SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

Draft Staff Report

Proposed Rule 1153.1 – Emissions of Oxides of Nitrogen from Commercial

Food Ovens

September October 2014

Deputy Executive Officer

Planning, Rule Development, and Area Sources

Elaine Chang, DrPH

Assistant Deputy Executive Officer

Planning, Rule Development, and Area Sources

Philip M. Fine, Ph. D. 

Planning and Rules Manager

Planning, Rule Development, and Area Sources 

Joe Cassmassi

Author: Wayne Barcikowski – Air Quality Specialist

Reviewed by: Gary Quinn, P.E. – Program Supervisor

Mary Reichert – Senior Deputy District Counsel
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

GOVERNING BOARD

Chairman: WILLIAM A. BURKE, Ed.D.

Speaker of the Assembly Appointee

Vice Chairman: DENNIS YATES

Mayor, Chino

Cities of San Bernardino County

MEMBERS:

MICHAEL D. ANTONOVICH

Supervisor, Fifth District

County of Los Angeles

BEN BENOIT

Mayor Pro Tem, Wildomar

Cities of Riverside County

JOHN J. BENOIT

Supervisor, Fourth District

County of Riverside

JOE BUSCAINO

Councilmember, 15th District

City of Los Angeles Representative

MICHAEL A. CACCIOTTI

Councilmember, South Pasadena

Cities of Los Angeles County/Eastern Region

JOSIE GONZALES

Supervisor, Fifth District

County of San Bernardino

JOSEPH K. LYOU, Ph.D.

Governor’s Appointee

JUDITH MITCHELL

Mayor, Rolling Hills Estates

Cities of Los Angeles County/Western Region

SHAWN NELSON

Supervisor, Fourth District

County of Orange

DR. CLARK E. PARKER, SR.

Senate Rules Appointee

MIGUEL A. PULIDO

Mayor, Santa Ana

Cities of Orange County

EXECUTIVE OFFICER:

BARRY R. WALLERSTEIN, D.Env.
i

TABLE OF CONTENTS

TABLE OF CONTENTS i

CHAPTER 1: BACKGROUND

INTRODUCTION 1-1

REGULATORY HISTORY 1-1

TECHNOLOGY ASSESSMENT 1-3

AFFECTED INDUSTRIES 1-7

PUBLIC PROCESS 1-87

CHAPTER 2: SUMMARY OF PROPOSED RULE 1153.1

PROPOSED RULE REQUIREMENTS 2-1

CHAPTER 3: IMPACT ASSESSMENT

IMPACT ANALYSIS 3-1

COST EFFECTIVENESS 3-1

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) ANALYSIS 3-2

SOCIOECONOMIC ASSESSMENT 3-2

DRAFT FINDINGS 3-3

INCREMENTAL COST EFFECTIVENESS 3-4

COMPARATIVE ANALYSIS 3-4

REFERENCES R-1

RESPONSE TO COMMENTS i
CHAPTER 1: BACKGROUND

INTRODUCTION

REGULATORY HISTORY

EQUIPMENT AND PROCESS

TECHNOLOGY ASSESSMENT

AFFECTED INDUSTRIES

PUBLIC PROCESS
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INTRODUCTION

The purpose of Proposed Rule 1153.1 – Emissions of Oxides of Nitrogen from Commercial 

Food Ovens (PR 1153.1) is to limit emissions of nitrogen oxides (NOx) and carbon monoxide 

(CO) from the combustion of gaseous and liquid fuels in food ovens, dry roasters and 

smokehouses. This equipment is currently regulated by SCAQMD Rule 1147 – NOx Reductions 

from Miscellaneous Sources and Regulation XIII – New Source Review (NSR). Rule 1147 

limits emissions of NOx from gaseous and liquid fuel fired combustion equipment that are not 

specifically addressed in other SCAQMD Regulation XI – Source Specific Standards. However, 

because control technologies have not matured in a timely manner for commercial food ovens, it 

was decided to regulate these sources separately from the other Rule 1147 sources. In this way 

the commercial food ovens could be placed on a more suitable compliance schedule with 

achievable emission limitations.

The equipment addressed by Rule 1147 is used in a variety of industrial and commercial 

applications. Based on stakeholder input and further evaluation of the technical feasibility of 

retrofit technologies applicable to older units of this class of equipment, staff has proposed to 

move food ovens, including roasters and smokehouses, from Rule 1147 and place them in a 

proposed new rule with different emission limits and compliance dates.

REGULATORY HISTORY

The equipment proposed to be regulated by PR 1153.1 is currently regulated under SCAQMD 

Rule 1147. Rule 1147 is based on two control measures from the South Coast Air Quality 

Management District 2007 Air Quality Management Plan (AQMP): Control Measure MCS-01 –

Facility Modernization and Control Measure CMB-01 – NOx Reductions from Non-RECLAIM 

Ovens, Dryers, and Furnaces. Emission reductions from the equipment addressed by Rule 1147 

and Control Measure CMB-01 of the 2007 AQMP were proposed to be regulated in earlier 

AQMPs (e.g., Control Measure 97CMB-092 from the 1997 AQMP). 

Control measure MCS-01 was a new control measure developed for the 2007 AQMP that 

proposes companies upgrade their current technology to best available control technology 

(BACT) – the cleanest technology available. The facility modernization control measure 

proposes that equipment operators meet best available control technology (BACT) emission 

limits at the end of the equipment’s useful life. For equipment regulated by Rule 1147, 

modernization requires burner upgrades, replacement of burner systems or replacement of 

equipment when the equipment reaches 15 to 20 years of age. 

Equipment that is regulated by Rule 1147 and PR 1153.1 must also meet the requirements of 

SCAQMD Regulation XIII – New Source Review (NSR) and SCAQMD Regulation IV –

Prohibitions. Equipment subject to NSR must meet BACT requirements and offset emission 

increases. Regulation IV limits emissions of particulate matter, carbon monoxide and NOx from 

combustion sources. However, NOx emission limits required by BACT are significantly more 

stringent than the emission limits in Regulation IV. For example, Rule 474 – Fuel Burning 

equipment – Oxides of Nitrogen has emission limits that vary from 125 ppm to 400 ppm 
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(referenced to 3% oxygen) depending upon the fuel and heat input rating of the equipment. NOx 

emission limits under BACT for combustion equipment subject to Rule 1147 vary from 30 ppm 

to 60 ppm (referenced to 3% oxygen). Rule 407 in Regulation IV also has a CO limit of 2,000 

ppm.

Rule 1147 was adopted in 2008 to address NOx emissions from miscellaneous sources not

regulated by other SCAQMD rules within Regulation XI. Due to the numbers of pieces of 

equipment and varying source categories a top down assessment* was conducted to determine 

emissions limits based on thermal process characteristics and establish implementation dates. 

This process resulted in several categories of equipment that had similar burner profiles being 

grouped together with a common set of emissions limits for defined process temperatures. As a 

result of the common burner traits, food ovens, roasters and smokehouses were grouped in the 

same category as dehydrators, dryers, heater, kilns, crematories, incinerators, calciners, furnace 

and heated storage tanks. BACT for ovens and dryers had been 30 ppm NOx since 1998 and the 

Rule 1147 NOx limit of 30 ppm or 60 ppm if the process temperature is above 1,200 °F was 

consistent with applications for the other categories of equipment. . However, stakeholders 

were concerned that achieving an emission concentration of 30 ppm would be difficult in older 

food oven, roaster and smokehouse equipment using ribbon burners. Responding to stakeholder

concerns, Rule 1147 provided a later compliance date, until 2014, for food ovens. 

In June of 2012, staff began an evaluation of Rule 1147 implementation. The evaluation 

focused on the costs associated with and the availability of burner technologies for several 

categories of equipment covered by the rule. In May 2013 SCAQMD Rules 219 and 222 were 

amended to exempt specific small equipment from permit requirements including food ovens 

with low emissions of VOCs. One of the reasons cited for the rule amendment was the lack of 

cost effective -compatible low NOx burners available to meet the requirements of Rule 1147. 

The Rule 219 amendment moved some small ovens from the permit program into the Rule 222 

registration program which exempts them from Rule 1147 and PR 1153.1. 

Concurrently, manufacturers and a research institute had started projects to lower NOx emissions 

from these types of burners and were expected to achieve the Rule 1147 emission limits by 2014. 

Because these projects have not been completed and there are many older ovens heated with 

ribbon burners in the SCAQMD, staff proposed to move existing (in-use) food ovens, dry 

roasters and smokehouses from Rule 1147 and place them in a new rule specific to these 

equipment. Staff is recommending a new rule with higher NOx emission limits and delay of the 

emission limit compliance dates for in-use SCAQMD permitted food ovens. New food ovens 

will be subject to the BACT requirements of new source review. Staff is also proposing a carbon 

monoxide emission limit for units regulated by PR 1153.1.

 

*

In a top down assessment an overview of the system of equipment is formulated specifying but not detailing any 

first level of equipment subsystems. Each subsystem is then refined in yet greater detail. This type of assessment is 

typically used whenever there are thousands of equipment of differing processes such as equipment subject to 

SCAQMD Rule 1147.
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TECHNOLOGY ASSESSMENT

There are several options for reducing NOx emissions from combustion equipment subject to PR 

1153.1. Some ovens may be able to change their process so heat is generated by electricity. 

Many ovens use heat generated by electricity. Other ovens may be able to use heat generated by 

a boiler or thermal fluid heater. Heat transfer from steam or thermal fluids can be an efficient 

and cost effective way to heat a process. However, heat transfer from a boiler or thermal fluid 

heater requires the use of a heat exchange system to warm air and the process chamber that heats 

the product. For the majority of processes however, the preferred option to reduce NOx 

emissions will be tuning or replacing the burner system. The following sections describe the 

typical burner designs used in food ovens, roasters and smokehouses and the methods to reduce 

NOx.

Process Equipment

PR 1153.1 regulates ovens, roasters, and smokehouses used to prepare food and beverages for 

human consumption. There are two main types of ovens – batch and conveyor ovens. Roasters 

and smokehouses are typically batch operations where product is placed in the oven and removed 

when the process is complete. Conveyor ovens continuously take in food items, cook them and 

delivery the cooked product to an area where it can cool and then be packaged. Regardless of 

the type of food oven, they operate in three temperature ranges – less than 500 °F, 500 to 900 °F 

and greater than 900 °F.

Both batch and conveyor ovens may be manufactured with ribbon burners or one of two types of 

air heating burners. Air heating burners are used in convection ovens where the burner is not in 

close proximity to the product being cooked. One type of air heating burner is a line or duct

burner that is often made up of one foot sections that can be put together in a variety of shapes 

but in food ovens are typically put together end to end. The other type of air heating burner has a 

cylindrical housing projecting into the oven in which the burner flame is contained. Both of 

these types of burners may fire into a small space and air is moved through that space by blowers 

to be heated and moved on to the main chamber of the oven.

Figure 1 – Air Heating Burners
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Many oven burners have historically been long sections of pipe with rows of holes down the 

length of the pipe. Gas and a small amount of air is introduced into the pipe and that mixture 

exits through the holes in the pipe where it is lit with a pilot flame. Most of the air for 

combustion is secondary air which is inside the oven and mixes with the gas as it exits the holes 

in the pipe. 

Figure 2 – Pipe Burner

Ribbon burners are similar to this older style of pipe burner but they have an insert along the 

length of the pipe that allows better control of the flame. They are also designed to provide 

premixing of air with fuel for more efficient and better control of combustion. The newest types 

of ribbon burners are made in a variety of ways, but they have better mixing of air with the fuel 

inside the body of the burner and better control of the distribution of fuel gas in the burner which 

result in lower NOx emissions and better efficiency. The lower emissions are also achieved 

because the flame that is produced has lower peak flame temperature which results in less NOx. 

Some versions of newer ribbon burners also include water cooling which can also help lower 

emissions. Together with modern control systems, ribbon burners have lower emissions than 

pipe and older ribbon burners.

Figure 3 – Ribbon Burner Pipe and Flame Holding Surface

Food ovens can also use radiant systems to provide heat. One type of burner, made with ceramic 

or metal fiber flame holding surfaces, produces most of their heat as infrared radiation; they 

produce a red glow, and have very low NOx emissions. These are often called infrared burners 

and directly heat the product in the oven. Another type of unit has burners which heat the inside 

of tubes and the tubes then radiate heat to the process. This indirect heating system is called 

radiant tube heating.
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Figure 4 – Infrared Burners

Emission Reduction Technology

Low NOx burners in some applications can achieve less than 10 ppm NOx. There are many 

types of burners with emission in the range of 20 to 60 ppm NOx. The manufacturers of these 

burners use a variety of techniques to achieve lower emissions. The principal technique is better 

premixing of fuel and air before combustion takes place. This results in more efficient 

combustion of fuel and a more uniform flame temperature. A more uniform flame temperature 

results in fewer hot spots and reduced formation of NOx. 

Many premix burners require the aid of a blower to mix the fuel with air before combustion takes 

place (primary air). However, residential tank type water heaters, some small boilers and other 

equipment are now made with atmospheric premix burners that achieve NOx emissions in the 

range of 15 to 60 ppm. Atmospheric burners do not use a blower to mix fuel and air. The 

burners in these units combine premixing with specially designed burner heads that reduce flame 

temperature and NOx emissions by spreading the flame over a larger area. Premixing of fuel and 

air is accomplished using a jet of fuel gas exiting a specially designed nozzle. The velocity of 

the fuel leaving the nozzle draws air into a mixing zone and mixing is completed before the fuel 

and air mixture leaves the burner. 

A variety of burners are designed to spread flames over a larger area to reduce hot spots and 

lower NOx emissions. One type, radiant premix burners, has been available for several decades. 

Radiant premix burners are made with ceramic, sintered metal, metal screen or metal fiber heads 

that spread the flame over a larger surface. These burners can be run in either radiant or blue 

flame modes. When a burner runs in radiant mode, the flame surface is red instead of blue and it 

produces more radiant heat. These burners come in a variety of shapes including flat and 

cylindrical. 

To further reduce NOx emissions, some premix burners also use staged combustion. This 

technique produces two combustion zones with differing air-fuel mixtures. The burner produces 

a fuel rich zone to start combustion and stabilize the flame and a fuel lean zone to complete 

combustion and reduce the peak flame temperature. In combination, these two zones reduce the 

formation of NOx. This technique incorporates premixing and can be used in combination with 

other techniques.
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Burner Technology for Food Ovens

Rule 1147 requires food oven, roasters and smokehouse equipment to meet NOx emission limits 

in the range of 30 ppm to 60 ppm (referenced to 3% oxygen) depending upon the process and 

process temperature. The emissions limit is segregated by temperature equaling or exceeding 

1200 oF where the higher 60 ppm limit applies. The NOx emissions limit for all other oven 

operations at temperatures less than 1200oF is set at 30 ppm. The emission limits are based on 

SCAQMD and other air district’s determinations for BACT, availability of burners that can 

achieve these emission levels and recent emission limits decisions for SCAQMD permits. 

BACT determinations since 1998 have resulted in emission limits of 30 to 60 ppm for equipment 

ranging from low temperature ovens to very high temperature metal melting and heat treating 

furnaces. The BACT NOx limit since 1998 for most ovens and dryers, including food ovens, has 

been 30 ppm. Currently, the typical emission for low NOx burners applicable to equipment 

subject to Rule 1147 varies from less than 20 ppm to 60 ppm depending upon the burner, process 

temperature and nature of the process. 

Prior to 1998, NOx emissions limits for food ovens were typically established as an operating 

condition of the equipment permit. Many of the food ovens subject to Rule 1147 that are 

currently operating in the SCAQMD predate the 1998 timeframe when BACT was established 

for the equipment category. As a consequence, the Rule 1147 NOx emissions limits based on the 

post 1998 BACT analyses have presented the older and more process specific equipment with a 

significant compliance challenge. It is also important to note that the Rule 1147 1200 oF 

temperature threshold represented a consensus for several categories of equipment, not restricted

only to food ovens, roasters or smokehouses. A review of the sources for which PR 1153.1 

would apply indicated that a lower temperature threshold combined with a minor relaxation in 

the emissions limit from 30 ppm to 40 ppm for the cooler operating processes would better fit the 

operational characteristics of the impacted equipment.

Food ovens are designed with a specific type of burner so that the oven can produce specific 

food products. Many ovens use ribbon burners. Changing the type of burner and the operational 

characteristics of the oven and burners can result in changes in taste, texture, appearance and 

other qualities of the product. Individual manufacturers of food products set up their ovens 

differently in order to produce their unique product. This situation has resulted in manufacturers 

using ovens that are 20 to 50 years old. Because food producers require specific types of oven 

and burner combinations and most ovens are decades old, it is often technically infeasible for 

these older units to comply with the emission limits for Rule 1147 and produce an identical food 

product. 

PR 1153.1 has proposed NOx emission limits for existing in-use equipment of 40 to 60 ppm for 

processes below and above 500 °F. These proposed NOx emission limits are based on 

comments from equipment and burner manufacturers and local businesses. For older in-use food 

ovens fired with ribbon burners, local businesses and a major customer of ribbon burner 

manufacturers proposed NOx emission limits in the range of 30 to 35 ppm for process 

temperatures less than about 500 °F, 45 ppm for process temperatures between 500 °F and 700

°F and 60 ppm for temperatures above 700 °F. Ribbon burner manufacturers have suggested 

temperature based NOx emission limits for new food ovens as low as 30 ppm for lower process 
PR 1153.1 Draft Staff Report

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temperatures below about 500 °F and 60 ppm for higher process temperatures above about 900 

°F. For process temperatures between about 500 and 900 °F an emission limit of 45 ppm was 

suggested. The PR 1153.1 NOx emission limit for existing in-use equipment of 40 ppm for 

processes below 500 °F has been set to bridge the suggested range proposed by the stakeholders 

between 35 and 45 ppm. Similarly, providing a higher 60 ppm limit for the 500 °F to 1200 °F 

range of operation will provide flexibility for units operating for variable temperature 

requirements in cooking. New and relocated food ovens will be subject to SCAQMD new 

source review requirements and BACT guidelines.

The Gas Company and the Gas Technology Institute have a project to reduce emissions from 

ribbon burners. The design goal is to achieve NOx emissions of 30 ppm across a wide range of 

temperatures. The project is currently moving from testing of burners to installation of the 

modified burners into test ovens. The project is expected to be completed in 2016. Individual 

burner manufacturers also have developed new burners to achieve NOx emissions of 30 ppm 

across a wide range of process temperatures. 

To meet PR 1153.1 emission limits, some ovens with ribbon burners will only require tuning and 

regular maintenance. In other cases, compliance with the emission limits will require 

replacement with newer design lower emitting burners and/or upgrades to burner control 

systems. 

Air heating and infrared burners used in food ovens can easily achieve the emission limits of PR 

1153.1 and are the basis for the BACT NOx limit of 30 ppm for most ovens and dryers. These 

burners are readily available. These burners and some older design air heating burners will 

achieve the emission limits in PR 1153.1.

Radiant tube heating systems can also achieve the emission limits of PR 1153.1 but would

require replacement with larger diameter heating tubes in order to use burners that will meet the 

proposed NOx limits. Alternatively, these types of ovens have an option from the manufacturer 

to use a thermal fluid radiant tube heating system where the thermal fluid in the radiant tubes is 

heated by a small process heater subject to Rules 1146.1 or 1146.2. In addition, some of these 

radiant tube heating ovens have an option from the manufacturer to be heated with direct fired air 

heating burners. Both of these types of heating systems achieve NOx emissions levels of 15 to 

30 ppm based on existing in-use permitted units in the SCAQMD permit database. 

There are many suppliers of ribbon burners for food ovens and many manufactures of air heating 

and radiant burners used in food ovens and roasters. Currently suppliers of ribbon burners for 

food ovens have products that will achieve the proposed NOx limits for the equipment regulated 

by PR 1153.1. The suppliers of other types of burners which are typically found in food ovens 

also produce burners that meet the NOx limits in Rule 1147 and PR 1153.1.

AFFECTED INDUSTRIES

Proposed Rule 1153.1 affects manufacturers of ovens, roasters and smokehouses (NAICS 333) 

and manufacturers of food and beverage products (NAICS 311 and 312). Staff has identified 94 

facilities with 210 total units that are expected to be regulated by PR 1153.1. 135 of the units are 
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small with emissions less than or equal to one pound per day NOx. Approximately 70 % of the 

units are food ovens and the remainder is roasters and smokehouses.

PUBLIC PROCESS

The rule development effort for PR1153.1 is part of an ongoing process to evaluate low NOx

technologies for combustion equipment subject to SCAQMD Rule 1147. To date, SCAQMD 

staff has held three PR 1153.1 Task Force meetings to discuss burner technology, 

implementation issues, compliance schedules, emission limits, emission testing, and other topics 

with representatives from affected manufacturers, trade organizations, and other interested 

parties. PR 1153.1 Task Force meetings were held on October 23, 2013, January 9, 2014, and 

March 6, 2014 in combination with Rule 1147 Task Force meetings. In addition, a Public 

Workshop for PR 1153.1 was held on April 2, 2014 and PR 1153.1 was discussed at the 

Stationary Source Committee on March 21 and July 25, 2014.
CHAPTER 2: SUMMARY OF PROPOSED RULE 1153.1

PROPOSED AMENDED RULE REQUIREMENTS
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PROPOSED RULE REQUIREMENTS

AQMP Control Measure

Control measure CMB-01 – NOx Reductions from Non-RECLAIM Ovens, Dryers, and Furnaces 

and control measure MCS-01 – Facility Modernization provide a framework for Rule 1147 and 

PR 1153.1. Control measure MCS-01 proposes that equipment operators meet best available 

control technology (BACT) emission limits at the end of the equipment’s useful life. Control 

measure CMB-01 proposes emission NOx limits in the range of 20 ppm to 60 ppm (referenced to 

3% oxygen) for ovens, dryers, kilns, furnaces and other miscellaneous combustion equipment 

based on BACT limits. Unlike Rule 1147, PR 1153.1 is based on best available retrofit control 

technology (BARCT) and has less stringent NOx emission limits than Rule 1147. To meet PR 

1153.1 emission limits, equipment will require tuning and regular maintenance and in some 

cases, replacement with lower emitting burners or upgrades to burner control systems. 

Purpose and Applicability

The purpose of PR 1153.1 is to limit nitrogen oxide emissions from gaseous and liquid fuel fired 

combustion equipment as defined in this rule. This rule applies to in-use ovens, dryers, smokers 

and dry roasters with nitrogen oxide emissions from fuel combustion that require a District 

permit and are used to prepare food or beverages for human consumption. This rule does not 

apply to solid fuel-fired combustion equipment, fryers (including those used for oil roasting of 

nuts, seeds and other products), char broilers, or boilers, water heaters, thermal fluid heaters and 

process heaters subject to District Rules 1146, 1146.1, or 1146.2. 

Requirements

PR 1153.1 sets NOx emission limits of 40 to 60 ppm and a CO limit of 800 ppm. A CO 

emission limit will ensure that burners are operated consistent with manufacturers operating 

guidelinescompliance with NOx limits are not circumvented by extreme adjustments of burner 

fuel and combustion air during emissions testing. The temperature of the oven will vary 

depending upon the product baked. The NOx and CO levels will vary depending upon the heat 

output of the burner. The 800 ppm CO emission limit will also provide operators flexibility for 

operating equipment that process more than one type of product. 

Figure 5 – Proposed Rule 1153.1 Compliance Schedule
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The proposed rule also includes an emission testing requirement but delays compliance dates for 

at least 2 additional years beyond the dates for Rule 1147. PR 1153.1 phases in compliance 

based on a 20 year equipment life instead of the 15 years used in Rule 1147. Figure 5 compares 

the compliance schedules of Rule 1147 and PR 1153.1.

PR 1153.1 also provides three alternate compliance options and an option for manufacturers to 

certify emissions. One alternate compliance option allows facilities with multiple units to phase 

in compliance over three to five years. A second alternate compliance option allows facilities to 

delay the emission limit compliance date by 5 orup to 10 years beyond an equipment life of 20 

years if they recently replaced all of the burners in an oven. A mitigation fee option provides 

facilities a third option to delay compliance by up to three years by paying a mitigation fee which 

will be used to fund emission reduction projects. 

The following two tables indicate the NOx emission limits and compliance dates for PR 1153.1.

Table 1 – NOx Emission Limit for In-Use Units

NOx Emission Limit

PPM @ 3% O2, dry or Pound/mmBTU heat input

Process Temperature

≤ 500° F > 500° F

40 ppm or 0.042 lb/mmBTU 60 ppm or 0.073 lb/mmBTU

Table 2 – Compliance Schedule for In-Use Units

Equipment Category(ies)

Permit 

Application Shall 

be Submitted By

Unit Shall Be in 

Compliance On 

and After

Griddle ovens and oOvens used solely for making pita 

bread and manufactured prior to 1999 October 1, 2017 July 1, 2018

Griddle ovens manufactured prior to 1999 October 1, 2017 July 1, 2018

Ovens heated solely by indirect-fired radiant tubes 

manufactured prior to 2002 October 1, 2021 July 1, 2022

Other unit manufactured prior to 1992 October 1, 2015 July 1, 2016

Other unit manufactured from 1992 through 1998 October 1, 2018 July 1, 2019

Ovens heated solely by indirect-fired radiant tubes 

manufactured after 2001 and any other unit 

manufactured after 1998

October 1 of the year 

prior to the compliance 

date

July 1 of the year the 

unit is 20 years old

PR 1153.1 will provide a later compliance date for existing (in-use) units making pita bread or 

using small diameter indirect fired radiant tube heating. New ovens built with radiant tube 
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heating have options from the manufacturer to be built with a thermal fluid radiant tube heating 

system using a small process heater subject to SCAQMD Rules 1146.1 or 1146.2. In addition, 

some of these ovens also have an option from the manufacturer for direct fired heating systems 

using air heating burners which can meet the proposed NOx emission limits. Information from 

the SCAQMD permit system indicates that both types of heating systems achieve NOx emissions 

in the range of 15 to 30 ppm and low CO emissions in these types of applications. In addition, 

there are burners available for larger diameter radiant tubes which can also meet emission levels 

of less than 30 ppm NOx.

Exemptions

PR 1153.1 includes exemptions from the emission limits and testing for small and low-use units

with NOx emissions of one pound per day or less. In addition, the proposed rule includes a 

testing exemption for units that only have infrared burners which have significantly lower NOx 

emissions than the limits in PR 1153.1.
CHAPTER 3: IMPACT ASSESSMENT

IMPACT ANALYSIS

COST EFFECTIVENESS

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) ANALYSIS

SOCIOECONOMIC ASSESSMENT

INCREMENTAL COST-EFFECTIVENESS

COMPARATIVE ANALYSIS
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IMPACT ANALYSIS

PR 1153.1 impacts over 200 ovens, roasters and smokehouses at approximately 100 facilities. 

The proposed rule will exempt two thirds of the ovens from emission limit requirements (small 

and low use units). The owners and operators of these units are still subject to the combustion 

system maintenance and recordkeeping requirements that are carried over from Rule 1147. The 

maintenance requirements will help limit NOx, CO, VOC and PM emissions from these units. 

An estimated 75 units would still be required to meet PR 1153.1 emission limits and demonstrate 

compliance through source testing. It is expected that most of the larger ovens will be able to 

comply with the proposed emission limits without changing burner systems. 

Emissions of CO, VOC and PM are not expected to change compared with Rules 1147. 

However, NOx emission reductions for PR 1153.1 are delayed compared with Rule 1147 and 

will result in about 120 pounds per day of NOx emissions forgone by 2023. PR 1153.1 is not 

anticipated to have any additional significant environmental impacts.

COST EFFECTIVENESS

The proposed rule amendment provides less stringent emission limits compared with Rule 1147 

and provides regulatory relief. As such, a cost effectiveness analysis for PR 1153.1 is not 

applicable. However, staff has reviewed and reaffirmed the applicability of the cost and cost 

effectiveness estimates for Rule 1147. The cost for ovens to comply with PR 1153.1 emission 

limits will vary depending upon the type of burners used in the oven. 

A few ovens with air heating burners may need to replace burners in order to meet PR 1153.1 

emission limits. For those ovens the cost and cost effectiveness estimated for Rule 1147 is 

applicable. However, for higher temperature ovens and many other ovens, the cost will be less 

than for Rule 1147 because their current burners can meet the PR 1153.1 NOx emission limits of

40 and 60 ppm. The following table lists Rule 1147 average cost for air heating burners in the 

size range used by food ovens.

Burner Size 

(mmBtu/hr) 30 ppm 60 ppm

Less than 0.5 $6,800 $2,500

1 $3,500 $2,000

2.5 $5,500 $3.500

5 $5,000 $5,000

 Table 3 – Average Burner Cost for Rule 1147 Adoption

Rule 1147 cost effectiveness is based on replacement of burners and other related costs. The 

average cost effectiveness for burner replacement for Rule 1147 was up to $20,000 per ton. This 

is an average cost effectiveness based on the wide range of burners and equipment subject to 

Rule 1147 emission limits. However, staff does not anticipate that most of the ovens using air 

heating burners will need to replace their burners. Newer ovens in the SCAQMD with air 
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heating burners have permits limits of 30 ppm NOx (the current SCAQMD NOx BACT limit for 

ovens and dryers). 

Food ovens using ribbon burners require regular replacement of burners on a frequency that 

varies from every year to every 10 years depending upon use and type of burner. The cost 

effectiveness of installing new burners with lower NOx emissions is the price difference between 

a new type of burner and the older style burners. The typical cost of individual ribbon burners 

for ovens cooking cookies, crackers and bread is in the range of $250 to $800. If ribbon burners 

are replaced with infrared/radiant pipe burners designed as a direct replacement for ribbon 

burners, the cost per burner would be $315 to $1000. The cost difference between ribbon 

burners and the infrared burners for an oven rated at 2 million Btu per your would be in the range 

of $12,000 to $17,000. With a NOx emission reduction of 4 tons or more over 20 years, the 

average cost effectiveness is around $3,000 to $4,000 per ton NOx reduced.

In some cases an owner may choose to use a new updated control system with ribbon burners in 

order to meet the emission limit. Depending upon the size of the oven and number of burners, a 

modern burner control system can cost $25,000 to $75,000 dollars. However, with an emission 

reduction of at least 4 tons of NOx over 20 years for a conveyor oven and an average cost of 

$50,000 for a new control system on a large oven, the average cost effectiveness of the control 

system is about $12,500/ton NOx reduced. This control systems cost and cost difference is in the 

range for other Rule 1147 equipment.

CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) ANALYSIS

Pursuant to California Environmental Quality Act (CEQA) Guidelines § 15252 and SCAQMD 

Rule 110, the SCAQMD has prepared an Environmental Assessment (EA) for proposed Rule 

1153.1. The Draft EA was released for a 45-day public review and comment period from July 

29, 2014 to September 16, 2014. No comment letters were received from the public regarding 

the Draft EA. 

The quantity of peak daily NOx emission reductions foregone exceeds the NOx significance 

threshold for operation of 55 pounds per day. Thus, proposed Rule 1153.1 will result in adverse 

significant operational air quality impacts. Proposed Rule 1153.1 also includes options for 

alternate compliance plans, equipment certification and a mitigation fee option that currently 

exists in Rule 1147. In Rule 1147, all mitigation fees are used to reduce NOx emissions through 

the SCAQMD’s leaf blower exchange program. The fees collected as a result of the 

implementation of proposed Rule 1153.1 from the affected facilities electing to use the 

mitigation fee option will be used in the same manner as fees collected for Rule 1147. By 

funding this program, emission reductions will be generated that provide a regional air quality 

and corresponding GHG benefit to reduce the impact from the potential delay in emission 

reductions from those facilities choosing to delay compliance. It is possible that the use of these 

fees will fully offset the adverse air quality impact, but this cannot be foreseen at this time. No 

further feasible mitigation measures are identified at this time that would reduce or eliminate the 

expected foregone emission reductions. Consequently, the operational air quality emissions 

impacts from the proposed project cannot be determined to be mitigated to less than significant. 

No other environmental topic area was determined to have a significant adverse impact as a 

result of the proposed project.
PR 1153.1 Draft Staff Report

3 - 3 SeptemberOctober 2014

Pursuant to CEQA Guidelines §15091, Findings have been prepared for each of the significant 

environmental effects accompanied by a brief explanation of the rationale for each finding. In 

addition, a Statement of Overriding Considerations has been prepared in accordance with CEQA 

Guidelines §15093 that discusses the benefits of the proposed project against unavoidable 

environmental risk when determining whether to approve the project. If the benefits outweigh 

the unavoidable adverse environmental effects, the adverse environmental effects may be 

considered acceptable. 

Since the release of the Draft EA, minor modifications have been made to the document. 

However, none of the modifications alter any conclusions reached in the Draft EA, nor provide 

new information of substantial importance relative to the draft document. As a result, these 

minor revisions do not require recirculation of the Draft EA pursuant to CEQA Guidelines § 

15073.5. Therefore, the Draft EA is now a Final EA and is included as an attachment to this 

Board package.

Pursuant to the California Environmental Quality Act (CEQA) and SCAQMD’s Certified 

Regulatory Program (Rule 110), the SCAQMD has prepared a Draft Environmental Assessment 

(EA) for Proposed Rule 1153.1. The Draft EA was released for a 45-day public review and 

comment period on July 29 through September 16, 2014. The Draft EA concluded that 

significant environmental impacts in the topic area of air quality would result from implementing 

the proposed project. The proposed project may have statewide, regional or area-wide 

significance; therefore, a CEQA scoping meeting was required (pursuant to Public Resources 

Code §21083.9(a)(2)). The public workshop conducted on April 2, 2014 also served as a CEQA 

scoping meeting for the proposed actions. Upon completion of the public review and comment 

period for the Draft EA, responses to comments received relative to the Draft EA will be 

prepared and incorporated into the Final EA.

SOCIOECONOMIC ASSESSMENT

Based on stakeholder input and evaluation of the technical feasibility of technologies applicable 

to older food ovens, staff has proposed to move existing in-use food ovens, including roasters 

and smokehouses, from Rule 1147 and place them in a proposed new rule with less stringent 

emission limits and later compliance dates. 

As such, PR 1153.1 is expected to impose lower costs than Rule 1147 on owner/operators of 

food ovens, roasters and smokehouse ovens. The reduced equipment replacement cost (savings) 

for small and low use ovens exempt from the PR 1153.1 emission limits will be on the order of 

$2,500 to $7,500 per burner. The proposed rules’ maintenance, recordkeeping and testing 

requirements, which apply to all food ovens, are the same as in Rule 1147 and will result in the 

same cost. Similar to Rule 1147, PR 1153.1 has a testing requirement. Testing cost will vary 

from $2,000 to $5,000 depending upon the type of equipment. Most of the food ovens are small 

or low use, they will not be required to do emissions testing, and will therefore see this cost 

savings. PR 1153.1 also has later compliance dates compared with Rule 1147 which delays the 

costs from equipment replacement and testing for larger units. 

Operators of large ovens with ribbon burners may choose to replace older design ribbon burners 

with new design burners or upgrade to a new control systems. As discussed in the previous 

section on cost effectiveness in this staff report, these costs are similar to the costs estimated for 

Rule 1147. The cost difference for lower emission burners for a 2 million Btu per hour oven is 
PR 1153.1 Draft Staff Report

3 - 4 SeptemberOctober 2014

estimated to be less than $20,000 and the cost of a new control system averages about $50,000. 

Which option an owner/operator chooses will depend on the variety of products made in the 

oven and other operational factors.

DRAFT FINDINGS UNDER CALIFORNIA HEALTH & SAFETY CODE 

SECTION 40727

California Health and Safety Code Section 40727 requires that prior to adopting, amending or 

repealing a rule or regulation, the SCAQMD Governing Board shall make findings of necessity, 

authority, clarity, consistency, non-duplication, and reference based on relevant information 

presented at the public hearing and in the staff report. In order to determine compliance with 

Sections 40727, 40727.2 require a written analysis comparing the proposed amended rule with 

existing regulations.

The following provides the draft findings.

Necessity: A need exists to adopt PR 1153.1 to address technical infeasibility and the need for 

additional time to retrofit food ovens, roasters and smokehouses to meet the new less stringent 

proposed NOx emission limits. 

Authority: The SCAQMD obtains its authority to adopt, amend, or repeal rules and regulations 

from California Health and Safety Code Sections 39002, 40000, 40001, 40440, 40440.1, 40702, 

40725 through 40728, 41508, and 41700.

Clarity: PR 1153.1 has been written or displayed so that its meaning can be easily understood 

by the persons affected by the rule.

Consistency: PR 1153.1 is in harmony with, and not in conflict with or contradictory to, 

existing federal or state statutes, court decisions or federal regulations.

Non-Duplication: PR 1153.1 does not impose the same requirement as any existing state or 

federal regulation, and is necessary and proper to execute the powers and duties granted to, and 

imposed upon the SCAQMD. 

Reference: In amending this rule, the following statues which the SCAQMD hereby 

implements, interprets or makes specific are referenced: Health and Safety Code sections 39002, 

40001, 40702, 40440(a), and 40725 through 40728.5.

INCREMENTAL COST-EFFECTIVENESS

Health and Safety Code Section 40920.6 requires an incremental cost-effectiveness analysis for 

Best Available Retrofit Control Technology (BARCT) rules or emission reduction strategies 

when there is more than one control option that would achieve the emission reduction objective 

of the proposed amendments, relative to ozone, CO, SOx, NOx, and their precursors. 

The proposal to adopt PR 1153.1 does not require additional emission controls or emission 

reduction strategies beyond those required under SCAQMD Rule 1147. However, PR 1153.1 

does require a less stringent emission limit and later compliance dates compared with Rule 1147 
PR 1153.1 Draft Staff Report

3 - 5 SeptemberOctober 2014

which currently applies to this equipment. Therefore, the incremental cost-effectiveness analysis 

requirement does not apply.

The only other options for reducing NOx emission from equipment affected by PR 1153.1 is 

replacement of burners with other sources of heat. Some ovens do use electricity to provide heat 

and other units provide heat through a heat exchanger with heated water of other fluid from a 

small boiler or process heater. However, this equipment is either not regulated for NOx 

emissions by the SCAQMD (electric ovens) or is regulated by other SCAQMD rules (Rules 

1146, 1146.1 and 1146.2). 

Staff has evaluated the incremental cost effectiveness as compared to a less stringent emission 

limit. The same technology used to achieve the proposed NOx limit can also be used to achieve 

less stringent limits. For these less stringent limits the cost of the technology is the same but 

because emission reductions are less, the cost effectiveness increases. In other words, a less 

stringent option is less cost-effective.

COMPARATIVE ANALYSIS

Under Health and Safety Code Section 40727.2, the SCAQMD is required to perform a 

comparative written analysis when adopting, amending, or repealing a rule or regulation. The 

comparative analysis is relative to existing federal requirements, existing or proposed SCAQMD

rules and air pollution control requirements and guidelines which are applicable to industrial, 

institutional, and commercial water heaters, boilers, steam generators, and process heaters.

The SCAQMD staff is not aware of any state or federal requirements regulating air pollution that 

are applicable to PR 1153.1 type units. PR 1153.1 does not make an existing limit or standard 

more stringent, or impose more stringent monitoring, reporting or recordkeeping requirements. 

However, PR 1153.1 does include a less stringent emission limit and later compliance dates 

compared with Rule 1147 which currently applies to this equipment. Since PR 1153.1 is only 

applicable to existing in-use ovens, roasters and smokehouses it does not conflict with Best 

Available Control Technology requirements under the SCAQMD’s New Source Review 

Program.
REFERENCES
PAR 1111 Staff Report

R - 1 May 22, 2014

REFERENCES

EPA, 2002. EPA Air Pollution Control Cost Manual, Sixth Edition (EPA-452-02-001), United 

Stated Environmental Protection Agency, January 2002

SCAQMD, 2008. Staff Report: Proposed Rule 1147 - NOx Reductions from Miscellaneous 

Sources. South Coast Air Quality Management District, December 2008.

SCAQMD, 2007. Air Quality Management Plan, Final 2007 AQMP Appendix IV-A, District’s 

Stationary and Mobile Source Control Measures, South Coast Air Quality Management District, 

June 2007.

SCAQMD, 1996. 1997 Air Quality Management Plan, Appendix IV-A, Stationary and Mobile 

Source Control Measures, South Coast Air Quality Management District, November 1996.
RESPONSE TO COMMENTS
PR 1153.1 Draft Staff Report

i SeptemberOctober 2014

RESPONSE TO COMMENTS

Comment: Because Rule 1147 is an approved rule in the state implementation plan (SIP), 

forgone emissions reductions associated with PR1153.1 could interfere with demonstration of 

attainment or reasonable further progress under section 110(l) of the federal Clean Air Act 

(CAA) or other provisions of the CAA. In addition, PR 1153.1 may undermine the rules 

enforceability and preclude reliance on it for SIP emission reduction credit in accordance with 

USEPA policy on economic incentive programs (EIPs) and other nontraditional emission 

reduction measures. USEPA approval of PR 1153.1 depends upon demonstration that its 

provisions, including fee provisions, result in emission reductions that are surplus, quantifiable, 

enforceable, permanent and consistent with all applicable CAA requirements.

Response: The SCAQMD 2007 and 2012 Air Quality Management Plan SIPs set aside 

sufficient NOx emissions reductions to offset potential emission reduction shortfalls resulting

from delays in implementing technology forcing rules. Therefore, the potential SIP reductions 

foregone/delayed are addressed- via the SIP set aside, not incentive programs.

Comment: Ovens using indirect fired radiant tube heating with small diameter tubes will not be 

able to meet the proposed NOx and CO emission limits. 

Response: Staff has revised PR 1153.1 to provide existing (in-use) units using indirect fired 

radiant tube heating additional time to meet the rule emission limits and testing requirement. 

Until the compliance date, these units must comply with the other requirements of PR 1153.1 

including combustion system maintenance and recordkeeping. These ovens have options from 

the manufacturer to convert to a thermal fluid radiant tube heating system, and some ovens also 

have an option from the manufacturer for direct fired heating systems using air heating burners. 

Staff recognizes that units with small diameter indirect fired heating tubes do not currently have 

burners available that meet the proposed emission limits. However, units can be built with 

thermal fluid heating using a small process heater subject to SCAQMD Rules 1146.1 or 1146.2 

or with direct fired air heating burners which can meet the proposed emission limits. 

Information from the SCAQMD permit system indicates that both of these types of heating 

systems achieve NOx emissions in the range of 15 to 30 ppm and low CO emissions in these 

types of applications. In addition, there are burners available for larger diameter radiant tubes 

which can meet emission levels of less than 30 ppm NOx.

Comment: Ovens with recently installed burners should have more time to comply with the 

emission limits regardless of the equipment age. This option is available in Rule 1147.

Response: Staff has revised PR 1153.1 to allow additional time for units that recently changed 

burners. Units with recent changes of burners will have 5 or 10 years from the date of the 

modification to comply with the emission limits. The 5 or 10 year time frame is based on 

industry provided information on the maximum lifetime of ribbon burners in small and large 

baking operations and is based upon the hours of operation of the oven.

Comment: Why is a carbon monoxide (CO) limit included in PR 1153.1 and what is the basis

for the limit?

Response: A CO limit is included in the proposed rule to assure that the burner is tuned and 

operated in a manner consistent with manufacturer’s recommendations. The CO limit will help 
PR 1153.1 Draft Staff Report

ii SeptemberOctober 2014

prevent circumvention of the NOx limit by extreme adjustments of burner fuel and combustion 

air during emission testing. Staff has found that some equipment subject to Rule 1147 have 

burners that were never designed to meet rule emission limits, but they have been tuned to meet 

the NOx limit during the test with very high CO levels. The CO emission level is set at a 

capping level to allow owner/operators flexibility during normal operations and at the same time 

assure that burners are tuned and operated as they were designed.

Comment: Are the PR 1153.1 testing and compliance requirements different than those for 

Rule 1147 equipment with more than one section and with more than one section connected to 

one exhaust manifold? 

Response: The test methods (sampling and analysis) are the same for both rules. The protocol 

for sampling for Rule 1147 and PR 1153.1 compliance demonstrations must be discussed 

between the owner/operator and SCAQMD staff and ultimately approved by SCAQMD staff. 

The owner/operator and their testing contractor should address this, and other issues that affect 

sampling, with SCAQMD staff to reach a consensus on how to sample for the compliance 

demonstration. Compliance demonstration for units with individual sections and with their own 

exhaust stacks are subject to long established Engineering and Compliance Division policy 

regarding compliance demonstration. This policy requires that all sections of a piece of 

equipment with individual manifolds must comply with federal and SCAQMD regulatory 

requirements (e.g., federal new source performance standards, BACT emission limits, and 

SCAQMD Rules).

Comment: Is it possible to get refunds on permit and alternate compliance applications for Rule 

1147 if they are no longer necessary? Will there be a cost to change a permit condition 

applicable to Rule 1147?

Response: The request is being addressed by SCAQMD Engineering and Compliance Division. 

The SCAQMD Small Business Assistance staff can also be contacted for business assistance at 

(800) 388-2121. 

Comment: Does this proposed rule affect equipment at RECLAIM facilities?

Response: Equipment at RECLAIM facilities is exempt from PR1153.1.