM/MSM requirements; however , the District has still conducte d a full control measure evaluation for alm ond hulling/shelli ng operations.

How would District SC 006 compar e with federal and state rules and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, N ESHAP, and MACT for this sour ce category.

State Regulations There are no state re gulations applicable to this source catego ry.

115 The Tioga Group. (2012). SJV Nut Industry Profile Preliminary Draft. Retrieved from http://www.sjvcogs.org/pdfs/2012/Nut%20Industry%20030612.pdf

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

C-228 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard 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 Reduc tion Opportunities Evaluation of emission reducti on opportunities for almond hulli ng and shelling operations included a review of ongoing research efforts, and t he technologicial feasibility and cost effectivene ss of polytetrafloroethylene (P TFE) bags.

Ongoing Research Efforts Research is currently being condu cted by Texas A&M University i n partnership with almond harvesting equipment manuf acturers, almond farmers, Unit ed States Department of Agriculture-Natura l Resources Conservation Servic e (USDA-NRCS), and the District to compare “low dust” almond harvesters and an exh aust abatement devices to conventional harvesters in th e harvesting of almonds at a Va lley farm. No differences were detected in the particle size distribution (PSD) character istics of PM emitted from each harvester, with t he exception of the exhaust abatement dev ice, where large particles were efficiently capt ured by the cyclone. Emissions of total suspended particulates (TSP) and PM10 trended lower for all new harvester s and were significantly lower for most harvesters. Ther e were significant reductions o f PM2.5 ranging from 61- 69% observed from the harvest ers and a 95% reduction in PM2.5 f rom the Clean Air Concept cyclone. The results of t hese tests imply that new har vest technologies are able to reduce PM emissions with out affecting product quality.

Polytetrafloroethylene Bags District BACT guidelines for al mond hullers and shellers requir e the use of a baghouse, which controls PM by moving the contaminated flow of air throug h bag type filters. The technology has been achieved in practice in the District. Stan dard polyester bags are the most commonly used type of bag for baghouses in the almond hulling/shelling industry. A layer of dust (dus t cake) collects on the upstrea m side of these bags and filtering efficiency increases a s the layer grows; however, the y are not designed to provide high PM2.5 control. On the other hand, membrane type b ags treated with polytetrafloroethlyene (PTFE) cont ain extremely small pores and filtering occurs on the bag surface instead of in a dust c ake. These types of filters are capable of controlling 99.9% 116 of PM2.5 emissions, whereas baghouses with polyester bags cont rol PM2.5 emissions by 95-99%. 117

The costs of using baghouses wit h PTFE bags rather than standar d polyester bags were calculated. The pressure d rop across polyester and PTFE b ags is about the same so there should not be a significa nt increase in electrical cos ts by using one bag over another. Additionally, existing baghouses would not require mo difications to accommodate PTFE bags so the incr eased 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/baghous e-filter/ptfe-filters/

. 117 Roberts, C. (2009). Information on Air Pollution Control Technology for Woody Biomass Boilers. Northeast States for Coordinated Air Use Man agement and the EPA Office of Air Qu ality Planning and Standards.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-229 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard PTFE bag typically costs $23, w hereas a polyester bag costs $12 . The lifetime of both bags is approximately 2 years. T he following cost differential was calculated, with knowledge that some facilities i n the Valley have up to 2-3 bag houses, each with 500 bags. District permits also requi re facilities to have replace ment bags accounting for 10% of the total number of bags; t herefore 550 bags will be use d 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 Redu ctions 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 P TFE bags – 99% control efficien cy 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 PTF E bags)

= 0.0036 tons/day reduced

(0.0036 tons/day reduced from usi ng 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 replac ing polyester bags was also cal culated at the lower end of the emission control efficien cy scale (95%) with the PTFE ba gs to determine what a more conservative cost effecti veness analysis would reveal; the cost effectiveness from 95% polyester bags to 99.9% PTFE bags is $42,706.88 /ton PM2.5 r educed.

Although the initial annual capital cost may seem relatively lo w; in terms of cost effectiveness, PTFE bags are not a cost effective alternative t o standard bags. The additional control efficiency gai ns are in the fractions of ton s of incremental emissions reductions. Additionally, as m entioned above, the emission inv entory used in these calculations (0.40 tons/day PM2 .5) includes the emissions of bo th almond hulling andSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-230 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard pistachio hulling, meaning the ac tual inventory is smaller, and making the actual cost effectiveness even higher than calculated.

The cyclone is another te chnology in common use at Valley facil ities for PM control in almond hulling/shelling; however , like baghouses with polyester bags, the technology primarily provides PM10 contro l. Additionally, cyclones typica lly achieve 80-85% control efficiency. Approximately 37 fa cilities in the Valley use cycl ones to control PM emissions. Therefore, if these fa cilities were required to rep lace cyclones with baghouses, the cost effectivene ss would be as follows:

Potential PM2.5 Emission Reduct ions for Replacing Cyclones with Baghouses with PTFE Bags

The PM2.5 control efficiency fo r cyclones is assumed to be equi valent 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 reduc ed) x (365 days/year)

= 21.754 tons/year reduced

Potential Cost Effectiveness fo r Replacing Cyclones with Baghou ses with PTFE Bags

37 facilities to install baghouses at a minimum of $150,000 eac h

With a 10 year amortization factor and 10% interest, the annual ized 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 w ould cost $41,508.92/ton, which does not inc lude additional costs of inst allation, electrical system upgrades, ductwork, demolition or disposal of the cyclone. The refore, replacing cyclones with baghouses is not a cos t effective control option. As previously stated, the emissions inventory used in these calculations (0.40 tons/day P M2.5) includes the emissions of both almond hulli ng and pistachio hulling, meaning the actual inventory is smaller, and making the actual cost effectiveness even higher t han stated.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-231 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Evaluation Findings Even though almond hull ing/shelling operations are not a signif icant source of PM2.5, NOx, or SOx in the Valley, the District has evaluated all poten tial control technologies and all control technologies achie ved in practice in other area s or included in other state implementation plans. As demons trated above, current control t echniques 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 c ategory. As the District continues to develop new attainment plans that address more stringent National Ambient Air Quality Standards, t he District will continue to ev aluate potential opportunities to reduce emission s from almond hulling/shelling operations in the Valley.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-232 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.37 SC 007 PISTACHIO HU LLING/SHELLING OPERATIONS

Source Category This control measure source cat egory would apply to pistachio h ulling and shelling operations within the Valley. P istachio hulling operations are permitted under the same permit with the pistachio rece iving and pre-cleaning portions o f the operation. These operations use 1D-3D cyclones to control PM emissions from the pre-cleaning portion of the process, which is the Bes t Available Control Technology (BA CT) standard. Typically pistachio processing equipment, located after the pre -cleaning section and prior to the pistachio dryers, i s of a wet-process design; PM e missions from this portion of the operation are assumed to be negligible. California prod uces 98.5% of U.S. pistachios and production has ex panded greatly in the last deca de. Pistachio acreage doubled between 1997 and 2010, and production looks like it wil l continue to increase in the near future. 118 In the interest of identifying ev ery possible strategy to red uce PM2.5 emissions, pistachio hulling and shelling operations were evalu ated for potential opportunities to reduce emission s; see the discussion below.

Emissions Inventory The emissions inventory for this category is included as a part of the emissions inventory for the control meas ure source category for almond hu lling. Refer to the emission inventory table present ed in SC 006 for this combined inventory.

How would District SC 007 compar e with federal and state rules and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, NESH AP, or MACT requirements f or this source category.

State Regulations There are no state re gulations applicable to this source catego ry.

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 Reduc tion Opportunities Pistachio shelling operations a re served by a baghouse, which i s the industry standard for shelling operations. While t here is no specific BACT guide line for shelling operations, baghouses are typically attributed to a PM2.5 contr ol efficiency of 95-99%. As discussed above in SC 006 (Alm ond Hulling/Shelli ng Operation s), polytetrafloroethylene (PTFE) bags have the potential to provid e additional PM2.5 control when used in baghouses but are not cost effective due t o 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

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

C-233 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard control efficiency of existing practices. Refer to SC 006 (Alm ond Hulling/Shelling Operations) for the cos t effectiveness analysis.

Unlike almonds which are shak en on the ground and vacuumed off the soil during harvesting, pistachios are caugh t with a canvas catcher before they hit the ground, which allows for a very small amount of dust and debris in addi tion to the pistachios. Much of the PM emissions associat ed with the processing of pist achios occur during the pre-cleaning stage, which is controlled by cyclones. The hull ing stage is a wet process as the nuts are floated on water; PM emissions from this portio n of the operation are assumed to be negligible. At this time

, the District’s analysis indicates that there are no feasible opportunities for addi tional emission reduction regula tory strategies for this source category.

Evaluation Findings Even though pistachio shelling op erations are not a significant source of PM2.5, NOx, or SOx in the Valley, the District has evaluated all potential con trol technologies and all control technologies achieved in p ractice in other areas or inc luded in other state implementation plans. While there is no specific rule or guidel ine for pistachio shelling, the industry-standard baghouse operation descr ibed above meets or exceeds both BACM and MSM requirements. As t he District continues to develop new attainment plans that address more stringen t National Ambient Air Quality Standards, the District will continue to evaluate potent ial opportunities to reduce emi ssions from pistachio shelling operations in the Valley.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-234 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.38 SC 008 AGRICULTURAL MATERIAL SCREENING/SHAKING OPERATIONS

Source Category This control measure source c ategory would be applicable to the handling and processing of agricultural mate rials in biomass, composting, an d other agricultural material handling facilities.

Emissions Inventory The emissions inventory for th is category is accounted for in o ther control measure source categories. Refer to App endix B for the emissions inven tory.

How would District SC 008 compar e with federal and state rules and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, N ESHAP, and MACT requirements for this source category.

State Regulations There are no state re gulations applicable to this source catego ry.

How would District SC 008 compar e to rules in oth er air distric ts? There are no analogous rules fo r this source category in BAAQMD , SMAQMD, or VCAPCD.

SCAQMD

 Rule 1131.1 (Chipping and Grinding Activities)

The District evaluated the require ments contained within SCAQMD 1131.1 and found no requirements that were more stringent than those already in New Source Review Rule 2201.

Additional Emission Reduc tion Opportunities District analysis of potential emission reduction opportunities includes an evaluation of the efficacy of wet suppressi on systems and enclosing conveyors and transfer points.

Wet Suppression System A wet suppression system can achiev e between 40-65% control of PM2.5. 119 In a wet suppression system, water is gener ally applied to all emissions units, transfer points, and raw material stockpiles to e nsure that adequate moisture is provided to the operation to successfully reduce PM emissions. No emissions wo uld be reduced by requiring a wet suppression system because this control is curr ently in use at all identified facilities in the Va lley and would be required at an y new facility triggering BACT under the New Source Review Rule 2201.

119 Environmental Protect ion Agency [EPA]. (1995). Compilation of Air Pollutant Em ission Factors, Table B.2-3.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-235 Appendix C: BACM and MSM for Stationary and Area Sources 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 t he drop or transfer points on the conveyors. However, in addition to the control effici ency of enclosed conveyors bei ng unknown, conveyors are already operated so that they move very slowly to avoid ent raining dust and limit visible emissions. Therefore, t he potential to reduce emission s is minimal and reduced emissions would not be quantifiable.

Evaluation Findings The District has evaluated all potential control technologies a nd all control technologies achieved in practice in other ar eas or included in other state implementation plans. As demonstrated above, current busi ness practices have in place th e most stringent measures feasible to implement i n 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 addre ss more stringen t National Ambie nt Air Quality Standards, the District will cont inue to evaluate potential opp ortunities to reduce emissions from agricultural mate rial screening/shaking operatio ns in the Valley.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-236 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.39 SC 009 TUB GRINDING

Source Category This control measure source cat egory would apply to operations using a tub grinder for agricultural material processi ng. Tub grinders are used to gri nd organic materials such as wood and agricultural material s for biomass fuel processing facilities, composting facilities, landscape material manufacturing (e.g. wood bark, m ulch, etc.), or agricultural waste grinding (e.g. orchard remo val, land clearing, etc.). Th ese units are typically powered by diesel-fired inter nal combustion engines (ranging fr om 100 horse power (hp) to 1,600 hp) and mounted on wheels to be transportable, wh ich allows the units to be towed to the jobsite where the piles of material are to be g round. In addition, these units may also be self-propelled and track-mounted; in this cas e the diesel engine powering the equipment is also us ed for motive power and is exe mpt from District permits since it is considered to be mobile equipment. The die sel engines powering the transportable units are subject to District Rule 4702 (Internal Combustion Engines) and Best Available Control Technolog y (BACT) Guideline 3.2.11. Thi s control measure source category discussion addresse s the particulate matter (PM ) emissions from the loading, grinding, and conveyin g of the process materials.

Emissions Inventory Emissions generated by the engines of the tub grinders are acco unted for as a part of the inventory for District Rule 4702 (Internal Combustion Engin es). The fugitive particulate emissions from these units are accounted for as a p art of the stationary and area source emissions inv entory. See Appendix B.

How would District SC 009 compar e with federal and state rules and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, N ESHAP, and MACT requirements for this source category.

State Regulations There are no state re gulations applicable to this source catego ry.

How would SC 009 compare to rules in other air districts? There are no analogous rules fo r this source category in BAAQMD , SMAQMD, or VCAPCD.

SCAQMD

 Rule 1131.1 (Chipping and Grinding Activities)

The District evaluated the require ments contained within SCAQMD Rule 1131.1 and found no requirements that were more stringent than those alrea dy in District Rules 2201 (New Source Review) and 4101 (Visible Emissions) and BACT guideline 6.4.2.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-237 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Additional Emission Reduc tion Opportunities Currently, fugitive particulate emissions from transportable an d self-propelled tub grinders are controlle d with a water sprink ler system during lo ading, grinding, and unloading of the process material s to prevent visible emissions in excess of 5% opacity per Rule 2201 (New Source Review) and BACT guide line 6.4.2. W ater sprinkler systems achieve between 40- 65% control of PM2.5. 120 It is standard practice to use water spray on this type of equi pment to meet the visible emiss ion requirements of Rule 4101 (Visible Emissions); therefor e, requiring water control fo r tub grinding operations would not result in additional emission reductions from this so urce category. A potential control option considered woul d be to require a baghouse to be installed onto the trailer of the equipment to capture fugi tive 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 tec hnologically feasible for a tra nsportable unit. No technologically feasible or al ternative basic equipment were identified in the District’s BACT guidelines.

Evaluation Findings The District has evaluated all potential control technologies a nd all control technologies achieved in practice in other ar eas or included in other state implementation plans. As demonstrated above, Rules 2201 , 4101, and District BACT guideli ne 6.4.2 currently have in place the most stringen t measures feasible to implement in the Valley and therefore meet or ex ceed both BACM and MSM requirements for thi s source category. As the District continues to develop new attainment plans that address more stringent National Ambient Air Quality Standards, the District will conti nue to evaluate potential opportunities to reduce emissions from tub grinding in the Vall ey.

120 Environmental Protect ion Agency [EPA]. (1995). Compilation of Air Pollutant Em ission Factors, Table B.2-3.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-238 Appendix C: BACM and MSM for Stationary and Area Sources 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 surfa ce by forcibly propelling a stream of abrasive material agai nst such surface. Abrasive bla sting can occur in a confined or an unconfined area, depending on the type of surfac e or application. Abrasive materials commonly us ed are walnut shells, various min eral or metal products, garnet, sand or aggregate, slag, st eel 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 si gnificance thresholds for sourc e categories for the purpose of evaluating the applic ation of BACM and MSM requireme nts are 4.0 tons per day (tpd) for PM2.5 dust, 13.1 t pd for NOx, and 1.0 tpd for SOx . As identified in the above table, emissions from abras ive blasting are lower than th e BACM/MSM significance thresholds. Theref ore, the Clean Air Act does not require a control measure evaluation for this sour ce category for the purpose of satisfying BACM/MSM requirements; however, the Distr ict has still conducted a full control measure evaluation for abrasive blasting.

How would District SC 010 compar e with federal and state rules and regulations?

Federal Regulations There are no EPA CTG, ACT, NSPS, NESH AP, or MACT requirements f or this source category.

NESHAP/ MACT

 40 CFR 63, Subpart XXXX XX (National Emission Standards for Haz ardous Air Pollutants Area Source Standards for Nine Metal Fabrication and Finishing Source Categories)

The District evaluated the require ments contained within 40 CFR 63, Subpart XXXXXX and found no requirement s that were more stringent than those a lready in District Rule 4102 (Nuisance) and 17 CCR 6 92200 (Opacity) through 92500 (Per formance Standards).San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-239 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard 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 compar e to rules in oth er air distric ts? No rule from another air distr ict has requirements beyond what is already required in state standards. BAAQMD Regulati on 12, Rule 4 (Sandblasting), SCAQMD Rule 1140 (Abrasive Blasting), and VCAPCD R ule 74.1 (Abrasive Blasting) r egulate abrasive blasting operations and activit ies, but all simply conform to t he state standards.

Additional Emission Reduc tion Opportunities Achieved-in-practice BACT cont rols for sandblasting include bag houses, filters, or cartridge dust collectors. With such technologies, 99% control efficiency can be achieved. As emissions source s, sandblasting operations within the District are subject to District Rule 4102 (Nuisanc e) and the standards of 17 Califo rnia Code of Regulations (CCR) Section 92200 (opacity) and 17 CCR Section 92500 (perform ance standards such as CARB-certified abrasives).

Opportunities for further emissi ons reductions are limited beca use 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 o pportunities for additional emissions reductions for this source category.

Evaluation Findings Even though abrasive bl asting operations are not a significant source of PM2.5, NOx, or SOx in the Valley, the District has evaluated all potential con trol technologies and all control technologies achieved in p ractice in other areas or inc luded in other state implementation plans. As demons trated above, the California Co de of Regulations and District Rule 4102 currently provi de the most stringent measure s feasible to implement in the Valley and therefore m eets 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 A mbient Air Quality Standards, the District will continue to evaluate potential opportuniti es to reduce emissions from ab rasive blasting operations in the Valley.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-240 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C.41 AMMONIA CONTROLS

Under Subpart 4 of the CAA, regi ons are required to address amm onia as a precursor in BACM/MSM analyses and other a reas of the plan unless EPA det ermines that ammonia sources do not contribut e significantly to PM concentra tions. To improve public health while also ensuring effective use of resources, a dditional ammonia controls should only be required when there is clear scientific evidence that reasonable measures to reduce ammonia emi ssions would be effective in sign ificantly reducing ambient PM2.5 concentrations.

Extensive scientific research and technical analyses (see Appen dix A) demonstrate that ammonia reductions do not contri bute to the Valley’s PM2.5 atta inment; as such, ammonia does not need to be addre ssed in this BACM/MSM analysis for the 1997 PM2.5 standard. Even though ammoni a is an insignificant PM2.5 precursor in the Valley, the following analysis sh ows that the Valley’s ammonia emissions have been significantly reduced through st ringent regulations, that addit ional ammonia control measures are infeasible, and tha t Valley sources currently impl ement BACM and MSM.

As demonstrated in Appendix B of this 2015 PM2.5 Plan , the three main sources of ammonia emissions in the Valle y from stationary and area source s that account for 95% of the Valley’s ammonia emissi ons are as follows (based on 2015 estimates):

 Farming Operations with 198.0 tons per day (tpd),

 Solvent evaporation from Agric ultural Fertilizers at 116.3 tpd , and

 Composting Solid Waste Operations at 9.0 tpd.

The following discussion evaluates:

 Confined Animal Facili ties (District Rule 4570)

 Agricultural Fertilizers

 Organic Material Composting (District Rule 4566)

 Biosolids, Animal Manure, and P oultry Litter Operations (Distr ict Rule 4565)

 Major Sources of Ammonia

Confined Animal Facilities (District Rule 4570)

I. District Rule Description

District Rule 4570, was origi nally adopted on June 15, 2006 and was most recently amended on October 21, 2010. The purpose of this rule is to li mit emissions of volatile organic compounds (VOC) fr om Confined Animal Facilities (CAF). District Rule 4570 applies to facilities where anima ls are corralled, penned, or o therwise caused to remain in restricted areas and primar ily fed by a means other than gra zing for at least 45 days in any twelve-month period. In a ddition to limiting VOC emissi ons, District Rule 4570 also includes measures that lim it ammonia (NH3) emissions from these operations; theSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-241 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard required measures have reduced a mmonia emissions by over 100 tp d 121 (this reduction is reflected in the emissions i nventory data above). The analy sis below focuses on how District Rule 4570 limits NH3 emissi ons in comparison to other rules and regulations.

A. Types of Confined Animal Facilities

Confined Animal Facilities are u sed for the raising of animals including, but not limited to, cattle, calves, chickens, ducks, goats, horses, sheep, swin e, rabbits, and turkeys, which are corralled, penned, or otherwise caused to remain in r estricted areas for commercial agricultural purposes and fed by a means other than grazing. (CH&SC §39011.5 (a)(1)). The major categor ies of Confined Animal Faci lities are listed below.

 Dairy Operations - Dairy operat ions are those operations produ cing milk or animals for facilities that produce milk.

 Poultry Operations - Poultry facilities operate ei ther as layer ranches for egg production or as broiler ranches w here birds are grown for the fresh meat market.

 Beef Cattle Feeding Operations – Beef cattle facilities are fa cilities that raise beef cattle (heifers and stee rs) for their meat.

 Swine Operations – These operati ons 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 i n the Valley and the thresholds for a facility to be subject to District Rule 4570 a re shown in the following table. The large CAF thresholds are based on the definition of a large CAF adopted by ARB as required by C alifornia Senate Bill (SB) 700. District R ule 4570 applies to confined animal facilities that have the capacity to house a nu mber of animals equal to or exceeding the Rule 4570 regulatory thresholds, which are low er than the large CAF thresholds for certain facilities.

121 Appendix F of the Staff Report fo r the June 200 9 re-adoption of Rule 4570, starting on the 329 th page of the pdf available here http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agend a/2009/June/Agenda%20Item_10_June_18_200 9.pdfSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-242 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard 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 Requireme nts of District Rule 4570

District Rule 4570 requires multip le mitigation measures from t he following CAF categories: Dairy, Beef Feedlots, Other Cattle Facilities, Swin e Facilities, Poultry facilities, and various other s maller operations. Each of thes e facilities consists of multiple sources of emissions wit hin the facility. Since these facilities generally cover a large area and have different pro cesses, a single mitigation me asure or technology is generally not sufficient to contro l overall emissions from the facility. Mitigation measures required by Rule 4570 have been tailored for each sour ce of emissions, thereby ensuring that the overall emissions from a facility are reduced. The current methodology in Rule 4570 allows fo r the greatest overall contro l from the entire facility.

District Rule 4570 recognized the following five emission sourc es for all of the CAFs: Feed, Housing, Solid Waste, Li quid Waste, and Land Application of Manure. Rule 4570 requires each CAF to implement a certain number of mitigation m easures for each of these sources. District Rule 457 0 also distinguishes between t he different types of housing configurations (freesta ll vs open corrals) for cattle a nd, as such, requires specific mitigation measures fo r each type of housing. By requ iring mitigation measure(s) for each source of e missions at a facility, District Rule 4570 ensures that reductions are achieved throughout the facility.

The following describes some of t he mitigation measures and the ways in which these measures reduce ammonia emissions:

 Nutritional management: Ammonia emi ssions result from the deco mposition of undigested nitrogen compounds in ani mal waste. Proper nutritio nal management, with diets formulate d to feed proper amounts of pro tein, improves nitrogen utilization by the animal, reducing production of ammo nia from animal waste.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-243 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard  Increased cleaning and remova l of manure and litter from anima l housing areas: Because animal waste is the prim ary source of ammonia emissions , increased removal of waste from animal ho using areas will reduce emission s by reducing the exposed area. Proper m anagement of the waste will stabiliz e the nitrogen compounds in the waste, which wil l reduce the rate that these c ompounds are converted to ammonia that can be lost to the atmosphere. In ad dition, ammonia is highly soluble in water; ther efore, when a flush system is u sed, ammonia emissions will be redu ced because much of t he ammonia will diss olve in the water rather than volatilize to the air.

 Incorporation of manure into fiel ds: Incorporation of manure i n fields reduces volatilization of gaseous pollut ants by minimizing the amount o f time that the manure is exposed to the atmos phere. Once the waste has been i ncorporated into the soil, VOCs and ammonia are absorbed onto soil particle s, providing the opportunity for these soil microbe s to oxidize these compounds into carbon dioxide, water, and nitrates.

One area to which some of these rules may apply is silage and s ilage-based total mixed ration (TMR) used as feed for ca ttle. Research has demonstrate d that silage and TMR are one of the largest sources of VOC emissions at cattle facil ities but are not significant sources of NH3 emissions, which p rimarily results from the anim al waste at CAFs; therefore, the measures that s pecifically apply to management o f 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 docu ment for confined animal facil ities.

B. EPA - Alternative Control Technology (ACT)

There is no EPA ACT guidance docu ment for confined animal facil ities.

C. Standards of Performance fo r New Stationary Sources (NSPS)

There is no NSPS gu idance document for gui dance document for co nfined animal facilities.

D. National Emission Standards for Haza rdous Air Pollutants (NESHAPs) and Maximum Achievable Control Technologies (MACTs)

There is no NESHAP gui dance document for confined animal facili ties.

III. How does District Rule 4570 compare to rules in other air districts?

As the largest agricultural area in California, the District to ok the lead in devising a list of mitigation measures for the vari ous emission sources during the initial development ofSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-244 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard District Rule 4570. This list of mit igation measures was essen tially utilized, almost identically, by all air district s in their rules. However, dur ing the last amendments to District Rule 4570, all of the miti gation measures were reevalu ated in light of the latest available science. In comparison to the previous version of th e rule, the current rule lowered threshold limits to bri ng in additional CAFs, requires additional mitigation measures, clarified previous mitigation measures, and added add itional monitoring, testing, and recordkeeping to improve enforceability.

The following California air dis trict rules were compared to Di strict 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 (Exempti ons), amended April 8, 2008

 SMAQMD Rule 496, adopted August, 24, 2006

 Imperial County APCD (ICAPCD) Rule 217 and Policy Number 38, a dopted October 10, 2006

 Butte County AQMD (BCAQMD) Rul e 450, adopted De cember 21, 2006

Idaho Administrative Procedure Act (IDAPA) 58.01.01 Sections 76 0-764 was also compared with District Rule 4570 and the analysis is shown belo w.

It is important to note that onl y District Rule 4570, SMAQMD Ru le 496, and SCAQMD Rule 1127 are prohibitory rules . For this reason, these rules include detailed recordkeeping as well as monito ring and testing requirements. Generally, the level of detail in a prohibitory rule is absent from permits rules becau se the purpose of a permit rule is different from the pur pose 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 am ended.

SCAQMD Rule 223 applies to lar ge CAFs as defined by ARB. Distr ict Rule 4570 defines large CAFs the same way except for large CAFs for horse s. District Rule 4570 defines a large CAF for horse s as having at least 3,000 he ad, whereas SCAQMD Rule 223 defines a large CAF for horses as having at lea st 2,500 head. There are currently no CAFs in the Valley with the capac ity to house at least 2,500 horses and no CAFs for horses in the Valley are exp ected to exceed this threshold in the foreseeable future.

In addition to applying to large CA Fs, District Rule 4570 lower s the applicability thresholds for the following CAFs:

 Dairies – from 1,000 milk cows to 500 milk cows

 Broilers/Ducks and Layers – fr om 650,000 birds to 400,000 bird sSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-245 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Therefore, Rule 4570 is more stringent regarding applicability.

Requirements for Dairy CAFs

Feed Mitigation Measures

District Rule 4570 has seven miti gation measures for feed and t wo mitigation measures for silage. Operators must implement four mandatory f eed mitigation measures and chose another one fr om a list of three, for a tota l of five mitigation measures required for feed. In th e SCAQMD rule, there are nine feed mitigation measures, from which the operator must implement five. Both ru les require selection of five mitigation m easures for feed, excluding silag e, but four of the five feed mitigation measures a re mandatory in District Rule 45 70. Therefore, overall District Rule 4570 is more stringent.

Milk Parlor Mitigation Measures

The milk parlor mitigation meas ures for SCAQMD includes one Cla ss One and one Class Two mitigation measure . District Rule 4570 contains the same mitigation measures included in the SCAQMD rule as Class One an d has removed the Class Two mitigation measures due to infeasibility; see the Staff Report for the October 21, 2010 amendments to Rule 4570 for mor e detail. Therefore, both rule s will be considered identical in this cate gory.

Freestall Mitigation Measures

District Rule 4570 has five mitigat ion measures, two of which a re mandatory. The facility is also required to choose one additional mitigati on measure from the remaining three. SCAQMD Rule 223 has eight Class One mitigatio ns measures, from which facilities are requir ed 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 O ne mitigation measures that re quire 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 re quires pipes and troughs to be inspected daily, and manur e from freestall beds to be rem oved daily, whereas District Rule 4570 does not require inspection of pipes and troughs in freestall barns. In the Valley, t he majority of freestall barn s use flush systems for manure management and may also use misters or water sprays to k eep animals cool; therefore, inspection of t he pipes and troughs in the fre estall barns was determined to be irrelevant since this is already a wet system. SCAQMD Rule 223 requires freestall beds to be ra ked/harrowed/graded at leas t twice every seven days, whereas District Rule 4570 requires this measure to be carried out once every 7 days for large dai ries and once every 14 days for medium dairies.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-246 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Although, SCAQMD Rule 223 has a higher frequency for these meas ures, the emissions generated from these s ources are not significant, inc luding the reductions achieved from the ov erall dairy. In addition, the C AF stakeholders have questioned the cost effectiv eness of a daily frequency.

Corral Mitigation Measures

District Rule 4570 has nine mitiga tion measures, six of which a re mandatory. The facility is also required to choose one additional mitigati on measure from the remaining three. SCAQMD Rule 223 has 14 Class One mitigation m easures and two Class Two mitigation measures , from which facilities are re quired to choose at least six. District Rule 4570 requires one additional mitig ation measure; therefore, District Rul e 4570 is more stringent.

SCAQMD Rule 223 has one Class One mitigation measure ( inspect water pipes and troughs and repair leaks ) that require increased fr equency in comparison to the corresponding District Rule 4570 measure. SCAQMD Rule 223 requires this measure to be carried out daily , whereas District Rule 4570 req uires it to be carried out only once every sev en days. Although, SCAQMD Rule 223 has a higher frequency for this measure , the difference in the emissi ons reductions from the two frequencies is not e xpected to be significant.

Solid Waste and Separated So lids 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 Cla ss Two mitigation measures, fr om which facilities are required to choose at least two.

Available studies have indicat ed that NH3 emissions from stored solid waste and separated solids pile to be a ve ry small fraction of total NH3 emissions at dairies. Since the NH3 emissions from so lid manure account for a very sm all fraction of emissions from the overall dairy , there would not be a signific ant increase in NH3 emission reductions if more measur es are required from this cat egory.

Liquid Waste Mitigation Measures

District Rule 4570 has four mitigat ion measures, from which ope rators are required to choose at least one. SCAQMD Rule 223 has five Clas s One mitigation measures and five Cla ss Two mitigation measures, fro m which operators are required to choos e at least one. Since only one measure is required by both rules, the rule s are similar in stringency.

Manure Land Application Mitigation Measures

District Rule 4570 has two mitigat ion measures required out of six optional measures. SCAQMD Rule 223 has f our mitigation measures, from w hichSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-247 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard facilities are required to choos e at least two. All the mitiga tion measures are similar in stringency.

Requirements for Poultry CAFs

There is a large degree of vari ability in the manure management practices, housing techniques, and potential feeding practices for the dif ferent type of poultry operations in the Valley . Due to these differences, Di strict Rule 4570 separates poultry CAFs into the following categories: 1) layers and 2) broilers, ducks, and turkeys.

Although on the surface the poultr y requirements results in few er mitigation measures compared to the other r ules, the segregating of the ty pes of poultry has allowed the mitigation measur es to be tailored specifically to the type of poultry operation. In addition, all measures for poultry in Di strict Rule 4570 are now mandated rather than left as options. Due to this reconfig uration and taking into consideration the latest science, the District Rule 4570 r equirements for poultry are more stringent than SCAQMD Rule 223.

Requirements for Ot her CAF Categories

In addition to dairy and poultry CA F mitigation measures discus sed above, District Rule 4570 provides specif ic mitigation measures for be ef cattle feedlots, other cattle, and swine CAFs. S CAQMD Rule 223 does not address mitigation measures for these additional CA F categories. For these types of large CAFs, District Rule 4570 is more stringent.

Requirements – Suspension and S ubstitution of Mitigation Measur es

Both rules allow the temporary su spension of a mitigation measu re upon the determination by a certified vete rinarian or nutritionist that such a suspension is necessary for animal health pur poses. The District must be not ified within 48 hours, and a new measure must be implemented if the suspension is expected to last longer than 30 days. In additi on, both rules allow for su bstitution of one mitigation measure with an equi valent or more stringent one wit h the submission of the appropriate information . Therefore, the suspension and substitution requirements of both rule s are equally stringent.

Conclusion – Comparison with South Coast AQMD Rule 223

Based on the analysis of the CAF categories in District Rule 45 70 and SCAQMD Rule 223, it is clear that District Rule 4570 is more stringent than SCAQMD Rule 223. There are differences in t he frequency with which some mi tigation measures are to be implemented. H owever, as stated earlier, ma ny of these sources are a small portion of a dairy’s overall emissions. Th e amended version of District Rule requires facilit ies to choose more mitigation measures and makes several mitigation measures mandatory.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-248 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard District Rule 4570 also provides m itigation for more CAF catego ries (beef feedlots, other cattle, and swin e) that are not addressed by SC AQMD Rule 223, and also has much more detailed recordkeeping requirements to d emonstrate implementation of selected miti gation measures. In addition, S CAQMD recently identified District Rule 4570 as the most stringent rule for th is source category in their ozone Reasonably Available C ontrol Technology (RACT) Demo nstration. 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 dairi es with 50 or more cows, heife rs, 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, Dis trict Rule 4570 applies to dairy CAFs with at l east 500 milking cows, but appli es to more than just manure-handling operations. Although the SCAQMD Rule has a lower applicability threshold, the over all control effectiveness of R ule 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 Distr ict rule has one mandatory mit igation measure. District Rule 4570 has five mitigat ion measures for freestalls, two of which are mandatory. The facility is als o required to choose one additio nal mitigation measure from the remaining three to implement. SCAQMD Rule 112 7 does not address these operations. Therefor e, overall District Rule 457 0 is more stringent than SCAQMD Rule 1127.

Corral Mitigation Measures

District Rule 4570 has nine mitiga tion measures, six of which a re mandatory. The facility is also required to choose one additional mitigati on measure from the remaining three. SCAQMD Rule 1127 has eight mitigation measure s, from which facilities are required to choos e at least six. The mitigation measures required by SCAQMD Rule 1127 specify the re moval of manure fr om the corrals , the minimization of water in the corrals, and the cleaning schedule and cleaning strategy for the corrals. While t he mitigation measures in the two rules are not

122 South Coast Air Quality Management District (June 6, 2014). Re asonably Available Control Technology Demonstration. http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board /2014/2014-jun6- 031.pdf?sfvrsn=2San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-249 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard phrased the same way, they cover similar requirements. Distric t Rule 4570 requires one additional measure; therefore , Rule 4570 is more s tringent.

Solid Waste, Separated Solids, and Liqu id Waste, and Manure Land Application Mitigation Measures

District Rule 4570 has two mitigati on measures for solid waste/ separated solids, from which operators are requi red to choose at least one. For liquid waste, District Rule 4570 has four mitigat ion measures for liquid wast e, from which operators are required to choose at least one. District Rule 4 570 has two mitigation measures for land app lication of manur e required out of six optional measures. SCAQMD Rule 1127 st ates that manure removed must be either treated at an approved manure processing o peration, or applied on agricultural land with local approval. SCAQM D Rule 1127 does not specify di fferent mitigation measures for solid waste, separated solids, or liqui d waste. District Rule 4570 has specific mitigati on measures for each of these op erations; therefore, it is able to bette r target the reduction of emissio ns from these the different operations. District R ule 4570 is therefore as strin gent as or more stringent than SCAQMD Rule 1127.

Requirements for Other CAFs

District Rule 4570 provides specif ic mitigation measures for be ef cattle feedlots, other cattle facilities, poultry facilities, and swine faciliti es. SCAQMD Rule 1127 does not address mitigation meas ures for these additional CAF c ategories. Therefore, District Rule 4570 is more stringent for this catego ry.

Requirements – Suspension and S ubstitution of Mitigation Measur es

SCAQMD Rule 1127 provides one exemption per year from one of th e corral clearings required every 90 days if the moisture content in the corrals is greater than 50%. The operator is requir ed to notify SCAQMD 30 days be fore the required cleaning, and test moist ure content weekly. If moistu re content is still above 50% when the cleaning is d ue, the operator may claim the exemption.

In comparison, District Rule 4570 allows an operator to tempora rily suspend any mitigation measure as long as t he suspension is recommended by a licensed veterinarian of animal nutriti onist on the basis of animal heal th. The operator must notify the District within 48 hours prior to the suspensio n. 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 un der this category is much more stringent because it is only a temporary su spension that cannot exceed 30 days, whereas SCAQMD Rule 1127’s ex emption may be perm anent, without any requ irement to substitute another measure.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-250 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Therefore, in this category of m itigation measure suspensions/s ubstitutions, District Rule 4570 is more st ringent than SCAQMD Rule 1127.

Testing, Monitoring, Rec ordkeeping Requirements

Both SCAQMD Rule 1127 and Distr ict Rule 4570 require monitoring , record keeping and source testing as appropriate and sufficient to pro vide evidence of each mitigation measur e being implemented.

In addition to recordkeeping , Rule 1127 requires an annual repo rt of manure being shipped out from the dairy . No annual r eporting is requi red by Rule 4570. Rule 1127 requires records be re tained for 3 years for minor so urces and 5 years for major sources, whereas Rul e 4570 requires records be retain ed for five years for all sources.

Overall, the monitoring, testi ng and recordkeeping requirements are similar for both rules.

Conclusion – Comparison with SCAQMD Rule 1127

For dairy CAFs, District Rule 4570 is more stringent than SCAQM D Rule 1127. District Rule 4570 requires emi ssion reductions from additional emission categories - milk parlors, fr eestall barns, and liquid manure - that are not addressed by SCAQMD Rule 1127 as well as requiring emission red uctions from CAFs from other animal specie s. As mentioned above, the curren t version of District Rule 4570 requires facilit ies to choose more mitigatio n measures and makes several mitigation meas ures mandatory. District Rule 457 0 also provides specific mitigation measures fo r beef cattle feedlots, other ca ttle, poultry, and swine CAFs, while SCAQMD Rule 1127 does not. District Rule 457 0 is therefore more stringent than SCAQMD Rule 1127.

C. BAAQMD Regulation 2 Rule 10 (Rule 2-10)

BAAQMD Rule 2-10 is a permit ru le. As such, it has fewer speci fics about large CAFs than District Rule 4570, whi ch 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. Dist rict Rule 4570 defines large CAFs the same w ay 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 havi ng 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 Polluti on 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 CA Fs, District Rule 4570 lower s the applicability thresholds for the following CAFs:

 Dairies – from 1,000 milk cows to 500 milk cows

 Broilers/Ducks and Layers – fr om 650,000 birds to 400,000 bird s

Therefore, Rule 4570 is more stringent regarding applicability.

Requirements for CAFs

The BAAQMD permit conditions mus t implement control measures th at represent Reasonably Available Control Te chnology (RACT) to reduce emissi ons of VOC, NOx and PM from the facility. BAAQMD Rule 2-10 requires RACT m itigation measures rather than the more s tringent BARCT controls required by District Rule 4570 as specifically not ed in the BAAQMD staff report for their rule. District staff previously contacted BAAQMD staff and verified that there is no list of RACT mitigation measur es 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, Rec ordkeeping Requirements

District Rule 4570 requires record s to be maintained and retain ed for at least five years, whereas BAAQMD Rule 2-10 r equires records to be retained for three years. District Rule 4570 theref ore has a more stringent recor d retention requirement.

District Rule 4570 requires facilities not subject to the mitig ation measure requirements to maintain suffici ent records to demonstrate thei r exemption status. Facilities subject to t he mitigation measure requireme nts must maintain sufficient records to demonstrate implementation of each mitiga tion measure selected. Facilities must also maintain animal population reco rds. BAAQMD Rule 2-10 requires the maintenan ce of animal population records but does not require specific records needed to demonstrate im plementation o f each mitigation measure selected. District Rule 4570 is therefore m ore stringent in the type of records that must be maintained.

Conclusion – Comparison with Bay Area AQMD Regulation 2 Rule 10

District Rule 4570 requires facilit ies to choose specific mitig ation measures and makes several mitigation measur es mandatory. In addition, Dist rict Rule 4570 has lower applicability threshol ds for dairies, chickens, and d ucks. Based on this information and the discussion abov e, District Rule 4570 is far more stringent than BAAQMD Rule 2-10.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-252 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard D. VCAPCD Rule 23 – E xemptions from Permit

In response to California Senate Bill (SB) 700, VCAPCD revised its “Exemptions from Permit” rule to remove an exemption for agricultural opera tions, including CAFs. VCAPCD does not have a spec ific rule for CAFs. In its s taff report for the rule revision, VCAPCD staff not ed that no facilities in their j urisdiction would meet the “large CAF” definition and t here was no expectation that a large CAF would move into the area in the fores eeable future; therefore, no sep arate CAF rule
was necessary.

Applicability/Exemption/ Large CAF Definition

VCAPCD Rule 23 adopted ARB’s definition of large CAFs. Distric t Rule 4570 defines large CAFs the same way except for large CAFs for horse s. District Rule 4570 defines a large CAF for horse s as having at least 3,000 he ad, whereas VCAPCD Rule 23 defines a large C AF for horses as having at leas t 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 horse s in the Valley are expected to exceed this threshold in the foreseeable future.

In addition to applying to large CA Fs, District Rule 4570 lower s the applicability thresholds for the following CAFs:

 Dairies – from 1,000 milk cows to 500 milk cows

 Broilers/Ducks and Layers – fr om 650,000 birds to 400,000 bird s

Therefore, Rule 4570 is more stringent regarding applicability.

Requirements for CAFs

There are no facilities that woul d trigger the large CAF thresh old 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 tri ggered by a new CAF that met t he “large CAF” definition or BACT wo uld be triggered if an existing CAF expand ed operations enough to meet the “large CAF” defin ition. At that point, VCAP CD staff would determine BACT for the CAF.

Conclusion – VCAPCD Rule 23

VCAPCD does not have a specific rule for CAFs; therefore, Distr ict Rule 4570 is more stringent.

E. SMAQMD Rule 496

Like District Rule 4570, SMAQMD Ru le 496 is a prohibitory rule, meaning that there are detailed requir ements for operators.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-253 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Applicability/Exemption/ Large CAF Definition

SMAQMD Rule 496 was adopted on August 24, 2006 and has not been amended.

SMAQMD Rule 496 applies to lar ge CAFs as defined by ARB. Distr ict Rule 4570 defines large CAFs the same way except for large CAFs for horse s. District Rule 4570 defines a large CAF for horse s as having at least 3,000 he ad, whereas SMAQMD Rule 496 defines a large CAF for horses as having at lea st 2,500 head. There are currently no CAFs in the Valley with the capac ity to house at least 2,500 horses and no CAFs for horses in the Valley are exp ected to exceed this threshold in the foreseeable future.

In addition to applying to large CA Fs, District Rule 4570 lower s the applicability thresholds for the following CAFs:

 Dairies - 1,000 milk cows to 500 milk cows

 Broilers/ducks and Lay ers – 650,000 – 400,000

Therefore, Rule 4570 is more stringent regarding applicability.

Requirements for Dairy CAFs

Feed Mitigation Measures

District Rule 4570 has seven miti gation measures for feed and t wo mitigation measures for silage. Operators must implement four mandatory f eed mitigation measures and chose another one fr om a list of three, for a tota l of five mitigation measures required for feed.

SMAQMD Rule 496 has seven Class O ne mitigation measures for fee d and two Class One mitigation measures f or silage. Operators must imple ment four feed mitigation measures and one si lage mitigation measure.

District Rule 4570 requires a tota l of five feed mitigation mea sures, excluding silage, which is greater than t he four feed miti gation measures required by SMAQMD Rule 496. In addition, f our of the five feed mitigation measures are mandatory in District Rule 4570. T herefore, District Rule 4570 is more stringent.

Milk Parlor Mitigation Measures

District Rule 4570 has one required milk parlor mitigation meas ure. SMAQMD Rule 496 also only requires one mi tigation measure for milk par lors. Since both rules only require the use of one mitigation measure, both rule s will be considered identical for this category.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-254 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Freestall Mitigation Measures

District Rule 4570 has five freesta ll mitigation measures, two of which are mandatory. The facility is als o required to choose one additio nal mitigation measure from the remaining thr ee. SMAQMD Rule 496 has eight Cl ass One mitigations measures and one Class Two mitigation measure from which facilities are required to imple ment at least two.

Rule 4570 is more stringent since it requires more mitigation m easures.

Corral Mitigation Measures

District Rule 4570 has nine corral mitigation measures, six of which are mandatory. The facility is also required to choose one additio nal mitigation measure from the remaining thr ee. SMAQMD Rule 496 has 15 Class One mitigation measures, which are all optional, and three Class Tw o mitigation measures, from which facilities are required to choose at least six. District Rule 4570 requires one additi onal mitigation meas ure; therefore in t his 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 req uires it to be carried out only once every sev en days. Although, SMAQMD Rule 496 has a higher frequency for this measure , the difference in the emissi ons reductions from the two frequencies is not e xpected to be significant. Ov erall, District Rule 4570 is more stringent.

Solid Waste and Separated So lids Mitigation Measures

District Rule 4570 contains only two mitigation measures, from which operators are required to choose at least o ne. SMAQMD Rule 496 has five Class One mitigation measures and three Cla ss Two mitigation measures, fr om which facilities are required to choose at least two.

Available studies have indicat ed that NH3 emissions from stored solid waste and separated solids pile to be a ve ry small fraction of total NH3 emissions at dairies. Since the NH3 emissions from so lid manure account for a very sm all fraction of emissions from the overall dairy , there would not be a signific ant increase in NH3 emission reductions if more measur es are required from this cat egory.

Liquid Waste Mitigation Measures

District Rule 4570 has four mitigat ion measures mitigation meas ures, from which operators are required to choose at least one. SMAQMD Rule 496 has four Class One mitigation measures and four Class Two mitigation mea sures, fromSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-255 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard which facilities are required to choose at least one. Since on ly one measure is required, both rules are equi valent in this respect.

Manure Land Application Mitigation Measures

District Rule 4570 has two mitigat ion measures required out of six measures. SMAQMD Rule 496 has six Class O ne mitigation measures, from whi ch facilities are required to choose at least t wo. Since two mitigation meas ures are required, both rules are equivalent in this respect.

Requirements for P oultry Large CAFs

There is a large degree of vari ability in the manure management practices, housing techniques, and potential feeding practices for the dif ferent type of poultry operations in the Valley . Due to these differences, Di strict Rule 4570 separates poultry CAFs into the following categories: 1) layers and 2) broilers, ducks, and turkeys.

Although on the surface the poultr y requirements results in few er mitigation measures compared to the other r ules, the segregating of the ty pes of poultry has allowed the mitigation measur es to be tailored specifically to the type of poultry operation. In addition, all measures for poultry in Di strict Rule 4570 are now mandated rather than left as options. Due to this reconfig uration and taking into consideration the latest science, District Rule 4570 requi rements for poultry are more stringent than SMAQMD Rule 496.

Other CAFs

In addition to dairy and poultry CA F mitigation measures discus sed above, District Rule 4570 provides specif ic mitigation measure option tables for beef cattle feedlots, other cattle facilities, and swine facilities. SMAQMD Rule 496 does not address mitigation meas ures for these additional CAF c ategories. For these types of large CAFs, Distr ict Rule 4570 is more stringent

. Requirements – Suspension and S ubstitution of Mitigation Measur es

Both rules allow for substituti on of one mitigation measure wit h an equivalent or more stringent measure with the submission of the appropriate a pplication. District Rule 4570 also allows the temporary suspension of a mi tigation measure upon the determination by a certi fied veterinarian or nutrition ist that such a suspension is necessary for animal health purposes. The Distri ct must be notified within 48 hour s, and a new measure must be implemented if the suspension is expected to last longer than 30 days. SMAQMD Rul e 496 does not have a specific provision fo r temporary suspension of mitig ation measures. As discussed above, District Rul e 4570 is as stringent as SMAQM D Rule 496.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-256 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Testing, Monitoring, Rec ordkeeping Requirements

The testing, monitoring, and recordkeeping provisions of Distri ct Rule 4570 and SMAQMD Rule 496 ar e nearly identical and are of equal stringenc y.

Conclusion – Comparison with Sac Metro AQMD Rule 496

For dairy CAFs, District Rule 4570 is more stringent than SMAQM D Rule 496. District Rule 4570 requires emi ssion reductions from four addit ional emission categories - milk parlors, f eed, freestall barns, and liquid ma nure - that are not addressed by SMAQMD Rule 496 as w ell as having specific require ments for other types of CAFs. District R ule 4570 also requires faciliti es to choose more mitigation measures and mandates several mitigation measures. In addition, Rule 4570 applies to dairies wit h greater than 500 milk cows an d 400,000 layers and broilers while SMAQMD Rule 496 applies to dairies with 1,00 0 milk cows or more and broiler and layer oper ations with more than 650,000 bi rds. As shown in the discussion above, District Rule 4570 is more stringent t han SMAQMD Rule 496.

F. ICAPCD Rule 217 – Large Conf ined Animal Facilities Permits R equired and ICAPCD Policy Number 38 – Recomme nded Mitigation Measures for L arge Confined Animal Facilities

ICAPCD Rule 217 is a permits rul e. ICAPCD Rule 217 requires th at owners or operators of large CAFs submit an emissions mitigation plan tha t demonstrates that the facility will use RACT to reduce emissions of pollutan ts that contribute to the non-attainment of any ambie nt air quality standard and are within the ICAPCD’s regulator y authority.

ICAPCD Rule 217 requires operator s of large CAFs to implement t he control measures identified in their emi ssions mitigation plan, which m ay be selected from the ICAPCD Policy Number 38 , Recommended Mitigation Measur es for Large Confined Animal Facilitie s. ICAPCD Policy Number 38 spec ifies the number of mitigation measures t he operator should implement for each operation within the CAF. The following discussion compares the recommen ded mitigation measures in ICAPCD Policy Number 38 to the measures in District Rule 4570. However, since the mitigation me asures in ICAPCD Policy Number 38 are only recommended by ICAPCD Rule 217 ra ther than being explicitly req uired, it is clear that District Rul e 4570 is more stringent.

Applicability/Exemption/ Large CAF Definition

ICAPCD Rule 217 was adopted on Oc tober 10, 2006 and has since n ot been amended.

ICAPCD adopted ARB’s def inition of large CAF. District Rule 45 70 defines large CAFs the same way except for la rge CAFs for horses. District R ule 4570 definesSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-257 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard a large CAF for horses as hav ing at least 3,000 head, whereas I CAPCD Rule 217 defines a large CAF for horse s as having at least 2,500 hea d. There are currently no CAFs in the Valley with the capacity to house at l east 2,500 horses and no CAFs for horses in the Valle y are expected to exceed thi s threshold in the foreseeable future.

In addition to applying to large CA Fs, District Rule 4570 lower s the applicability thresholds for the following CAFs:

 Dairies – from 1,000 milk cows to 500 milk cows

 Broilers/Ducks and Layers – fr om 650,000 birds to 400,000 bird s

ICAPCD Policy Number 38 only lists mitigation meas ures for dairy operations and beef feedlot operations while Dis trict Rule 4570 covers additio nal CAFs (swine, chicken layer, chicken broiler , duck and turkey, and other CAFs ). Therefore, more CAFs are subject to the requ irements 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 rule s are identical under this secti on.

Freestall Mitigation Measures

District Rule 4570 has five freesta ll mitigation measures, two of which are mandatory. The facility is als o required to choose one additio nal mitigation measure from the remaining thr ee. ICAPCD Policy Number 38 has eight mitigation measures, from which operators are required to choos e at least two. Since District Rule 4570, require s three mitigation measures an d mandates two out of the three, District Rul e 4570 is more stringent than ICA PCD Policy Number 38.

Corral Mitigation Measures

District Rule 4570 has nine mitiga tion measures, six of which a re mandatory. The facility is also required to choose one additional mitigati on measure from the remaining three. ICAPCD Policy Nu mber 38 has eight mitigation measures, from which facilities are requi red to choose at least four.

For three of the mitigation meas ures, the compliance times diff er between the District rule and ICAPCD Policy Nu mber 38. For these measures, ICAPCD Policy Number 38 allows longer ti me periods between repeated pe rformance ofSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-258 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard the measures than District Rule 4570. For these three mitigati on measures, District Rule 4570 is more stri ngent because District Rule 4570 requires repeated performance of the otherwise ident ical mitigation measures in s horter time periods.

For two of the mitigation meas ures, the maximum depth of manure differs significantly between the Distr ict Rule 4570 and ICAPCD Policy Number 38. For these measures, ICAPCD Policy Nu mber 38 allows manure depths th at are deeper than allowed by District R ule 4570. For these two mitig ation measures, District Rule 4570 rule is more s tringent because the District Rule 4570 requires shallower manure depths for other wise identical mitigation meas ures.

Therefore, District Rule 4570 is far more stringent than the IC APCD Policy Number 38.

Solid Waste and Separated So lids Mitigation Measures

District Rule 4570 has two solid w aste and separated solids mit igation measures, from which operators are requi red to choose at least one. ICAP CD Policy Number 38 has four mit igation measures from which facilities ar e required to choose at least one. Therefore, both rules are identical in th is category.

There are a few differences in ICAPCD Policy Number 38 mitigati on measures when compared to District Rule 4570. ICAPCD Policy Number 38 p olicy 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 th e ICAPCD are able to allow manure to accumula te in the corrals until it can be hauled offsite. Few, if any, CAFs in the ICAPCD ar e expected to actually store manure onsite outside of corrals, so it is likely that no facilities in ICAPC D are actually choosing and implementing this measure. S eparated solids piles are not specifically addressed in ICAPCD Policy Number 38. Overall District Rule 45 70 is as stringent as ICAPCD Policy Number 38.

Liquid Waste Mitigation Measures

District Rule 4570 has four liquid waste mitigation measures, f rom which operators are required to choose at least one. ICAPCD Policy N umber 38 has four mitigation measures, from w hich operators are required to choose at least one. ICAPCD Policy Number 38 c ontains an option to manage the facility so that lagoons only contain waste from milking parlor and storm w ater as a mitigation measure. District R ule 4570 does not contain this o ption. This difference, although worth noting , is not expected to influence the overall effectiveness of District Rule 457 0; District Rule 4570 is as s tringent as ICAPCD Policy Number 38.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

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 mitigat ion measures that are mandato ry if applicable. ICAPCD policy has a menu of five mit igation measures from which operators are required to choose two. Since tw o measures are required by bot h ICAPCD Policy Number 38 and District R ule 4570, they will be considere d identical under this category.

Requirements for Beef Feedlot CAFs

Animal Housing Mitigation Measures

District Rule 4570 has nine mitiga tion measures, six of which a re mandatory. The facility is also required to choose one additional mitigati on measure from the remaining three. ICAPCD Policy Nu mber 38 has nine mitigation m easures, from which facilities are required to choose at least four. Since o perators in Imperial County are required to implemen t fewer mitigation measures, Dis trict Rule 4570 is more stringent.

For three of the mitigation meas ures, the compliance times diff er between the District rule and ICAPCD Policy Nu mber 38. For these measures, ICAPCD Policy Number 38 allows longer ti me periods between repeated pe rformances of the measures than District Rule 4570. For these three mitigati on measures, the District rule is more stringent because the District Rule 4570 requires repeated performance of the otherwise ident ical mitigation measures in s horter time periods.

For two of the mitigation meas ures, the maximum depth of manure differs significantly between the Distr ict Rule 4570 and ICAPCD Policy Number 38. For these measures, ICAPCD Policy Nu mber 38 allows manure depths th at are deeper than allowed by District R ule 4570. For these two mitig ation measures, District Rule 4570 rule is more s tringent because the District Rule 4570 requires shallower manure depths for other wise identical mitigation meas ures.

Solid Waste and Separated So lids Mitigation Measures

District Rule 4570 has two solid w aste and separated solids mit igation measures, from which operators are requi red to choose at least one. ICAP CD Policy Number 38 has four mit igation measures from which facilities ar e required to choose at least one. Therefore, both rules are identical in th is category.

ICAPCD Policy Number 38 policy r equires that manure piles are c overed year round whereas District Rule 4570 r equires that the piles be cov ered from October through May – the months in the Valley in which rainfall is mos t likely. However, because of the greater depth of m anure allowed in corrals and i ncreased duration (up to two years) for removal of manure from the corra ls allowed by ICAPCD Policy Number 38, CAFs in the ICAPCD are able to allow m anure toSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-260 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard accumulate in the corrals unt il it can be hauled offsite. Few , if any, CAFs in the ICAPCD are expected to actually s tore manure onsite outside of corrals, so it is likely than no facilities in ICAPC D are actually choosing and i mplementing this measure. Overall District Rul e 4570 is as stringent as ICAPCD Policy Number 38.

Liquid Manure Handling

ICAPCD Policy Number 38 does no t address liquid manure handling for beef feedlot operations. This is lik ely because beef feedlot facili ties in ICAPCD do not generally use liquid manure m anagement systems. District Rule 4570 requires one measure to be selected out o f a menu of options, if applica ble. Therefore, Rule 4570 is more stringent in this category.

Manure Land Application Mitigation Measures

District Rule 4570 has two mitigat ion measures that are mandato ry 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 r equired by both ICAPCD Policy Number 38 and District Rul e 4570, they will be co nsidered identical under this category.

Requirements for Other CAFs

In the same manner as for dairy and beef feedlot operations, Di strict Rule 4570 specifies mitigation methods for confined animal facilities oth er than dairies and beef feedlots. ICAPCD Policy Num ber 38 only has mitigation mea sures for dairy and beef feedlot operations. In com paring the two documents, D istrict Rule 4570 is therefore more comprehensive and stringent.

Requirements – Suspension and S ubstitution of Mitigation Measur es

District Rule 4570 and ICAPCD Policy Number 38 allow for substi tution of one mitigation measure with an equi valent or more stringent one wit h the submission of the appropriate application . District Rule 4570 also allows the temporary suspension of a mitigation meas ure upon the determination by a certified veterinarian or nutritionist tha t such a suspension is necessar y for animal health purposes. The District must be notified within 48 hours, and a new measure must be implemented if the sus pension is expected to last longe r than 30 days. ICAPCD Policy Number 38 allows fo r temporary suspension of miti gation measures under circumstances s imilar to District Rule 4570. Ba sed on the discussion, Rule 4570 is as stringent as ICAPCD Policy Number 3 8.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-261 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Testing, Monitoring, Rec ordkeeping Requirements

District Rule 4570 requires record s to be maintained and retain ed for at least five years, whereas ICAPCD Rule 217 requi res records to be retained for two years. District Rule 4570 therefore has a more stringent record retent ion requirement.

District Rule 4570 requires facilities not subject to the mitig ation measure requirements to maintain suffici ent records to demonstrate thei r exemption status. Facilities subject to the mitigation measure requireme nts must maintain sufficient records to demonstrate implementation of each mitiga tion measure selected. Facilities must also maintain animal population reco rds. ICAPCD Rule 217 requires the maintenance of animal population records but d oes not require specific records needed to demons trate implementation of each m itigation measure selected. District Rul e 4570 is therefore more stringe nt in the type of records required to be maintained.

Conclusion- Comparison with IC APCD Rule 217 and ICAPCD Policy N umber 38

ICAPCD Rule 217 requires operator s of large CAFs to implement t he control measures identified in their emi ssions mitigation plan, which m ay be selected from the ICAPCD Policy Number 38, Recommended Mitigation Measur es for Large Confined Animal Facilities ; however, compliance with ICAP CD Policy Number 38 is not explicitly r equired by the rule. District Rul e 4570 contains several mandatory mitigation meas ures, unlike the optional natu re of the mitigation measures in ICAPCD Rule 217. District Rule 4570 als o has a lower applicability threshold for dairies (500 milk cows). In additi on, ICAPCD Policy Number 38 only lists mitigation measures for dairy operations a nd beef feedlot operations while District Rule 457 0 covers additional CAFs (swi ne, chicken layer, chicken broiler, duck and turk ey, and other CAFs). As shown th e discussion above, District Rule 4570 is far more stringent than ICAPCD Rul e 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 ter ms, the requirements for a complete pe rmit application and how the staf f would evaluate and approve/disapprove t he 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 def inition of large CAF. District Rule 45 70 defines large CAFs the same way except fo r large CAFs for horses. Dist rict Rule 4570 defines a large CAF for horses as having at least 3,000 head, w hereas BCAQMD Rule 450 defines a large CAF for horses as having at least 2,50 0 head. ThereSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-262 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard are currently no CAFs in the Va lley with the capacity to house at least 2,500 horses and no CAFs for horses in the Valley are expected to exc eed this threshold in the foreseeable future.

In addition to applying to large CA Fs, District Rule 4570 lower s the applicability thresholds for the following CAFs:

 Dairies – from 1,000 milk cows to 500 milk cows

 Broilers/Ducks and Layers – fr om 650,000 birds to 400,000 bird s

Therefore, Rule 4570 is more stringent regarding applicability.

CAF Requirements

BCAQMD Rule 450 requires large CAFs to obtain a permit and to s ubmit and implement a mitigation plan; how ever, the rule does not list mi tigation measures or specify the number of mitigat ion measures required. Distric t Rule 4570 has a menu of specific mitigation meas ures and stipulates the number of mitigation measures an operator is requir ed 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 a ll CAFs record the daily number of animals onsite. These records are to be ke pt on-site for two years and p resented if requested. District Rule 4570 r equires testing and records be kept to demonstrate compliance with the operator’s selected mitigation measures. The records are to be kept for fi ve years and presented upon the re quest of EPA or the District. Because District R ule 4570 covers testing, as we ll as having a longer record retention time, i t is more stringent than BCAQMD Rule 450.

Conclusion – Comparison wit h Butte County AQMD Rule 450

District Rule 4570 contains specifie s the actual mitigation mea sures 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 BCA QMD Rule 450.

H. IDAPA 58.01.01 Sect ions 760-764: Rules fo r the Control of Am monia from Dairy Farms

Applicability/Exemption

IDAPA 58.01.01 Sections 760-763 was adopted on March 30, 2007 a nd IDAPA 58.01.01 Subsection 764. 02: Table – Ammonia Control Practices f or Idaho Dairies was last am ended on May 8, 2009.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-263 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard Pursuant to IDAPA 58.01.01 Secti on 761, Sections 760-764 apply to dairies of the following sizes. The thres holds are based on estimating th e number of cattle required to produce 100 tons o f ammonia emissions annually. Di fferent thresholds are given for drylo t dairies, dairies with scraped f reestalls, 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 ma ture cow threshold to produce 10 0 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
2,293 27% volatilization 1 6,842 3,827

80% volatilization 2 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% volatilization 1 4,887 2,733

80% volatilization 2 4,589 2,643 No land app 5,063 2,781
1 Assumes expected level of N->NH 3 volatilization for drop-hose or ground level liquid manure application. 2 Assumes expected level of N->NH 3 volatilization for center pi vot or other conventional sprink ler irrigation liquid manure

application

The smallest dairy to which ID APA 58.01.01 Sections 760-764 app lies would have the equivalent of at least 1, 638 mature cows in flushed fr eestalls and a larger number of animals in scr aped freestalls or corrals. In c omparison, 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, inc luding beef cattle feedlots, oth er cattle facilities, poultry facilities, and swine fa cilities. Therefore, District Rule 4570 is more stringent regarding applicability.

Requirements for Dairies

Each dairy farm subject to IDAPA 58.01.01 Secti ons 760 - 764 mu st employ Best Management Practices (BMPs) for the control of ammonia. The BM Ps are applied to the following systems at a dairy: Waste Storage and Treatment Systems, General Practices, Fr eestall Barns, Open Lots and Corr als, Animal Nutrition, Composting Practice s, and Land Application. A total of twenty-seven (27) points must be achieved fo r the BMPs employed. The table located in Subsection 764.02 lists the approved BMPs and their associated point values. During development of the regulati on, a point system with a max imum of 20 points was assigned to each prac tice. A practice receiving 20 points equates toSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-264 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard a system or practice that is cons idered to result in major redu ction in ammonia emissions for that specific proc ess. However, according to the supporting documentation, this point system is “arbitrary”. 123 Therefore, there is no direct correlation from the points r equired and the amount of emission reductions achieved. In fact, due to the fl exibility 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 redu ctions may not be substantial. The Idaho Department of Environmental Qualit y (IDEQ) may also determine a practice not listed in the table constitute s a BMP and assign a point value. Points may also be obtained through third party e xport with sufficient document ation.

The paper Commentary Ammonia-Based Air Quality Permits for Idaho Dairies 124 indicated that, “ Solid separation of manure, co rral harrowing, low-pressure irrigation, composting, and rapi d manure removal from outdoor l ots were found to be the most common BMPs.”

Solids Separation In the Idaho regulation, solids s eparation refers to “gravity o r mechanical separation system to remove manure solids from liquid waste str eam.” This practice has been impl emented by almost all dairies in the Vall ey 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 co rral 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 beddi ng from an open lot surface in spring or as quickly as practicable. Distric t Rule 4570 has much more strin gent requirements for corral cleaning and maint enance at dairies. For corrals, D istrict Rule 4570 requires dairies to implem ent the following measures: a) Cleaning manure from corrals at least four times per y ear with at least 60 days betw een cleaning, or b) Cleaning corrals at least once between April and July and at le ast once between September and December ; a) Scraping, vacuuming, or flushing con crete lanes in corrals at least once every day for mature cows and every seven days for support stock, or b) Cleaning con crete lanes such that the dept h of manure does not exceed twelve inches at any point or time; inspection of wa ter pipes and troughs and repairing leaks at lea st once every seven days; and a) Sloping the surface of the corrals at least 3% where the available space fo r each animal is 400 square feet or less and Slopi ng the surface of the corrals at least 1.5%

123 Idaho Department of Environmental Quality (2006). Scientific B asis 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 Divisi on, Idaho Department of Environm ental Quality. http://www.deq.idaho.gov/media/635665-58_0101_0502_scientific_b asis_final.pdf
124 Sheffield, R. E. and Louks, B. ( 2008). COMMENTARY: Ammonia-Base d Air Quality Permits for Idaho Dairies. Environmental Practice, 10, pp 13-19. doi:10.1017/S146604660808 0046. http://journals.cambridge.org/acti on/displayAbstract?fromPage=o nline&aid=1888928San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-265 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard where the available space for each animal is more than 400 squa re feet per animal, b) Maintaining corrals to ensure proper drainage preven ting water from standing more than forty-eight (48 ) hours, or c) Harrowing, rak ing, or scraping corrals sufficiently to maintai n a dry surface. In addition, D istrict Rule 4570 requires dairies to choose an add itional corral mitigation meas ure, 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 moundi ng. Therefore, the corral cleaning and maintenance r equirements of District Rule 4 570 are far more stringent than IDAPA 58.01.01 Se ctions 760 – 764.

Previous emission studies conduct ed in the Valley have demonstr ated that the corrals and pens are the sources with the greatest potential fo r NH3 emissions in Valley dairies 125 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 Energ y/Pressure Application System s refers to use of center pivot and liner-move irr igation strategy that applies liquids at low pressures using drop nozzles. The guidance for the regulation s tates that larger droplets result in lower emissi ons but may cause infiltration p roblems on some soils. The use of center pivot and liner-move irrigation to ap ply liquid manure is very uncommon in the Valley and m ay be prohibit ed in the use pe rmits 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 wi th fresh irrigation water as generally required by e ither the Water Q uality Board o r the local County and as a means to avoid damage to growing crops. Because of th e reduced surface area, flood and furrow irri gation have even lower emiss ions than low pressure sprinkler irrigation systems. Dilution of the liquid manure with fresh irrigation water further reduces NH3 emissions and is also list ed as a BMP in the Idaho regulation. Therefore, the liquid manure practices utili zed in the Valley are more stringent than the Idaho regulation.

Composting In the Idaho regulation “c omposting” refers to stacking and drying of separated manure solids or corral manure. Almost all dairies in the Vall ey utilize this practice to prepare solid manur e and/or separated solids for be dding and/or for use on cropland. In addition, Dis trict Rule 4570 requires that dairies implement one of the following m easures for solid manure or separated sol ids: 1) w ithin 72 hours of removal from housing, e ither: a) Remove dry manure fro m the facility, or b) Cover dry manure outside t he housing with a weatherproof cov ering from October through May, except for ti mes when wind events remove t he covering,

125 See: Schmidt, C. and Card, T. ( 2006) Dairy Air Emissions Repor t: Summary of Dairy E mission Estimation Procedures (May 2006) . Final Report to Califor nia Air Resource Board (ARB). http://www.arb.ca.gov/ag/caf/SchmidtDairyEmissions2005.pdf http://www.arb.ca.gov/ag/caf/S chmidtDairyTestData2005.pdfSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-266 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard not to exceed 24 hours per event; o r 2) Within seventy-two hour s 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 ti mes when wind events remove t he covering, not to exceed 24 hours per event . Therefore, the general manag ement practices conducted on dairies in the Va lley and the requirements of District Rule 4570 are far more stringent than the Idaho regulation.

For dairy corrals, which are t he largest source of NH3 emission s at dairies in the Valley, District Rule 4570 require s more stringent mitigation m easures and a greater number of these measures . District Rule 4570 is also m ore specific in regards to mitigation measures r equired from other processes at dairies and the number of mitigation measures tha t must be implemented for each process; as a result, District Rule 4570 is abl e to better target the reducti on of emissions from these different operations. Ther efore, District Rule 4570 is m ore stringent than IDAPA 58.01.01 Sect ions 760- 764.

Requirements for Other Conf ined Animal Facilities

As stated above, District Rule 457 0 provides specific mitigatio n measures for beef cattle feedlots, other cattl e facilities, poultry faciliti es, and swine facilities. IDAPA 58.01.01 Sections 760-764 does not addr ess mitigation mea sures for these additional categories. Ther efore, District Rule 4570 is more stringent for this category.

Requirements – Suspension and S ubstitution of Mitigation Measur es

IDAPA 58.01.01 Subsection 762.03 prov ides that if a dairy farm not subject to Sections 760-764 becomes subject to these regulations as a resu lt of an emergency (for example if a dai ry farmer takes additional cows due to unforeseen circumstances), the da iry 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 th e consequences of the emergency continue. In t he event of unforeseen equipmen t upsets and breakdowns, so long as correctiv e action is taken within a reas onable time, the event does not reduce the BMP point value.

In comparison, District Rule 4570 allows an operator to tempora rily suspend any mitigation measure as long as t he suspension is recommended by a licensed veterinarian or animal nutriti onist on the basis of animal heal th. The operator must notify the District within 48 hours prior to the suspensio n. 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 un der this category is much more stringent because it is a temporary sus pension that cannot exceed 30 days , whereas theSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-267 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard IDAPA 58.01.01 Sections 760-764 exemption may last much longer, without any requirement to substitute another measure.

Therefore, in this category of m itigation measure suspensions/s ubstitutions, District Rule 4570 is more st ringent than IDAPA 58.01.01 Sectio ns 760-764.

Testing, Monitoring, Rec ordkeeping Requirements

Compliance with the requirements of IDAPA 58.01. 01 Sections 760 -764 is primarily determined by inspecti ons by the Idaho State Departme nt of Agriculture. The Idaho regulatio ns do not specify what records must be kept or have any requirement that the reco rds be maintained for a certa in period of time.

District Rule 4570 includes specific requirements for monitorin g, source testing as appropriate and recordkeeping to ensure mitigation measure a re being implemented. Facilities must also maintain animal population r ecords. District Rule 4570 also requires facilit ies not subject to the mitigatio n measure requirements to maintain suffici ent records to demonstrate thei r exemption status. District Rule 4570 requi res records be retained for fi ve years for all sources. District Rule 4570 is ther efore more stringent in thi s area.

Conclusion – Comparison with IDAPA 58.01.01 Sections 760-764

For dairy facilities, District R ule 4570 is far more stringent than IDAPA 58.01.01 Sections 760-764. Unlike IDAPA 58.01.01 Sections 760-764, Dist rict Rule 4570 requires specific practices for the various operations at dairi es. District Rule 4570 also provides specific mitigat ion measures for beef cattle feedlots, other cattle facilities, poultry facilities, and swine facilities, wh ile IDAPA 58.01.01 Sections 760-764 does not. The m easures required by the Idaho regulation are also based on an arbitrary point system and as such do not guar antee a specific degree of control. District Rul e 4570 is, therefore, more stri ngent than IDAPA 58.01.01 Sections 760-764.

IV. Evaluation of Additional Control Measures

Recent studies have cited the episodic application of sodium bi sulfate (SBS) onto manure at dairies as a potential control strategy to reduce amm onia emissions. SCAQMD included a pot ential control measur e within their 2012 A ir Quality Management Plan (AQMP) to evaluate the use of SBS at dairies to determine the technical and economic feasibilit y of its application in reduci ng ammonia emissions as well as potentia l impacts to groundwater. The Dis trict did not find any agency requiring the use of SBS. The District has evaluate d SBS as a potential control meas ure and determined that for a variety of reasons that this control strategy is infeasible and ineffective for reducing PM2 .5 concentrations in the Valley.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-268 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard SBS is an acid salt that has been used to reduce pH and bacteri al levels in the bedding for dairy cattle. Applic ation of SBS on fresh manure or corral surfaces has the potential to reduce ammoni a emissions by reducing the p H of the manure or corral surface. With a lower pH, a greater fraction of the ammonia is converted to non-volatile ammoni um (NH4+). The ammonium combin es with sulfate to form ammonium sulfa te, which is retained in the manu re or on the surface of the corral.

There are a number of potential issues that need to be consider ed related to the application of SBS at dairies i ncluding, but not limited to, th e health and safety of dairy workers and dairy cattle, i mpacts on water quality, and o verall cost and effectiveness. The SCAQMD 2012 AQ MP states: that potential use of SBS would be specific to dairies i n the SCAQMD and may be unique to localized operations, that “the requirem ents may not be applicable to dai ries elsewhere where a site-specific assessment would need to be made relative to those particular conditions”, and that i t is likely that each air dis trict would need to conduct an assessment as to the f easibility of SBS application in their jurisdiction.

The SCAQMD AQMP focuses on episo dic controls to reduce ammonia emissions during periods of hi gh PM2.5 concentrations. PM conc entrations in the Valley are highest during t he winter season (November – Feb ruary). Unlike the SCAQMD where the majority o f dairies are open corral facili ties, most dairies in the Valley utilize a freesta ll 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 littl e to no fresh manure excreted in corrals during the winter period. In addition, onc e 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 lar ge dairies would be very labor intensive, time consuming, be extremely cost ly, and would potentially pose heal th and safety risks to the workers.

Although SBS is generally consider ed to be safe in small quanti ties, excessive loading of salts is a major wa ter quality concern in the centra l and southern regions of the Valley where many dairies are located. In addit ion, 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 requir es significant amounts of SBS to be applied, whi ch as discussed below can be q uite costprohibitive. The application of SBS will also be short lived a nd conflict with requirements from Rule 4550 whic h requires dairies to scrape th eir corrals on a frequent basis at least once every two weeks, making the applic ation of SBS ineffective and even more costly due to the constant need to re apply.

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 re vised since the water qualit y surrounding dairies is a major concern and any additional impacts would nee d to beSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-269 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard thoroughly reviewed. This may r equire hauling manure significa nt distances to areas that would not be adversely affected by the increased sal inity, which would result in increased emissions and costs related to hauling.

There are significant costs asso ciated 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-1,9 55 lb/cow-yr of SBS would be ne eded for application to one entire corra l area, costing $430-$645/cow-yr . Using the District’s corral ammonia emissi on factor for milk cows and ass uming a conservatively high estimate of 50% reduction in overall ammoni a 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 s hows reduced costs of $129-$193/cow-yr for onl y treating heavy use areas, su ch as feed bunks and water troughs. It is not clear how much manure is excreted in heavy use areas, but even if the resulti ng cost per ton of reduction was cut in half, the costs would still be significant.

Also, because flush dairies are c ommon in the Valley (both free stall and open corral), the heavy use areas will generally be paved, and frequ ent flushing of the freestall or corral lanes (as r equired by Rule 4570) already si gnificantly reduces ammonia emissions; therefore, app lication of SBS to only these areas would not provide significant additional reductions i n ammonia emissions. By design, SBS will be flushed to a lagoon or pond where the high buffering ca pacity would render it ineffective and possibly increase H2S emissions.

Overall, given the insignifican t PM2.5 reduction achieved per t on of ammonia reduction (as demonstrated in this plan), the cost effectivenes s associated with implementing SBS translates to a much higher relative cost effe ctiveness when compared to other, more effectiv e strategies, su ch as NOx reduc tions.

V. Conclusion

While BACM and MSM requirements do not apply to ammonia since i t is not a significant precursor to PM2.5 formation in the Valley, Distric t staff concludes that District Rule 4570 meets BACM and MS M requirements for ammonia emissions from CAFs. The District evaluated the feasibility of additional amm onia emissions reductions and did not identify any additiona l feasible measures. In fact , the SCAQMD recently identified District Rule 4570 as the most stringent rule for th is source category. 126

Agricultural Fertilizers

Farms have continued to impro ve methods of fertilizer applicati on over the years to maximize nitrogen use efficiency and minimize environmental imp acts. Best

126 South Coast Air Quality Management District (June 6, 2014). Re asonably Available Control Technology Demonstration. http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board /2014/2014-jun6- 031.pdf?sfvrsn=2San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-270 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard management practices are being im plemented to minimize nitrate leaching in irrigated crop production. Researchers at UC Cooperative Extension have been studying the nitrogen use efficiency for va rious crop types and have begun i dentifying the point at which the applicati on of additional nitr ogen no longer signific antly increases crop quality and yields. This will allow grow ers to apply fertilizer with m ore precision to reduce the amount of nitrogen left in the soil.

Agricultural operations in Calif ornia are regul ated by the Stat e Water Resources Control Board, which is charged by the st ate Legislature in enforcing s tate and federal water quality protection laws . The State Water Resources Control Boa rd consists of Regional Water Quality Control Boards ( Regional Boards) that develop obj ectives and plans to protect the beneficial uses of wat er, recognizing local differe nces in climate, topography, geology and hydrology. All dairy farms in California’s Central Valley are regulated by the Central Valley Regional Wate r Quality Control Board (“Regio nal Board”). The vast majority of dairies— about 1,200 dairies—are regulated under a R egional Board General Order 127 and the remainder are regulated via individual orders that ens ure compliance with the same requirements. These requirements include:

 A Nutrient Management Plan (NMP) , prepared by a certified prof essional crop advisor or equivalent, designed to control nutrient losses for protection of surface water and groundwater;

 A Waste Management Plan (WMP), p repared by a licensed engineer ;

 Environmental sampling and moni toring of soil, manure, water a nd plant tissue for compliance;

 Routine site inspections, r ecordkeeping, and reporting; and

 Additional groundwater monitoring to assess ongoing water qual ity protection

A major purpose of these regulat ions is to ensure responsible s torage and use of manure as an important crop fe rtilizer and soil builder, thus p reventing unnecessary runoff or leaching of nitrogen compounds to the environment, wh ere they can impact water quality. The NMP is desig ned to assure that the amount o f nitrogen excreted by milking cows and support stock is in reasonable balance with th e needs of crops grown at the dairy farm. Man ure nitrogen in excess of crop needs sho uld be exported off the farm to where it can be used by other farmers. Nitrogen used o n 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 fo r crop growth and in the amou nts needed. Overapplication or mistimed applicat ion of nitrogen fertilizers can result in unnecessary losses of nitrogen to the environment, both as seepage below th e 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 s uggested in 2005 that “...optimal N loading rates of 1.4 to 1.65 times the crop N harvest rem oval are practical and, based on field observations,

127 http://www.waterboards.ca.gov/centralvalley/board_decisions/ado pted_orders/general_orders/r5-2013-0122.pdf
128 See “Managing Dairy Manure in t he Central Valley of California, ” published by the University of California Committee of Experts on Dair y Manure Management, 2005. http://groundwater.ucda vis.edu/files/136450.pdfSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-271 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard achievable if the production field is properly managed.” 129 The UC assessment was the ultimate basis for performance standards set by the Regional Bo ard in the General Order, which was adopt ed in 2007 and revis ed and reissued in 20 13. Research suggests that to achieve the more stringent targets in the Gene ral Order, many dairies had to greatly increase the prec ision of their manure and ferti lizer applications, while also reducing the overall amoun t of nitrogen applied to their c rops 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, losse s of nitrogen to groundwater al one 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 atmospher e as ammonia and other compounds following excretion o f manure from animals, during st orage of manure in ponds or corrals, and in the proce ss of applying manure to soil as a crop nutrient. 132 Thus, as a result of full implem entation of the General Order , losses of nitrates to groundwater on dairies may be reduced by up to 85 p ercent compared to pre-General Order conditions, t hough this number will be smalle r 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 fert ilizer to crops, and therefore, less opportunity for volatilization in t he fields. Some research already conducted f ound lower emissions with moderate nitrogen applic ations and suggested, “...synchronizing N applications with crop N demand. Once the N requirem ent for each crop stage is kn own, the N applications can be adjusted acco rdingly. This strategy should lead to improved N use efficiency and likely lower N2O emissions.” 133

Other nitrogen compounds such as a mmonia can also volatilize to air during application to fields. The University of Calif ornia Committee of Experts on Dairy Manure Management has suggested that dur ing application of manure wate r to crops, significant ammonia emissions can occur when manure water is no t 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, ammo nia losses from the ground surface will comm only be minimal during the irrigation ( 10% or less).” 134

Although additional r esearch will be helpf ul in quantifying the environmental benefits of improved waste management and nutri ent applications, the weight of evidence suggests that managing nutrient applications to fields as presc ribed in the General Order, especially compared to pre-General Order management on s ome dairy farms, has significantly reduced losses of nitrogen compounds to the e nvironment, including

129 Ibid., p. 47
130 “Cow Numbers and Water Quality – is there a magic limit?” (Hart er, Menke 2005), http://groundwater.ucdav is.edu/files/136451.pdf
131 Ibid., Harter.
132 Ibid., “Managing Dairy Manure in t he Central Valley of Californ ia.”
133 “Assessment of Nitrous Oxide Emissions in California’s Dairy Sy stems, DRAFT FINAL R EPORT, California Air Resources Board, Contract No. 09-325, William R. Horwath, Marti n Burger, Stuart Pettygrove, http://www.arb.ca.gov/researc h/rsc/10-18-13/it em6dfr09-325.pdf
134 Ibid., “Managing Dairy Manure in t he Central Valley of Californ ia,” p. 41.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-272 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard leaching of nitrogen compounds to groundwater and air emissions such as ammonia and nitrous oxide.

Organic Material Composti ng (District Rule 4566)

I. District Rule Description:

District Rule 4566 (Organic Material Composting) is the most st ringent rule in the nation for controlling emissions from composting operations; additiona l controls are infeasible. Additionally, as di scussed in Appendix E of this 2015 PM2.5 Plan, one of the technology focus areas for the Dis trict’s Technology Advancemen t Program is for waste solutions that focus on waste syst ems or technologies that mini mize or eliminate emissions from existing waste management systems and processes, including wasteto-fuel systems, such as dairy d igesters and other bio-fuel app lications. The District has taken every regulatory action feasible to reduce emissions from this source and continues to seek additional methods to reduce emissions throug h innovative strategies such as the support of research and technology demonstrations w ith potential to reduce emissions further.

District Rule 4566, was adopted on August 18, 2011, to limit VO C emissions from composting facilities whose feeds tock consists of greenwaste an d/or foodwaste. District Rule 4566 applies to operations that stockpile and compost gree nwaste and foodwaste. In addition to limiting VOC emi ssions, District Rule 4566 also limits NH3 emissions from these operations. The analysis bel ow focuses on how District R ule 4566 limits NH3 emissions in comparison to o ther 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 do cument for greenwaste or foodwas te composting operations.

B. EPA - Alternative Control Technology (ACT)

There is no EPA ACT guidance do cument for greenwaste or foodwas te composting operations.

C. Standards of Performance for New Stationary Sources (NSPS)

There is no NSPS gui dance document for greenwaste or foodwaste composting operations.

D. National Emission Standards for Ha zardous Air Pollutants (NESHAPs) and Maximum Achievable Control Technologies (MACTs)San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-273 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard 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 Distric t Rule 4566 with the rules for g reenwaste and foodwaste composting operations from other California air districts. The results of the analysis are discussed below. District staff o nly located one other air dis trict rule that applied to similar sources: SCAQMD Rule 1 133.3. No other air district rul es that applied to greenwaste or similar sources were found.

A. SCAQMD Rule 1133.3 - Emission Reductions from Greenwaste Com posting Operations (Adopted July 8, 2011)

The purpose of SCAQMD Rule 1133. 3 is to reduce emissions of VOC s and NH3 from greenwaste and foodwaste c omposting operations. The table below compares the significant similarities and differences between SJVAPCD Ru le 4566 and SCAQMD Rule 1133.3. For purpos es of this analysis, the ammonia control efficiencies achieved by the requi rements of SJVAPCD Rule 4566 are assumed to be the same as the VOC control effi ciencies since the same control measures will reduce both VOC and NH3 from these operations. It is worth not ing that greenwaste/foodwaste composting produces about 16% of the ammon ia emissions on a per ton basis compared to co-composting. 135

135 SCAQMD Rule 1133.3, baseline NH 3 emissions from greenwaste/foodwast e composting = 0.46 lb-NH3/t onthroughput. SCAQMD Rule 1133.2, baseline NH 3 emissions from co-composting = 2.93 lb-NH3/ton-throughput.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-274 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard 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 requi res 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, bas ed on discussions with SCAQMD p ermitting and rule development staff, SCAQMD does not have any greenwaste composti ng production facilities subject to the 80% amm onia reduction requirement of Rule 1133.3. SCAQMD has recently issued Authority to Construct permits for two expe rimental research greenwaste composting facilities located in Fontana and Riversi de operated by Burrtec. The permits authorize Burrtec t o perform greenwaste composting for one year (with the possibility of an extension) in order to evaluate the feasibili ty of three different compost emissions control technologies and conduct emissions testing fo r each technology. If atSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-275 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard the end of the permitted experimenta l research period, Burrtec wanted to convert one or both facilities into a regular g reenwaste composting production facility, they would need to obtain new ATC permits. The Burr tec facilities then are not re presentative of a commercial production greenwaste composting facility.

Because SCAQMD has no existing production greenwaste composting facilities that are subject to the 80% ammonia contro l 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 le vel of greenwaste composting.

B. No rules that apply to organ ic materials composting operatio ns were located for the air districts listed below:

 Amador County Air Pollution Control District (ACAPCD)

 Bay Area Air Quality M anagement District (BAAQMD)

 Eastern Kern County Air Poll ution Control District (EKAPCD)

 El Dorado County Air Q uality Management District

 Imperial County Air Polluti on Control District (ICAPCD)

 Mojave Desert Air Quality Management District (MDAQMD)

 North Coast Unified Air Qualit y Management District (NCAQMD)

 Placer County Air Pollution Control District (PCAPCD)

 Sacramento Metropolitan Air Qua lity Management District (SMAQM D)

 San Diego County Air Pollution Control District (SDCAPCD)

 Ventura County Air Polluti on Control District (VCAPCD)

 Yolo-Solano Air Quality Management District (YSAQMD)

C. IDAPA 58.01.01 Sect ions 760-764: Rules fo r the Control of Am monia from Dairy Farms

The purpose of IDAPA 58. 01.01 Sections 760-764 is to set forth requirements for the control of ammonia thr ough best management practices for ce rtain 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 app ly to other agricultural facilities or facilities in which the primary activity is the p roduction of compost. Therefore, it was determined that this regulation is not releva nt to the current analysis since it does not specifically limit emissions from co mposting facilities.

IV. Conclusion

While BACM and MSM requirements do not apply to ammonia since i t is not a significant precursor to PM2.5 formation in the Valley, Distric t staff concludes that District Rule 4566 meets BACM and MS M requirements for ammonia emissions from greenwaste and foodwaste compos ting operations. The District e valuated the feasibilitySan Joaquin Valley Unified Air Polluti on 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 emission s reductions and did not identify any additional feasible

measures.

Biosolids, Animal Manure, and P oultry Litter Operations (Distri ct Rule 4565)

I. District Rule Description:

District Rule 4565, was adopted on March 15, 2007, to limit VOC emissions from facilities whose throughput consis ts entirely or in part of bio solids, animal manure, or poultry litter. District Rule 4 565 applies to operations that landfill, land apply, compost, or co-compost these materials. In addition to limiting VOC emi ssions, District Rule 4565 also limits NH3 emissions from these operations. The analysis below focuses on how District Rule 4565 limits NH3 emissi ons 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 docu ment for biosolids, animal man ure, and/or poultry litter operations.

B. EPA - Alternative Control Technology (ACT)

There is no EPA ACT guidance docu ment for biosolids, animal man ure, and/or poultry litter operations.

C. Standards of Performance for New Stationary Sources (NSPS)

There is no NSPS gui dance document for biosolids, animal manure , and/or poultry litter operations.

D. National Emission Standards for Ha zardous Air Pollutants (NESHAPs) and Maximum Achievable Control Technologies (MACTs)

There is no NESHAP or MACT guidance documen t for biosolids, ani mal manure, and/or poultry litter operations.

III. How does District Rule 4565 compare to rules in other air districts?

District staff compared Distric t Rule 4565 with the rules for b iosolids, animal manure, and poultry litter operations from o ther California air distric ts. The results of the analysis are discussed below. District sta ff only located one other air district rule that applied to similar sources, which was SCA QMD Rule 1133.2. No other air di strict rules that applied to similar sources were found.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-277 Appendix C: BACM and MSM for Stationary and Area Sources 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 an d existing co-composting operations in the SCAQMD. Staff notes that there are some d ifferences between District Ru le 4565 and SCAQMD Rule 1133.2. This does not mean that one rule is more stringen t 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 h ave been completed since SCAQMD R ule 1133.2 was adopted; and 3. The socioeconomic climate of the SCAQMD is significantly dif ferent 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 differen ces between the two rules. For purposes of this analysis, the NH3 control effi ciency for the requirements of District Rule 4565 are assumed to be the same a s the VOC control efficiency for these requirement s 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 effe ctive, 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 pr actice, the facilities that a re actually subject to SCAQMD Rule 1133.2 will have much larger throughputs than 1,000 ton per yearSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-278 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard throughput threshold given in the rule. SCAQMD Rule 1133.2 inc ludes the following exemptions for existi ng co-composting operations with a design capacity of less than 35,000 tons of th roughput per year containing no m ore than 20 percent biosolids by volume and new and e xisting municipal facilities u sing aeration and processing less than 5,000 tons o f biosolids or manure per year . In addition many operations in the SCAQMD have found it to be economical to tran sport these materials to other jurisdicti ons for processing. An example of this is the Synagro South Kern Compost Manufacturing Facility, which is a newer fac ility located in the Valley and processes biosolid s transported from SCAQMD.

Because some mitigation measures are only cost-effective for la rger facilities, District staff developed the c oncept of Class One and Class Two mitigation measures. Class One mitigation measures are cost effective opt ions for all facilities, regardless of size . These measures are management practices found to be best practices for all composting operations.

Class Two mitigation measures a re the technology options and ac hieve reductions greater than Class One mitigatio n measures; however, they were determined to not be cost effective for faciliti es with throughputs of less than 100,000 wet tons per
year.

District Rule 4565 requires reduc tions from two additional cate gories (landfilling and land applying) when compared to S CAQMD Rule 1133.2. For the th ird category, composting, District staff deter mined it is not cost effective to require in-vessel (enclosed) composting.

B. No rules that apply to biosolids, animal manure, and/or poul try litter operations were located for th e air districts listed below

 Amador County Air Pollution Control District (ACAPCD)

 Bay Area Air Quality M anagement District (BAAQMD)

 Eastern Kern County Air Poll ution Control District (EKAPCD)

 El Dorado County Air Q uality Management District

 Imperial County Air Polluti on Control District (ICAPCD)

 Mojave Desert Air Quality Management District (MDAQMD)

 North Coast Unified Air Qualit y Management District (NCAQMD)

 Placer County Air Pollution Control District (PCAPCD)

 Sacramento Metropolitan Air Qua lity Management District (SMAQM D)

 San Diego County Air Pollution Control District (SDCAPCD)

 Ventura County Air Polluti on Control District (VCAPCD)

 Yolo-Solano Air Quality Management District (YSAQMD)San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-279 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard C. IDAPA 58.01.01 Sect ions 760-764: Rules fo r the Control of Am monia 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 St ate Department of Agricultu re to sell milk for human consumption.

This regulation only applies to large dairies and does not app ly to other agricultural facilities or facilities in which the primary activity is the p roduction of compost. Therefore, it was determined that this regulation is not releva nt to the current analysis since it does not specifically limit emissions from co mposting facilities.

IV. Conclusion

While BACM and MSM requirements do not apply to ammonia since i t is not a significant precursor to PM2.5 formation in the Valley, Distric t staff concludes that District Rule 4565 meets BACM and MS M requirements for ammonia emissions from biosolids, animal manure, and poul try litter operations. The D istrict evaluated the feasibility of additional ammoni a 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 e missions from the facilities we re entirely or primarily the direct result of the use of cat alytic emission controls to redu ce NOx emissions to acceptable levels as determined by regulatory agencies includin g, EPA, ARB, the District, and, in one case the Cali fornia Energy Commission (CE C). Because the Valley is primarily a rural NOx-limit ed area, NOx reductions are the m ost critical element of District’s plans to reach attainm ent with the federal ambient a ir quality standards for both PM2.5 and ozone. T herefore, controls that reduce NH3 whil e increasing NOx would increase the formation o f PM2.5 and ozone in the Valley a nd would be detrimental to the goals of reachi ng attainment with the federa l ambient air quality standards.

Facility Name: J.R. Simplot C ompany; District Facility #C-705 This facility produces fertilizers. The NH3 emissions from thi s facility are associated with the Nitric acid production plant at the facility. Althoug h ammonia is used in the production of nitric acid, the vas t majority of the ammonia int roduced is consumed in the production of the nitric acid or recovered. The ammonia emissi ons from the nitric acid are the result of the use of a non-selective catalytic reductio n (NSCR) system to reduce NOx emissions from the nitric acid plant. The tail gas from ni tric acid plants contains large amounts of NOx and this p lant uses NSCR to reduce NOx to comply with 40 CFR 60 Subpart G (Standards of Performanc e for Nitric Acid Plants) and federallyenforceable New and Modi fied Source Review (NSR) limits. The N SR permit for this facility includes conditions minim izing the allowable amount of NH3 slip with associatedSan Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-280 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard emissions testing. Because the NH3 emissions are the direct re sult of the use of NSCR, which is required to compl y with federal NSPS and NSR req uirements, and reducing the amount of NH3 would increase NOx emissions, this f acility 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 injecti on for Selective Non-Catalytic Reduction (SNCR) to control NOx from two biomass-fi red boilers at the facility. Us e of the SNCR to reduce NOx is required by the EPA-issued Prevention of Significant Det erioration (PSD) Permit PSD ATC SJ 90-01 and federally-enf orceable NSR conditions and a lso required to comply with 40 CFR 60 Subpart Db (Standards of Performance for IndustrialCommercial-Institutional Steam G enerating Units). The NSR perm its 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 in jection shall be incorporated within the boilers. Ammonia shall be inje cted continuously during all periods of operation at a rate which results in co mpliance with the NOx emission limits. ” Because a perfect reaction cannot be ac hieved, some excess NH3 must be injected in the boiler stacks to reduce NOx to acceptabl e levels and this excess unrea cted NH3 escapes the stack as slip. The facility incu rs a cost for all of the NH3 i njected into the boiler stacks, so there is an incentive to min imize NH3 slip to reduce costs a ssociated with compliance with the NOx limits . In addition, the NSR permits f or the biomass-fired boilers include conditions limit ing the allowa ble amount of NH3 slip.

The NH3 emissions from the bioma ss boilers are the direct resul t of the use of SNCR, which is required by NSR conditi ons and the EPA-issued PSD Perm it PSD ATC SJ 90- 01 and required to comply with t he requirements of Federal NSPS . The NSR permits for the biomass-fired boilers i nclude conditions limiting the a llowable amount of NH3 slip with associated emissions testi ng, and further reducing the amo unt of NH3 could potentially increase NOx emissi ons; therefore, this facility is considered to satisfy BACM and MSM for NH3.

Facility Name: Northern Califor nia 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 injecti on for Selective Catalytic Redu ction (SCR) to control NOx from two natural gas-fired turb ines at the facility. Use of th e SCR to reduce NOx is required by federally-enforceabl e NSR conditi ons and also requi red to comply with the federally-enforceable requirement s of District Rule 4703 (Stati onary Gas Turbines), which is included in the SIP. B ecause a perfect reaction canno t be achieved, some excess NH3 must be injected to r educe 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 ther e is an incentive to minimize NH3 slip to reduce costs associated with the compliance wi th the NOx limits. In additio n, the NSR permits for the natural gas-fired turbines inclu de conditions limiting the allo wable amount of NH3 slip.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-281 Appendix C: BACM and MSM for Stationary and Area Sources 2015 Plan for the 1997 PM2.5 Standard The NH3 emissions from the natural gas-fired turbines are the d irect result of the use SCR, which is required by NSR c onditions and required to comply with the federallyenforceable requirem ents of District Rule 4703. The NSR permit s for the natural gasfired turbines include condition s limiting the allowable amount of NH3 slip and associated emissions testing, and further reducing the amount o f NH3 could potentially increase NOx emissions; theref ore, this facility is considered to satisfy BACM and MSM for NH3.

Conclusion While BACM and MSM requirements do not apply to ammonia since i t is not a significant precursor to PM2.5 formation in the Valley, Distric t staff concludes that major sources of ammonia in the Valley satisfy BACM and MSM requireme nts for NH3. The District evaluated the feasibilit y of additional ammonia emissi ons reductions and did not identify any additional feasible measures.San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-282 Appendix C: BACM and MSM for Stationary and Area Sources 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 Polluti on Control District April 16, 2015

C-283 Appendix C: BACM and MSM for Stationary and Area Sources 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) 410-400-2058-0000San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-284 Appendix C: BACM and MSM for Stationary and Area Sources 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) 645-646-5400-0000San Joaquin Valley Unified Air Polluti on Control District April 16, 2015

C-285 Appendix C: BACM and MSM for Stationary and Area Sources 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/ASan Joaquin Valley Unified Air Polluti on 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 This page intentionally blank.