### 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

Elain e Chang , Dr PH

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 Qualit y Specialist

Reviewed by: Gary Quinn, P.E.

– Program Supervisor Mary Reichert

– Senior Deputy District CounselSOUTH COAST AIR QUAL ITY MANAGEMENT DISTR ICT

GOVERNING BOARD

Chairman: WILLIAM A. BURKE, Ed.D. Speaker of the Assembly Appointee

Vice Cha irman: 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

Co unty 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 Bernard ino

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

- 8 7

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 ENVIRONME NTAL QUALITY ACT (CE QA) ANALYSIS 3

- 2

SOCIOECONOMIC ASSESSMENT 3

- 2

DRAFT FINDINGS 3

- 3

IN CREMENTAL COST EFFECTIVENESS 3

- 4

CO MPARATIVE ANALYSIS 3

- 4

REFERENCES R

- 1

RESPONSE TO COMMENTS i

### CHAPTER 1: BACKGROUND

INTRODUCTION

REGULATORY HISTORY

EQUIPMENT AND PROCESS

TECHNOLOGY ASSESSMEN T

AFFECTED INDUSTRIES

PUBLIC PROCESSPR 1153.1 Draft Staff Report

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- 1 September October 2014 

### 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 gas eous and liq uid 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 regul ate 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, s taff has proposed to move food ovens, including roaster s 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 i s based on two control measures from the South Coast Air Quality Management District 2007 Air Quality Management Plan (AQMP): Control Measure MCS

- 01

– F acility Modernization and Control Measure CMB

- 01

– NOx Reductions from Non

- RECLAIM Ovens, Dryers, a nd F urnaces . Emission reductions from the equipment addressed by Rule 1147

and Control M easure CMB

- 01 of the 2007 AQMP were proposed to be regulated in earlier AQMPs (e.g., Control M easure 97CMB

- 092 from the 1997 AQMP).

Control measure MCS

- 01 was a new con trol measure developed for the 2007 AQMP that

proposes companies upgrade their current technology to best available control technology (BACT)

– the cleanest technology available. The f acility 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 require s burner upgrades

, replacement of burner systems or replacement of equipment when the equi pment 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 limit s in Regulation IV. For example, Rule 474

– Fuel Burning equipment

– Oxides of Nitrogen has emission limits that vary from 125 ppm to 400 ppmP R 1153.1 Draft Staff Report

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- 2 September October 2014 (referenced to 3% oxygen) depending upon the fuel and heat input rating of the equipment. NOx

emission limits un der BACT for co mbustion equipment subject to Rule 1147 vary from 30 ppm

to 6 0 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 conducte d to determine

emissions limits based on thermal process characteristics and establish implem entation 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 define d process temperatures. As a

result of the common burner traits, food oven s
, roasters and smokehouses were grouped in the same category as dehydrators, dryers, heater, kilns, crematories, incinerators, calciner s
, furnace and heated storage t ank s. 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 olde r food oven

, roas ter and smokehouse equipment using ribbon burners. Responding to stakeholder

concern s
, Rule 1147 provide d a later compliance date, until 2014, for food ovens.

In June of 2012, staff began an evaluation of Rule 1147 implementation. Th e 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 requir ements 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 ov ens 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 exp ected 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 smokehous es from Rule 1147 and place them in a new rule specific to these equipment. S taff is recommending a new rule with higher NOx emission limits and delay of the emission limit compli ance dates for in

- use SCAQMD permitted food ovens. New food ovens

will be s ubject 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. Eac h subsystem is then refined in ye t 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.P R 1153.1 Draft Staff Report

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- 3 September October 2014 

### TECHNOLOGY ASSESSMEN T

There are several options for reducing NOx emissions from combustion equipment subjec t 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 stea m 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

NO x.



### 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 whe re 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, t hey 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 convectio n 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 typica lly 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 Burner sP R 1153.1 Draft Staff Report

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- 4 September October 2014 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 intro duced 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 al so 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. O ne type of burner, made with ceramic or metal fiber flame holding surfaces

, produce s 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.P R 1153.1 Draft Staff Report

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- 5 September October 2014 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 2 0 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 tha t 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 spread ing 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 mad e 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 an d 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 techniq ue incorporates premixing and can be used in combination with other techniques.P R 1153.1 Draft Staff Report

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- 6 September October 2014 

### Burner Technology for Food Ovens

Rule 1147 requires food oven, roasters and smo ke house 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 o F where the higher 60 ppm limit applies. The NOx emissions limit for all other oven operations at temperatures les s than 1200 o F 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 determ inations 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 foo d 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, N Ox emissions limits for food ovens were typically established as an operatin g 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

fo r the equipment category. As a consequence, the Rule 1147 NOx emissions limits based on the post 1998 BACT analyses have presented the older and mor e process specific equipment with a sig nificant compliance challenge. It is also important to note that the Rule 1147 1200 o F 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 t hreshold 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 produ ct. 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

p rocesses 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 tempera tures above 700 °F

. Ribbon b urner manufacturers have suggested temperature based NOx em ission limits for new food ovens as low as 30 ppm for lower processP R 1153.1 Draft Staff Report

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- 7 September October 2014 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 sta keholders 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

. N ew and relocated food ovens will be s ubject 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

tem peratures. 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 e missions 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 replace ment 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 requir e 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 emissio ns 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 bur ners 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 11 53.1 affects manufacturers of ovens, roasters and smokehouses (NAICS 333 )

and manufacturers of food and beverage products (NAICS 3 11 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 areP R 1153.1 Draft Staff Report

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- 8 September October 2014 small with emissions less than or equal to one pound per day NOx. Approximately 70 % of the

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



### PUBLIC PROCESS

The rule development effort for P R1153.1 is part of an ongoing process to evaluate low NOx technologies f

or combustion equipment subject to SCAQMD Rule 1147 . To date, SC AQMD

staff has held thr ee PR 1153.1 Ta sk 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

part ies. PR 1153.1 Task F orce 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 REQUIREMENTSPR 1153.1 Draft Staff Report

2

- 1 September October 2014 

### PROPOSED RULE REQUIR EMENTS

AQMP Control Measure

Control measure CMB

- 01

– NOx Reductions from Non

- REC LAIM 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 mis cellaneous 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 limit s than Rule 1147 . To meet PR 1153.1 emission limits, equipment will require tuning and regular maintenance and in some

cas es, 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. T his 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

- fi red 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.



### Requirement s

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 guidelines compliance with NOx limits are not circumvented by extreme adjustme nts 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 SchedulePR 1153.1 Draft Staff Report

2

- 2 September October 2014 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 1 153.1.

PR 1153.1 also provides three a lternate 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 altern ate compliance option allows facilities to delay the emission limit compliance date by 5 or up to 10 years beyond an equipment life of 20

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

facilities a third opt ion 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

– NO

x Emission Limit f or In

- Use Units

NOx Emission Limit

PPM @ 3% O 2 , dry or Pound/mm BTU heat input

Process Temperature

≤ 500 ° F > 5 00 ° F

40 ppm or 0.042 lb/mm BTU 60 ppm or 0.073 lb/mm BTU

Table 2

– Compliance Schedule for In

- Use Units

Equipment Category(ies) Permit

Applic ation Shall

be Submitted By Unit Shall Be in

Compliance On

and After

Griddle ovens and o O vens 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, 2 018

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, 201 9

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 t he year the

unit is 20 years old

PR 1153.1 will provide a later compli ance date for existing (in

- use) units making pita bread or using small diameter indirect fired radiant tube heating. New ovens built with radiant tubePR 1153.1 Draft Staff Report

2

- 3 September October 2014 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 rad iant tubes which can also meet emission levels of less than 30 ppm NOx.



### Exemptions

PR 1153.1 includes e xemption s from the emission limit s and testing for small and low

- use units with NOx emissions of one pound per day or less. In addition, the proposed ru le includes a

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

emission s than the limits in PR 1153.1.

### CHAPTER 3: IMPACT ASSESSMENT

IMPACT ANALYSIS

COST EFFECTIVENESS

CALIFORNIA ENVIRONME NTAL QUA LITY ACT (CEQA) ANAL YSIS

SOCIOECONOMIC ASSESS MENT

INCREMENTAL COST

- EFFECTIVENESS

COMPARATIVE ANALYSISPR 1153.1 Draft Staff Report

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- 1 September October 2014 

### IMPACT ANALYSIS

PR 1153.1 impacts over 200 ovens, roasters and smokehouses at approximately 100 facilities. The proposed rule will exempt two thirds o f 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 re quirements 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 wil l 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 an d 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 comp ared with Rule 1147 and provides regulatory relief. As such, a cost effectiveness analysis for PR 1153.1 is not applicable. However, s taff 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 o vens 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 burner s can meet the PR 1153.1 NOx emission limit s 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 effectiven ess 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. N ewer ovens in the SCAQMD with airPR 1153.1 Draft Staff Report

3

- 2 September October 2014 heating burners have permits limits of 30 ppm NOx (the current SCAQMD NOx BACT limit for ovens and dryers).

F ood ovens using ribbon burners require regular replacement of burners on a frequency that varies from every year to every 10 years depending upon use an d type of burner . The cost

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

a new type of burner and the older style burner s

. The typical cost of individual ribbon burners for ovens cooking cookies, cracker s 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.

I n 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. H owever, 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 ENVIRONME NTAL QUALITY ACT (CE QA) ANALYSIS

Pursuant to California Environmental Quality Act (CEQA) Guidelines § 15252 and SCAQMD Rule 110, the SCAQMD ha s 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 E A.

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 p rogram. 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

f ees 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, th e 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 September October 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 prepar ed 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 in formation 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 att achment 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 relea sed 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 proj ect 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 pro posed 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 ASSESS MENT

Based on stakeholder input and evaluation of the technical feasibility of technologies applicable to older food ovens, s taff 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

emis sion limits and later compliance dates.

As such, PR 1153.1 is expected to impose lower cost s 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 ex empt 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 c ost

. 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 t herefore 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 l arge ovens with ribbon burners may choose to replace older d esign 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 isPR 1153.1 Draft Staff Report

3

- 4 September October 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 product s 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 find ings 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 analy sis 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 a nd the need for

additi onal time to retrofit food ovens, roaster s 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, 4044 0.1, 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

- effective ness analysis for Best Available Retrofit Control Technology (BARCT) rules or emission reduction strategies

when there i s more than one control option that would achieve the emission reduction objective of the proposed amendments, relative to ozone, CO, SOx, NOx , and their pr ecursors.

The proposal to adopt PR 1153.1 does not require additional emission controls or emissi on 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 1147PR 1153.1 Draft Staff Report

3

- 5 September October 2014 which currently applies to this equipment. Therefore, the incremental cost

- effective ness analysis requirement does not apply.

The only other option s for reducing NOx emission from equipment affected by PR 1153.1 is replacement of burner s with other sources of heat . Some ovens do use electricity to provide heat

and other u nit s 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 (Rule s 1146, 1146.1 and 1146.2)

.

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

limit

. The same technology used to achi eve the proposed NOx limit can also be used to achieve less stringent limit s . 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 Sec tion 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 pol lution 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 p ollution 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 emi ssion 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 req uirements under the SCAQMD ’s New Source Review Program.

### REFERENCESP A R 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 Repo r t: Proposed Rule 1147

- NOx Reductions from Miscellaneous

Sources . South Coast Air Q uality Management District, Dec ember 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 COMMENTSPR 1153.1 Draft Staff Report

i September October 2014 

### RESPONSE TO COMMENTS

Comment: Because Rule 1147 is an approved rule in the state implementation plan (SIP), forgone emissio ns reductions associated with PR 1153.1 could interfere with demonstration of

attainment or reasonable f urther progress under section 110(l) of the federal Clean Air Act (CAA) or other provisi ons of the CAA. In addition, P R 1153.1 may undermine the rules enforceability and preclude reliance on it for SIP emission reduction credit in accordance with USEPA po licy on economic incentive programs (EIPs) and other nontraditional emission

reduction measures. USEPA approval of P R 1153.1 depends upon demonstration that its provisions, including fee provisions, result in emission reductions that are surplus, quantifi able, 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 tub es 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 requirem ent. Until the compliance date, these units must comply with the other requirements of PR 1153.1 including combustion system maintenance and recordkeeping

. T hese 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 sy stems using air heating burners.

S taff 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 dire ct fired air heating burners which can meet the proposed emission limits

. Information from the SCAQMD permit system indicates that b oth 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 tu bes 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 h as revised PR 1153.1 to allow additional time for units that recently changed

burners. Units wit h 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 helpPR 1153.1 Draft Staff Report

ii September October 2014 prevent circumvention of the NOx limit by extreme adj ustments 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 P R 1153.1 tes ting 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. T he 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/ ope rator 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 Engi neering 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 perfo rmance 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 e quipment at RECLAIM facilities?

Response: E quipment at RECLAIM facilities is exempt from PR1153.1

.