D-0 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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2012 PM2.5 Plan

SJVUAPCD

Appendix D 

Stationary and Area 

Source Control 

Strategy Evaluation 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

Appendix D: Stationary and Area Source Control Strategy Evaluation 

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San Joaquin Valley Unified Air Pollution Control District December 20, 2012

Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Table of Contents 

D.1 Combustion Devices ......................................................................................... D-7

D.1.1 Rule 4203 Particulate Matter Emissions from the Incineration of 

Combustible Refuse ............................................................................... D-10

D.1.2 Rule 4307 Boilers, Steam Generators and Process Heaters–2.0 MMBtu/hr 

to 5.0 MMBtu/hr ...................................................................................... D-13

D.1.3 Rule 4308 Boilers, Steam Generators and Process Heaters–0.075 

MMBtu/hr to less than 2.0 MMBtu/hr ...................................................... D-19

D.1.4 Rule 4309 Dryers, Dehydrators, and Ovens ........................................... D-26

D.1.5 Rule 4320 Advanced Emission Reduction Options for Boilers, Steam 

Generators, and Process Heaters Greater than 5.0 MMBtu/hr ............... D-32

D.1.6 Rule 4352 Solid Fuel Fired Boilers, Steam Generators, and Process 

Heaters ................................................................................................... D-39

D.1.7 Rule 4702 Internal Combustion Engines ................................................ D-47

D.1.8 Rule 4703 Stationary Gas Turbines ........................................................ D-54

D.2 Industrial Processes ....................................................................................... D-65

D.2.1 Rule 4104 Reduction of Animal Matter ................................................... D-67

D.2.2 Rule 4311 Flares .................................................................................... D-70

D.2.3 Rule 4313 Lime Kilns .............................................................................. D-74

D.2.4 Rule 4354 Glass Melting Furnaces ......................................................... D-75

D.2.5 Rule 4802 Sulfuric Acid Mist ................................................................... D-79

D.3 Managed Burning ........................................................................................... D-82

D.3.1 Rule 4103 Open Burning ........................................................................ D-85

D.3.2 Rule 4106 Prescribed Burning and Hazard Reduction Burning .............. D-90

D.4 Agricultural Processes .................................................................................... D-96

D.4.1 Rule 4204 Cotton Gins ........................................................................... D-99

D.4.2 Rule 4550 Conservation Management Practices ................................. D-104

D.5 Residential and Commercial ......................................................................... D-108

D.5.1 Rule 4692 Commercial Charbroiling ..................................................... D-111

D.5.2 Rule 4901 Wood Burning Fireplaces and Wood Burning Heaters ........ D-118

D.5.3 Rule 4902 Residential Water Heaters .................................................. D-128

D.5.4 Rule 4905 Natural Gas-Fired, Fan-Type, Residential Central Furnaces ........ 

 ..............................................................................................................D-132

 
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D.6 Fugitive Particulate Matter ............................................................................ D-135

D.6.1 Rule 8011 General Requirements ........................................................ D-138

D.6.2 Rule 8021 Construction, Demolition, Excavation, Extraction, and Other 

Earthmoving Activities .......................................................................... D-141

D.6.3 Rule 8031 Bulk Materials ...................................................................... D-144

D.6.4 Rule 8041 Carryout and Trackout ......................................................... D-147

D.6.5 Rule 8051 Open Areas ......................................................................... D-150

D.6.6 Rule 8061 Paved and Unpaved Roads ................................................ D-153

D.6.7 Rule 8071 Unpaved Vehicle/ Equipment Traffic Areas ......................... D-157

D.6.8 Rule 8081 Agricultural Sources ............................................................ D-160

D.7 Additional Source Categories ....................................................................... D-163

D.7.1 SC 001 Lawn and Garden Equipment .................................................. D-167

D.7.2 SC 002 Energy Efficiency ..................................................................... D-176

D.7.3 SC 003 Fireworks ................................................................................. D-179

D.7.4 SC 004 Sand and Gravel Operations ................................................... D-183

D.7.5 SC 005 Asphalt/Concrete Operations ................................................... D-186

D.7.6 SC 006 Almond Hulling/Shelling Operations ........................................ D-190

D.7.7 SC 007 Pistachio Hulling/Shelling Operations ...................................... D-196

D.7.8 SC 008 Agricultural Material Screening/Shaking Operations ............... D-199

D.7.9 SC 009 Tub Grinding ............................................................................ D-202

D.7.10 SC 010 Abrasive Blasting ..................................................................... D-205

D.8 Emission Inventory Codes ............................................................................ D-208
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Appendix D: Stationary and Area Source Control Strategy Evaluation 

The San Joaquin Valley air basin (Valley) faces significant challenges in meeting the 

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

Control District (District) has demonstrated leadership in developing and implementing 

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

such as those for indirect source review, residential fireplaces, glass manufacturing, and 

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

The District has adopted many regulatory control measures under the District’s air 

quality attainment plans, including but not limited to the 2007 Ozone Plan and 2008 

PM2.5 Plan, which serve as control measures under the 2012 PM2.5 Plan. Under the 

federal Environmental Protection Agency (EPA) policy, there is a preference for reliance 

on control measures that have already been adopted. The 2012 PM2.5 Plan regulatory 

control measures that have already been adopted are achieving 247.8 tons per day 

(tpd) of NOx reductions and 15.7 tpd of PM2.5 reductions, and include both stationary 

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

rules for mobile sources. The stationary and area source control measures that the 

District has already adopted and are contributing to achieving attainment of the 2006 

NAAQS as a part of this plan are displayed in Table D-1 below. Refer to Appendix C for 

the discussion on mobile sources and mobile source regulatory control measures. Also, 

refer to Chapter 5 for a detailed discussion about the regulatory control measures that 

have already been adopted and will continue to get emissions reductions. 

While the District has adopted numerous rules to reduce emissions from stationary and 

area sources that will achieve significant emissions reductions in the coming years, the 

District has invested significant effort in investigating additional potential opportunities 

for reducing emissions and leaving “no stone unturned,” as outlined in the following 

Guiding Principles adopted by the District’s Governing Board: 

• Use sound science as the plan’s foundation. This includes efforts to assess 

public health impacts, predict future air quality, determine the extent of 

emissions reductions needed, and evaluate the availability, effectiveness, and 

feasibility of emission control measures. 

• Consider all opportunities for timely, innovative, and cost-effective emission 

reductions. Consider traditional regulations, but look beyond traditional 

regulations to incorporate monetary incentives, policy initiatives, guidance 

documents, and outreach, including working with cities and counties to 

incorporate 2012 PM2.5 Plan principles into their general plans.

This appendix reflects the comprehensive evaluation performed by District staff to 

examine the Valley’s various emissions sources, and identify additional potential 

emission reduction strategies for inclusion in this plan. 
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D-2 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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Table D-1 District Stationary and Area Source Regulations Contributing to 

Continued PM2.5 Improvement 

Adopted District Rules Emissions 

Reduced1

Rule 4103 Open Burning 0.12 tpd NOx 

0.34 tpd PM2.5 

Rule 4106 Prescribed Burning and Hazard Reduction Burning NQ2

Rule 4204 Cotton Gins 0.79 tpd PM 

Rule 4307 Boilers, Steam Generators, and Process Heaters 2 to

5 MMBtu/hr 3.36 tpd NOx 

Rule 4308 Boilers, Steam Generators, and Process Heaters 

0.075 to <2 MMBtu/hr 3.30 tpd NOx 

Rule 4309 Dryers, Dehydrators, and Ovens 0.65 tpd NOx 

Rule 4311 Flares 0.06 tpd SOx 

Rules 4306 & 4320 Boilers, Steam Generators, and Process 

Heaters >5 MMBtu/hr 

3.50 tpd NOx 

3.60 tpd SOx 

Rule 4352 Solid Fuel Fired Boilers, Steam Generators, and 

Process Heaters >5 MMBtu/hr NQ2

Rule 4354 Glass Melting Furnaces 

3.37 tpd NOx 

1.70 tpd SOx 

0.11 tpd PM2.5 

Rule 4550 Conservation Management Practices 34.2 tpd PM 

Rule 4692 Commercial Charbroiling 0.08 tpd PM2.5 

Rule 4702 Internal Combustion Engines 22.43 tpd NOx 

Rule 4703 Stationary Gas Turbines 2.20 tpd NOx 

Rule 4901 Wood Burning Fireplaces and Wood Burning Heaters32.40 tpd PM2.5 

Rule 4902 Residential Water Heaters 1.03 tpd NOx 

Rule 4905 Natural Gas-Fired, Fan-Type Residential Central 

Furnaces 2.6 tpd NOx 

Regulation VIII Rules Fugitive PM10 Prohibitions 20.4 tpd PM 

1. Emissions reduced upon full implementation of rule amendments. 

2. Not quantified. 

3. As an average for November – April; the reductions on any given “No Burn” day are much higher. 

Given the significant emissions reductions already achieved through stationary and area 

source regulatory strategies and the significant investment necessary to achieve 

emissions reductions, the Valley is at the point of diminishing returns from new 

regulatory controls on stationary and area sources. Keeping in line with the District 

Governing Board adopted Guiding Principles; staff broadens the search for emission 

reduction opportunities beyond traditional regulatory strategies and considers other 

opportunities for timely, innovative, and cost effective emissions reductions, including 

new incentive programs, policy initiatives, and enhanced education and outreach 

efforts. Also, where additional research is required to determine if potential 

opportunities to further reduce emissions of particulate matter and particulate 

precursors may be feasible for the Valley, the District recommends further study. 

Further study commitments are another example of the District’s commitment to 
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D-3 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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continuously pursue emission reduction opportunities, even after an air quality plan has 

been adopted. The District’s long-standing, multi-faceted strategy for attaining air 

quality standards has produced positive results. The District recognizes that there is no 

“silver bullet” for attainment, and every sector – from the public through all levels of 

government, businesses, and industry – must continue to reduce emissions to meet 

more stringent air quality standards. 

This appendix consists of a literature review and evaluation of emission reduction 

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

multiple departments with expertise in these various sectors contributed to this effort. 

The evaluations in this appendix are intended to capture relevant background 

information, examine emission reduction opportunities for technological and economic 

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

to solicit public input during the plan development process. 

Appendix D Organization and Evaluation 

The stationary and area source control measure source categories evaluated in this 

appendix are organized into the following groups: combustion devices, industrial 

processes, managed burning, agricultural processes, residential and commercial, 

fugitive particulate matter, and additional source categories. Each control measure 

source category group discussion includes a summary of incentive programs, policy 

initiatives, and District rules that are specific to that category. Each individual control 

measure analyzed in this appendix has its own discussion and source category 

analysis. 

Source Category Analysis 

Each control measure source category analysis includes regulatory evaluations 

including an assessment of Reasonably Available Control Technology (RACT); review 

of potential opportunities to reduce emissions; an assessment of each source category 

with respect to the District’s Risk-based Strategy; and recommendations for 

commitments for future actions to be taken by the District. 

Regulatory Evaluation 

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

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

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

comparisons: 

• Federal Regulations – Investigation of federal regulations includes literature 

review of the following regulations and guidance documents: 

o Control Techniques Guidelines (CTG) 

o Alternative Control Techniques (ACT) 

o National Emission Standards for Hazardous Air Pollutants (NESHAP) 

o New Source Performance Standards (NSPS) 

o Best Available Control Technology (BACT) 
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o Maximum Achievable Control Technology (MACT) 

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

Ozone Demonstration, the rules were also compared to analogous regulations 

adopted by California’s most progressive air districts. Investigation of control 

strategies and measures in other air districts and agencies includes, but is not 

limited to the following air districts: 

o South Coast Air Quality Management District (SCAQMD) 

o Sacramento Metropolitan Air Quality Management District (SMAQMD) 

o Bay Area Air Quality Management District (BAAQMD) 

o Ventura County Air Pollution Control District (VCAPCD) 

• Reasonably Available Control Technology (RACT) –EPA has defined RACT 

as “the lowest emission limitation that a particular source is capable of meeting 

by the application of control technology that is reasonably available considering 

technological and economic feasibility” (44 FR 53762; September 17, 1979). Per 

Sections 182(b)(2) and 182(f) of the federal Clean Air Act, ozone nonattainment 

areas are required to implement RACT for sources that are subject to CTG 

documents issued by EPA and for “major sources” of VOCs and oxides of 

nitrogen (NOx), which are ozone precursors. Each control measure source 

category subject to RACT is evaluated to determine if each is at least as 

stringent as established RACT requirements. All source categories subject to 

RACT requirements have been determined to currently satisfy RACT 

requirements. Any new prohibitory requirements for these source categories 

would be more stringent than RACT. 

Potential Opportunities to Reduce Emissions 

Each control measure source category analysis identifies potential emission reduction 

opportunities for PM2.5 and its precursors, such as NOx and SOx. The potential 

emission reduction opportunities are then thoroughly evaluated using the following key 

factors: 

• Technological Feasibility – The technological feasibility analysis determines if a 

potential opportunity to reduce emissions will physically work for existing facilities 

and operators in the Valley. District analysis of technological feasibility includes 

a literature review of BACT guidelines; District permits; environmental and 

technological studies; EPA and ARB guideline documents; and other air districts’ 

rules, regulations, and guidelines, to identify potential opportunities and 

determine the technological feasibility of any identified potential opportunities. 

• Cost Effectiveness – The purpose of conducting a cost effectiveness analysis is 

to evaluate the economic reasonableness of a pollution control measure or 

technology as it applies to operators in the Valley. A cost effectiveness analysis 

examines the added cost, in dollars per year, of the control technology or 

technique, divided by the emissions reductions achieved, in tons per year. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-5 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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( )

Emission Reduction ( / )

Compliancecost ($/ )

Cost Effectiveness /$ 

ton year

year

ton =

Additionally, a literature review of previous staff reports from District rules, staff 

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

and applicable study data from the scientific community is conducted to 

determine if any technologically feasible opportunities that were previously not 

cost effective have changed to become cost effective since the last amendment. 

Risk-Based Strategy 

The District’s Risk-based Strategy (RBS) fits within and effectively supplements EPA’s 

current Clean Air Act (CAA) framework. Through the RBS, the District is maximizing 

public health improvements resulting from the District’s attainment strategies and 

related initiatives. The District is integrating the RBS into various aspects of the 2012 

PM2.5 Plan, including control measure review and strategy prioritization. As described 

in Chapter 2 of this plan, the District uses a five-factor exposure assessment 

methodology to evaluate the PM2.5 attainment strategy under the RBS: 

1. Relevance to attainment 

2. Toxicity of chemical species 

3. Particle size and deposition 

4. Proximity to PM 0.1 

5. Population intake fraction 

Based on this assessment, the District prioritizes regulatory control measures and other 

strategies that maximize public health. EPA policy directly acknowledges the 

importance of a Risk-based Strategy to maximize public health benefits within a region’s 

attainment efforts, noting in the March 2012 PM2.5 implementation guidance memo, 

“...it is likely that SIPs for the 2006 24-hour PM2.5 NAAQS may need to include greater 

emphasis on reducing emissions from local sources [emphasis added] as compared to 

plans to attain the 1997 PM2.5 NAAQS.”[1] EPA’s memo further encourages that states 

consider evidence from published literature indicating that reductions of direct PM2.5 

have a greater health benefit per ton than reductions of other criteria pollutants, such as 

SO2 and NOx,[2] and that providing methods local air quality plans can use to maximize 

health benefits and minimize risk inequality.[3] 

 

[1] U.S. Environmental Protection Agency (2012, March 2). Memorandum from the Office of Air Quality Planning and 

Standards: Implementation Guidance for the 2006 24-Hour Fine Particle (PM2.5) National Ambient Air Quality 

Standards (NAAQS). Retrieved from http://www.epa.gov/ttn/naaqs/pm/pdfs/20120302_implement_guidance_24-

hr_pm2.5_naaqs.pdf

[2] Fann, N., Fulcher, C.M., & Hubbell, B.J. (2009). The Influence of Location, Source, and Emission Type in 

Estimates of the Human Health Benefits of Reducing a Ton of Air Pollution. Air Quality, Atmosphere & Health, 2(3), 

169–176. doi: 10.1007/s11869-009-0044-0 

[3] Fann, N., Roman, H.A., Fulcher, C.M., Gentile, M.A., Hubbell, B.J., Wesson, K., & Levy, J.I. (2011). Maximizing 

Health Benefits and Minimizing Inequality: Incorporating Local-Scale Data in the Design and Evaluation of Air Quality 

Policies. Risk Analysis, 31(6), 908–922. doi: 10.1111/j.1539-6924.2011.01629.x
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-6 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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Control Measure Commitment Recommendations 

District’s analysis of all applicable criteria discussed above will result in 

recommendations for commitments for the District to take to attain the standard as 

expeditiously as practicable. After the public has had opportunities to contribute to and 

comment on the evaluations and analyses, the District will determine which control 

strategies should be included in the plan. Commitments for future control strategies are 

in the form of the following types of actions: 

• Regulatory Action 

o Rule amendments or adoption of new rules 

o Further study for additional opportunities to reduce emissions 

• Incentive programs 

• Technology advancement programs 

• Policy initiatives 

• Increased public outreach and education 

Regulatory action commitments are summarized in Chapter 5 (Regulatory Control 

Measures), and all commitments are summarized in Chapter 9 (Progress Toward 

Attainment of the 2006 PM2.5 Standard). 
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D-7 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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D.1 COMBUSTION DEVICES 

Combustion devices are equipment that burn fuel to create power, heat, or other forms 

of energy. The process of burning fuel via internal or external combustion creates 

multiple pollutants, including oxides of nitrogen (NOx), the primary PM2.5 precursor, 

volatile organic compounds (VOC), and oxides of sulfur (SOx). Establishing effective 

emission reduction strategies for combustion devices continues to be a key component 

of the San Joaquin Valley Air Pollution Control District’s (District) strategy to reduce 

emissions and achieve federal air quality standards. 

Combustion devices are utilized in numerous applications throughout the private and 

public sectors. The control measure source categories discussed affect several 

industries in the San Joaquin Valley air basin (Valley) including, but not limited to: 

electrical utilities, cogeneration, oil and gas production, petroleum refining, 

manufacturing processes, industrial activities, and food and agricultural processing. 

Existing Control Strategies 

Due to the degree of difficulty and enormity of the challenge that the Valley faces in 

meeting the National Ambient Air Quality Standards (NAAQS), the District recognizes 

that prohibitory rules alone are not enough to reduce emissions to meet attainment 

requirements and protect public health. The District’s longstanding, progressive 

strategy for reducing emissions is a multifaceted effort that includes incentive programs 

and policy initiatives in addition to prohibitory rules. The following discussion 

summarizes both the existing District efforts to reduce emissions from this source 

category, and evaluations for potential opportunities for further emissions reductions. 

Incentive Programs 

Incentive programs are an integral part of the emission reduction efforts of the District, 

especially where the District lacks direct jurisdiction in establishing emission control 

requirements. Since the emission units within the Combustion Devices category are 

typically located at stationary sources and have been subject to several generations of 

regulations, the opportunities for incentive programs have been minimal. The District 

currently funds the following incentive programs that directly apply to stationary 

combustion units. 

 

The stationary agricultural irrigation pump engine program component of the District’s 

Heavy-Duty Engine Program was created to assist agricultural stakeholders in replacing 

old polluting internal combustion engines with new more efficient and less polluting units 

or with electric units with zero emissions. To date, the program has distributed over 

$100 million in grant money and has funded the replacement and/or purchase of 6,094 

new engines and electric motors, reducing 47,059 tons of NOx and 1,738 tons of 

particulate emissions. Similarly, the District partnered with the Natural Resources 

Conservation Service (NRCS) Environmental Quality Incentives Program (EQIP) to 
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replace 15 agricultural pump engines in the Valley. Between 2003 and 2011, NRCS 

also replaced an additional 547 diesel irrigation engines in the Valley.1

 

Incentives have also been available for biomass facilities through state and Federal 

funded programs independent from the District. Funding or tax credits are available 

through some short-term programs such as the Existing Renewable Facilities Program 

through the California Energy Commission (CEC) and federal corporate tax credits from 

a federal program called the Renewable Electricity Program Tax Credit. In addition to 

these programs, incentives and funding through Assembly Bill 118 (Núñez Statutes of 

2007, Chapter 750), which directs the CEC to develop the Alternative and Renewable 

Fuel and Vehicle Technology Program, are available to identify and promote alternative

biomass-based feedstocks, including agricultural waste, for the production of alternative 

fuels. 

Policy Initiatives 

The District’s policies and Legislative Platform are important components to the 

District’s strategy to attain federal ambient air quality standards. The District utilizes 

policies and the legislative platform to bring attention to major issues that have a direct 

impact on the Valley’s air quality. 

The District supports legislation for the continued operation of biomass facilities, 

including subsidies and/or preferential utility rates for power produced from biomass to 

enhance the economic feasibility of this alternative. Adoption of Senate Bill 705 (2003, 

codified as Health and Safety Code Sections 41855.5 and 41855.6), which phases out 

the ability to burn certain agricultural material in the field, has underlined the importance 

of biomass facilities in providing a mechanism to dispose of this agricultural material. 

The District also supports legislation that calls for the increased development and use of 

cleaner-burning fuels. This platform was developed in an effort to accelerate the 

reduction of NOx emissions from combustion devices and the ability of Valley sources 

to achieve lower emission limits. 

The District has made a diligent effort to support legislation that provides funding for the 

Carl Moyer Program and other similar incentive programs. The District supports the 

continuation of air quality funding in the Farm Bill to accelerate the replacement of 

agricultural equipment. Incentive funds have resulted in the turnover of thousands of 

irrigation pumps thus far, generating significant emissions reductions for the Valley. 

Rules and Regulations 

The following is a list of District rules that apply to the Combustion Devices category. 

Units subject to these rules are subject to some of the most stringent regulations and 

standards in the nation and have been subject to several generations of rule 

amendments. Each of the following rules will be evaluated to examine potential 

opportunities for additional emissions reductions. 

 

1

 The District has also participated in the replacement of various mobile source combustion units (i.e. tractors) 

through other incentives programs. Please see Chapter 6 for additional information. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

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Table D-2 District Combustion Devices Rules 

Rule

Last 

Amended/ 

Adopted

Rule 4203 Particulate Matter Emissions from Incineration of 

Combustible Refuse 12/17/1992 

Rule 4307 Boilers, Steam Generators and Process Heaters–2.0 

MMBtu/hr to 5.0 MMBtu/hr 05/19/2011 

Rule 4308 Boilers, Steam Generators and Process Heaters–

0.075 MMBtu/hr to less than 2.0 MMBtu/hr 12/17/2009 

Rule 4309 Dryers, Dehydrators, and Ovens 12/15/2005 

Rule 4320 Advanced Emission Reduction Options for Boilers, 

Steam Generators, and Process Heaters Greater 

than 5.0 MMBtu/hr 

10/16/2008 

Rule 4352 Solid Fuel Fired Boilers, Steam Generators, and 

Process Heaters 12/15/2011 

Rule 4702 Internal Combustion Engines 08/18/2011 

Rule 4703 Stationary Gas Turbines 09/20/2007 
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D.1.1 Rule 4203 Particulate Matter Emissions from the Incineration 

of Combustible Refuse 

Source Category 

Rule 4203 is applicable to incinerators or other equipment used to dispose of or process 

combustible refuse by incineration. The rule limits the concentration of particulate 

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

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

District rule number reorganization on December 17, 1992. There are currently 3 

facilities in the Valley subject to Rule 4203. These facilities currently implement Best 

Available Control Technology (BACT) requirements; the facilities are required to 

mitigate the discharge of air pollutants to the maximum degree achievable. For this 

source category, examples of emission control technologies include baghouses and 

lime scrubbers. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.08 0.10 0.10 0.11 0.11 0.11 0.11 0.12

NOx 0.88 1.12 1.18 1.25 1.29 1.29 1.32 1.33

SOx 0.05 0.04 0.02 0.02 0.02 0.02 0.02 0.02

Winter Average - Tons per day

PM2.5 0.08 0.10 0.10 0.11 0.11 0.11 0.11 0.12

NOx 0.88 1.12 1.18 1.25 1.29 1.29 1.32 1.33

SOx 0.05 0.04 0.02 0.02 0.02 0.02 0.02 0.02

Regulatory Evaluation 

How does District Rule 4203 compare with federal rules and regulations? 

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

New Source Performance Standards (NSPS), Control Techniques Guidelines (CTG), 

Alternative Control Technology (ACT), Maximum Achievable Control Technology 

(MACT), and National Emission Standards for Hazardous Air Pollutants (NESHAP). 

EPA BACT standards require the use of a fabric filter or baghouse. However, District 

BACT standards are just as stringent and require the use of natural gas supplemental 

fuel with a baghouse. 
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How does District Rule 4203 compare to rules in other air districts? 

Rule 4203 was compared to similar rules at other air districts and is at least as stringent, 

if not more stringent, than other districts’ rules. Comparisons to other air district rules 

included SCAMQD Rule 473 (Disposal of Solid and Liquid Wastes) and SMAQMD Rule 

407 (Open Burn). BAAQMD and VCAPCD do not have comparable rules. 

In addition to being one of the most stringent rules in the nation for this source category 

any new unit brought to the Valley, as well as any major modifications to existing units, 

would trigger BACT requirements. These new or modified units would be required to 

control emissions beyond that established as being RACT and implement the best 

available controls for NOx and PM2.5 emissions, as required by District Rule 2201 (New 

and Modified Stationary Source Review Rule). Additionally, all new or modified units 

are evaluated under the District’s air toxics policy, and are required to not pose a 

significant health risk to Valley residents. 

Emission Reduction Opportunities 

Rule 4203 is one of the most stringent rules in the nation for this source category. As 

mentioned above, units subject to this rule already meet BACT level requirements, 

which require the mitigation of air pollution to the maximum degree achievable using 

control technology like baghouses and lime scrubbers. No technologies beyond those 

established as BACT were identified. 

Risk-based Strategy Analysis 

The emissions from units subject to Rule 4203 contribute 2.3% of average winter NOx 

emitted from stationary and area sources in the 2012 emission inventory. As illustrated 

in the emission inventory table above, the emissions from this source category are 

relatively small and consistent throughout the year, with no elevated emission levels in 

the winter months. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4203. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4203. 

Incentive Action 

Units subject to Rule 4203 are regulated stationary sources, and already implement 

BACT level controls; as such, the opportunities for incentive programs are minimal. No 

incentive actions are recommended for furnaces and other units used for the 

incineration of combustible refuse at this time. 

 
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Technology Advancement Action 

There is no recommendation for a new technology advancement project for units 

subject to Rule 4203. Through its Technology Advancement Program, the District will 

continue to seek potential feasible and low-cost technologies that may provide for 

additional emission reduction opportunities in this category. 

Policy Initiatives 

The District is not currently supporting any policy initiatives specific to furnaces and 

other units used for the incineration of combustible refuse. As regulated sources are 

already implementing BACT level controls, there are no recommendations for new 

policy initiatives for these sources. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. No new education and outreach efforts are recommended for these sources 

at this time. The District will continue to work closely with affected sources to ensure 

successful compliance. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-13 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.1.2 Rule 4307 Boilers, Steam Generators and Process Heaters–

2.0 MMBtu/hr to 5.0 MMBtu/hr 

Source Category 

This rule applies to any gaseous fuel or liquid fuel fired boiler, steam generator, or 

process heater with a total rated heat input of 2.0 million British thermal units per hour 

(MMBtu/hr) up to and including 5.0 MMBtu/hr. The purpose of this rule is to limit 

emissions of NOx, carbon monoxide (CO), sulfur dioxide (SO2), and particulates from 

units subject to this rule. Based on District permits information, there are currently 540 

permitted and Permit-Exempt Equipment Registration (PEER) units subject to Rule 

4307 requirements. 

Rule 4307 was adopted on December 15, 2005 to establish emissions limits and control 

requirements for these units which were previously exempt because of their size. Since 

its adoption, the rule has been amended three times. The most recent amendments 

strengthened the rule by removing some exemptions, imposing NOx limits of 9 or 12 

ppmv for new and replacement units, and adding a menu-approach for particulate 

matter control that also encompasses SOx controls. EPA finalized approval of Rule 

4307 on January 13, 2010 and deemed this rule as being at least as stringent as 

established RACT requirements. As a result of this rule, NOx emissions have been 

controlled by over 84% for units in this source category. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.37 0.33 0.32 0.31 0.31 0.30 0.30 0.29

NOx 0.70 0.38 0.34 0.31 0.30 0.30 0.29 0.28

SOx 0.39 0.22 0.09 0.09 0.09 0.08 0.08 0.08

Winter Average - Tons per day

PM2.5 0.36 0.32 0.31 0.31 0.30 0.30 0.29 0.29

NOx 0.67 0.36 0.33 0.30 0.29 0.29 0.28 0.27

SOx 0.38 0.21 0.09 0.08 0.08 0.08 0.08 0.08
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-14 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Regulatory Evaluation 

How does District Rule 4307 compare with federal rules and regulations? 

Rule 4307 is equivalent to the applicable federal standards and guidelines. As 

confirmed by the June 2009 EPA Technical Support Document (TSD) for Rule 4307, the 

rule is as stringent as the federal Alternative Control Techniques (ACT) documents 

(EPA –453/R-94-022 “Alternative Control Techniques Document – NOx Emissions from 

Industrial/Commercial/Institutional Boilers”, dated March 1994 and EPA – 452/R-93-008 

“Alternative Control Techniques Document—NOx Emissions from Utility Boilers”, dated 

March 1994), New Source Performance Standards (NSPS) (40 CFR 60 Subpart D 

(Standards of Performance for Fossil-Fuel Fired Steam Generators for Which 

Construction Commenced After August 17, 1971) and 40 CFR 60 Subpart Dc 

(Standards of Performance for Small Industrial-Commercial-Institutional Steam 

Generating Units)), and Maximum Achievable Control Technology (MACT) (40 CFR 63 

Subpart DDDDD (NESHAP for Industrial, Commercial, and Institutional Boilers and 

Process Heaters)). Additionally, there are no EPA Control Technique Guidelines (CTG) 

or Best Available Control Technology (BACT) requirements listed for this category. 

How does District Rule 4307 compare to rules in other air districts? 

In comparison to other California air districts’ rules for similar sources, Rule 4307 is at 

least as stringent as the analogous rules for SCAQMD (Rule 1146.1—Emissions of 

Oxides of Nitrogen from Small Industrial, Institutional, and Commercial Boilers, Steam 

Generators, and Process Heaters), BAAQMD (Regulation 9 Rule 7—Nitrogen Oxides 

and Carbon Monoxide from Industrial, Institutional and Commercial Boilers, Steam 

Generators and Process Heaters and Regulation 9 Rule 10—Nitrogen Oxides and 

Carbon Monoxide from Boilers, Steam Generators and Process Heaters in Petroleum 

Refineries), SMAQMD (Rule 411—NOx from Boilers, Process Heaters, and Steam 

Generators), and VCAPCD (Rule 74.15.1—Boilers, Steam Generators, and Process 

Heaters). 

No BACT requirements exist for units of this small size. Generally, these smaller units 

have been exempt from permit requirements. However, the District does require these 

units to be registered through Rule 2250 (Permit-Exempt Equipment Registration) to 

ensure compliance with Rule 4307 requirements. 

Emission Reduction Opportunities 

The District has adopted numerous rule amendments over the years for boilers that 

have significantly reduced emissions from units subject to Rule 4307. Most units 

subject to Rule 4307 are fired on Public Utilities Commission (PUC) quality natural gas, 

and are inherently low-emitters of SOx and PM2.5 emissions. The NOx limits 

implemented through Rule 4307 and its amendments will reduce emissions from over 

1,000 small (2-5 MMBtu/hr) boilers in the Valley when fully implemented, including from 

units that were previously exempt. As a result of these regulatory efforts, the emissions 

inventory for NOx from these boilers has dropped from 3.81 tpd in 2005 to 0.38 tpd in 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-15 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

2012. Additional emissions reductions are forthcoming with existing Rule 4307 as 

additional compliance dates are approaching in 2016. Given the significant efforts and 

investments already made to reduce emissions from this source category, there are little 

remaining opportunities for obtaining additional emissions reductions. 

As discussed above, Rule 4307 is as stringent as or more stringent than federal 

regulations and requirements and other districts’ rules and regulations. Any new or 

additional requirements would extend well beyond RACT requirements. 

EMx as Potential Control 

Post-combustion controls such as EMx, the second generation of the SCONOx 

technology that reduces NOx, SOx, CO, and volatile organic compound (VOC) 

emissions, were researched. This technology has not been achieved in practice (AIP) 

in the District and there is no available data that indicates that SCONOx or EMx has 

been installed on boilers, particularly in this size range, even though the manufacturer’s 

website states that the technology is transferrable to industrial boilers. Based on 

research of the best available controls from EPA and other air districts, the SCONOx 

and EMx systems have only been utilized by power plants for the control of turbine 

emissions. In fact, cost effectiveness analyses conducted by the District for the 

installation of SCONOx/EMx units on large power plant turbine installations within the 

San Joaquin Valley have been found to not be cost effective. Given the high cost 

effectiveness demonstrated for turbines and lack of demonstrated practice with boilers, 

the District does not expect this technology to be feasible or cost effective for reducing 

emissions from this category. 

 

PM2.5 Limits for Alternative Fuels 

The majority of boilers (2-5 MMBtu/hr) in the Valley combust PUC-quality natural gas; 

PUC natural gas contains a very low sulfur content and inherently has low emissions. 

Few boilers in the Valley use alternative fuels for their combustion processes. 

Alternative fuels include digester gas, produced gas, and liquid fuel. Units fired on 

digester gas or produced gas are already required to use inlet gas scrubbers to meet 

District rule requirements. Current rule language requires that on and after July 1, 2015 

liquid fuel shall be used only during a PUC quality natural gas curtailment period 

provided it contains no more than 15 ppm sulfur. While the currently limited use of 

liquid fuel will become even more strictly limited by July 2015, the feasibility of reducing 

PM emissions through adding PM2.5 limits for units using liquid fuel was explored as 

part of the District’s comprehensive control measure evaluation. 

There are 25 liquid fuel fired units in the Valley (2-5 MMBtu/hr) with a combined 

emissions inventory of approximately 0.08 tons per year of total PM. The low emissions 

inventory is attributed to the fact that these units either utilize liquid fuel as a backup if 

there is a natural gas curtailment or are minimally operated units. The following three 

technologies were evaluated as potential control options for reducing PM emissions: 

baghouses, electrostatic precipitators (ESPs), and wet scrubbers. Baghouses control 

total PM and PM2.5 emissions by 90-99%; ESPs control total PM and PM2.5 emissions 

by 90-99%; and wet scrubbers control large particulates (>PM5) by 99% and PM2.5 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-16 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

emissions by approximately 50%.2 However, baghouses are typically not used with 

liquid-fired boilers due to the potential clogging of the baghouse and are therefore not a 

recommended technology due to infeasibility and safety issues.3

 

PM Potential Emissions Reductions for an ESP and Scrubber 

For the purposes of these calculations, the following assumptions were made: 

1. For simplicity, the analysis will evaluate the cost effectiveness of these 

technologies for total PM reductions from liquid fuel fired units. 

2. The PM control efficiency of an ESP is 99%. 

3. The PM control efficiency of a scrubber is 99%. 

Potential Emissions ReductionsESP = (Total PM Emissions) x (Control Efficiency) 

Potential Emissions ReductionsESP = 0.08 tons/year X 0.99 

Potential Emissions ReductionsESP = 0.079 tons/ year (tpy) 

Potential Emissions Reductions scrubber = (Total PM Emissions) x (Control Efficiency) 

Potential Emissions Reductions scrubber = 0.08 tons/year X 0.99 

Potential Emissions Reductions scrubber = 0.079 tons/ year (tpy) 

Annualized Cost of an ESP and Wet Scrubber 

The capital cost for the installation of an ESP for a 1-5 MMBtu/hr boiler ranges from 

$90,000 - $100,000 and the annual maintenance cost is $1,000-$2,000.4

 For the wet 

scrubber system, EPA estimated the annualized cost at $5,300-$102,000 per sm3

/sec 

at an average air flow rate of 0.7- 47 sm3/sec.5 The following assumptions were made 

for this cost effectiveness calculations: 

1. The capital cost of an ESP is assumed to be the median of the range above 

($95,000). 

2. The annual maintenance cost of an ESP is assumed to be the median of the 

range above ($1,500). 

3. The annualized cost of a wet scrubber system is assumed to be the median of 

the range above ($53,650 per sm3/sec). 

4. The average air flow rate for a wet scrubber system is assumed to be the median 

of the range above (23.85 sm3

/sec). 

 

2

 Northeast States for Coordinated Air Use Management. (November 2008) Applicability and Feasibility of NOx, 

SO2, and PM Emissions Control Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. 

3

 Northeast States for Coordinated Air Use Management. (November 2008) Applicability and Feasibility of NOx, 

SO2, and PM Emissions Control Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. 

4

 Catherine Roberts. (March 2009) Information on Air Pollution Control Technology for Woody Biomass Boilers. 

Environmental Protection Agency Office of Air Quality Planning and Standards and Northeast States for Coordinated 

Air Use Management. 

5

 Environmental Protection Agency. (2002). Air Pollution Control Technology Fact Sheet: Spray-Chamber/SprayTower Wet Scrubber.
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-17 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

5. The total capital and maintenance cost of an ESP will be calculated by 

multiplying the cost of 1 unit by the total number of units. 

6. The total annualized cost of a wet scrubber will be calculated by multiplying the 

annualized cost of 1 unit by the total number of units. 

7. Lifetime of the ESP is 10 years at 10% interest. To account for this, the 

annualized capital cost will be calculated by multiplying the total capital cost by 

the capital recovery factor of 0.1627 and adding the annual maintenance costs. 

Annual CostESP = (Total Capital Cost) x (0.1627) + (Annual Maintenance Cost) 

Annual CostESP = ($95,000 x 25) x (0.1627) + ($1,500 x 25) 

Annual CostESP = $423,913/year 

Annual Costscrubber = (Annualized Cost of 1 unit) x (Number of Units) x 

(Average Flow Rate) 

Annual Costscrubber = ($53,650/ sm3/sec) x (25) x (23.85 sm3/sec) 

Annual Costscrubber = $31,988,813 year 

Cost Effectiveness of an ESP and Wet Scrubber 

Cost Effectiveness = Annual Cost / Annual Emissions Reductions 

Cost EffectivenessESP = ($423,913/year) / (0.079 tons/ year) 

Cost EffectivenessESP = $5,365,987/ton of PM 

Cost Effectivenessscrubber = ($31,988,813/year) / (0.079 tons/ year) 

Cost Effectivenessscrubber = $404,921,684ton of PM 

As illustrated above, neither PM control technology is a cost effective option for this 

source category. The cost of the ESP technology does not include costs of retrofitting 

equipment and/or the facility or compliance monitoring costs, which would drive the cost 

effectiveness up even more. In addition, the annualized costs provided by EPA for the 

wet scrubber system are in 2002 dollars, which means the value above would be even 

greater if it were adjusted to 2012 dollars. 

At this time, the District’s analysis indicates that there are no feasible opportunities for 

additional emission reduction regulatory strategies for this source category. 

Risk-based Strategy Analysis 

The emissions from units subject to Rule 4307 contribute 0.7% of average winter NOx, 

2.6% of average winter SOx, and 0.6% of average winter PM2.5 emitted from stationary 

and area sources in the 2012 emission inventory. These units are primarily fired on 

PUC-quality natural gas, which is generally considered a clean burning fuel with low 

SOx and PM emissions. Overall, Rule 4307 has significantly reduced NOx and SOx 

emissions from these units and has assisted in reducing PM2.5 concentrations through 

reductions of these key precursors. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-18 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4307. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4307. 

Incentive Action 

Boilers subject to Rule 4307 are regulated units that have been subject to several 

generations of regulations; as such, the opportunities for incentive programs are 

minimal. There are no recommendations for incentive actions at this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for units 

subject to Rule 4307. Through its Technology Advancement Program, the District will 

continue to seek potential feasible and low-cost technologies that may provide for 

additional emission reduction opportunities in this category. 

Policy Initiatives 

The District’s current legislative platform includes support for the increased 

development and use of cleaner-burning fuels. The recommendation is to continue 

supporting the current legislative platform. There are no recommendations for new 

policy initiatives at this time because the rule already requires the most effective 

emission control technologies. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. The District does not have recommendations for new education and outreach 

efforts for these sources. The District will continue to work closely with affected sources 

to ensure successful compliance. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-19 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.1.3 Rule 4308 Boilers, Steam Generators and Process Heaters–

0.075 MMBtu/hr to less than 2.0 MMBtu/hr 

Source Category 

This rule applies to any person who supplies, sells, offers for sale, installs, or solicits the 

installation of any boiler, steam generator, process heater or water heater with a rated 

heat input capacity greater than or equal to 0.075 MMBtu/hr and less than 2.0 

MMBtu/hr. This rule is a point of sale rule and achieves reductions as units subject to 

the rule are replaced over time. 

Rule 4308 was adopted on October 20, 2005 to establish NOx emissions limits for these 

units which were previously exempt because of their size. The rule has been amended 

once, in December 2009, to lower the NOx emissions limits to 20 ppmv for units fired on 

natural gas, with the exception of a few unit types. EPA finalized approval for Rule 

4308 on January 31, 2011 and deemed this rule as being at least as stringent as 

established RACT requirements. This rule has resulted in approximately 93% control of 

emissions from this source category. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day 

PM2.5 0.70 0.62 0.60 0.59 0.58 0.57 0.56 0.55

NOx 1.32 0.71 0.64 0.60 0.58 0.56 0.54 0.53

SOx 0.73 0.42 0.17 0.17 0.16 0.16 0.16 0.15

Winter Average - Tons per day 

PM2.5 0.68 0.61 0.59 0.58 0.57 0.56 0.55 0.54

NOx 1.27 0.68 0.62 0.57 0.55 0.54 0.52 0.51

SOx 0.71 0.41 0.17 0.16 0.16 0.16 0.15 0.15

Regulatory Evaluation 

How does District Rule 4308 compare with federal rules and regulations? 

Rule 4308 is equivalent to the applicable federal standards and guidelines. As 

confirmed by the July 2010 EPA technical support document (TSD) for the approval of 

Rule 4308, the rule is as stringent as the federal Alternative Control Techniques (ACT) 

(EPA –453/R-94-022 “Alternative Control Techniques Document – NOx Emissions from 

Industrial/Commercial/ Institutional Boilers”, dated March 1994 and EPA – 452/R-93-

008 “Alternative Control Techniques Document—NOx Emissions from Utility Boilers”, 

dated March 1994). Federal requirements such as New Source Performance 

Standards (NSPS), National Emission Standards for Hazardous Air Pollutants 

(NESHAP), and Maximum Achievable Control Technology (MACT) requirements are 

not applicable to boilers, steam generators, and process heaters of this size. 

Additionally, there are no EPA Control Techniques Guidelines (CTG) or Best Available 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-20 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Control Technology (BACT) requirements listed for this category. The District, 

SCAQMD, BAAQMD, and EPA do not employ BACT requirements for this source 

category because BACT is required for new or modified permitted units and these units 

are exempt from the permitting process. 

How does District Rule 4308 compare to rules in other air districts? 

Air districts’ rules that were evaluated as a part of this control measure effort include 

BAAQMD Regulation 9 Rule 6 (Nitrogen Oxides Emissions from Natural Gas-Fired 

Boilers and Water Heaters), SMAQMD Rule 411 (NOx from Boilers, Process Heaters 

and Steam Generators), SMAQMD Rule 414 (Water Heaters, Boilers and Process 

Heaters Rated Less Than 1,000,000 BTU Per Hour), VCAPCD Rule 74.11.1 (Large 

Water Heaters and Small Boilers), and SCAQMD Rule 1146.2 (Emissions of Oxides of 

Nitrogen From Large Water Heaters and Small Boilers and Process Heaters). 

District Rule 4308 meets RACT standards, which includes a comparison to other air 

district rules, as confirmed by the previously mentioned 2010 EPA TSD. Rule 4308 was 

compared to other California air districts’ rules for similar sources and cross-referenced 

with the exemptions in each rule. Multiple air districts do not exempt water heaters in 

mobile homes like Rule 4308; however, because those air districts have different rule 

structures with regards to the size of devices regulated, District Rule 4308 requirements 

are as stringent as the other Districts’ rules. 

For example, SCAQMD Rule 1146.2 does not regulate mobile home water heaters, per 

the definition for type 1 units, because they are subject to Rule 1121 (Control of 

Nitrogen Oxides from Residential Type, Natural Gas-Fired Water Heaters). SCAQMD 

Rule 1121 regulates units less than 0.075 MMBtu/hr, which is out of the size range of 

District Rule 4308. Similarly, in SMAQMD Rule 414, mobile home units are regulated in 

the size range of less than 0.075 MMBtu/hr. District Rule 4902 (Residential Water 

Heaters) applies to units less than 0.075 MMBtu/hr and currently regulates mobile home 

water heaters with the same emission limit in SCAQMD and SMAQMD rules. BAAQMD 

Rule 09-06 regulates all units less than 2 MMBtu/hr, essentially combining the 

requirements of District Rules 4308 and 4902. 

Upon further comparison of District Rule 4308 to other air district rules, it was found that 

other air districts have more stringent limits for instantaneous water heaters. SCAQMD 

Rule 1146.2 (amended May 5, 2006) contains a limit of 20 ppmv NOx for natural gasfired instantaneous water heaters in the size range of 0.075 – 0.4 MMBtu/hr, effective 

January 1, 2012 and BAAQMD Rule 09-06 (amended November 7, 2007) also contains 

a limit of 20 ppmv NOx effective January 2013. District Rule 4308 contains a limit of 55 

ppmv for these same units. Refer to the Instantaneous Water Heaters discussion below 

for more details. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-21 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Emission Reduction Opportunities 

The adoption of Rule 4308 and its subsequent amendment in 2009 have significantly 

reduced NOx and PM emissions from boilers of this size category, effectively reducing 

the emissions inventory for NOx from 3.66 tons per day (tpd) in 2005 to 0.71 tpd in 

2012. It is estimated that the rule will effectively reduce emissions from over 17,000 

units in the Valley upon full implementation. Additional emissions reductions are 

forthcoming as consumers continue to replace older units with newer and lower-emitting 

units. Given the significant regulatory efforts already made to reduce emissions from 

this source category, the only remaining potential opportunity for obtaining additional 

emissions reductions from currently regulated units would be to lower the NOx emission 

limit for instantaneous water heaters in the size range of 0.075 – 0.4 MMBtu/hr. For 

thoroughness, the possibility of further reducing emissions from currently exempt 

sources is also evaluated below. 

Instantaneous Water Heaters 

The emissions limits for units subject to Rule 4308 are separated based on two size 

categories: units 0.075-0.4 MMBtu/hr and units 0.4-2.0 MMBtu/hr. The larger category 

of instantaneous (tankless) water heaters 0.4-2.0MMBtu/hr are currently regulated with 

a NOx emissions limit of 20 ppmv, which is as stringent as the limit in the other air 

districts’ rules. As a result, there is no opportunity to reduce emissions from the larger 

instantaneous water heaters. However, the emissions limit for instantaneous water 

heaters 0.075-0.4 MMBtu/hr in Rule 4308 is not equivalent to the other air districts’ 

rules, which creates a potential opportunity for further emissions reductions from this 

category. 

BAAQMD Rule 09-06 and SCAQMD Rule 1146.2 contain a more stringent NOx limit for 

instantaneous water heaters. When SCAQMD amended Rule 1146.2 to incorporate a 

20 ppmv NOx limit for instantaneous water heaters, the technology had not been 

achieved in practice yet; however, manufacturers of instantaneous water heaters were 

reporting their progress of technology advancements quarterly to SCAQMD and 

indicated that they were on track to achieve a 20 ppmv NOx standard for instantaneous 

units by 20126

. Similarly, BAAQMD amended Rule 09-06 in 2007 to incorporate a 20 

ppmv NOx limit for instantaneous water heaters after SCAQMD indicated that the 

technology was still set to be available in 2012. During that same time, BAAQMD 

received information that the additional cost of a 20 ppmv instantaneous water heater 

would be $100-$200, in comparison to a 55 ppmv instantaneous unit. Even though 

these units were not available at the time of the rule amendments, BAAQMD and 

SCAQMD amended their rules to include a 20 ppmv NOx limit for instantaneous units in 

this size range in anticipation of the technology being available by the compliance 

deadlines and because the cost differential for a 20 ppmv unit would be at most $200. 

SCAQMD has obtained information that six manufacturers now produce instantaneous 

water heaters in this size range that meet the 20 ppmv limit. Five of the six 

manufacturers were contacted and four of them sell the identified models to Valley 

 

6

 Gimlen, Guy A. (October 2007). Staff Report for BAAQMD Regulation 9, Rule 6: Nitrogen Oxides from Natural GasFired Water Heaters. San Francisco, CA: Bay Area Air Quality Management District. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-22 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

sources. Three of the manufacturers distribute their units through planning wholesalers 

who only sell to licensed contractors, with no direct retail sales. The fourth manufacturer 

sells units through online retailers. 

After confirming the availability of this technology in the Valley, the feasibility of reducing 

current NOx limits for instantaneous water heaters to the 20 ppmv limit enforced in 

SCAQMD and BAAQMD was explored. 

Potential Emissions Reductions by Reducing Instantaneous Water Heater NOx 

Limit 

For purposes of these calculations, the following assumptions were made: 

1. A 0.22 capacity factor was assumed based on South Coast Rule 1146.2 

information. 

2. An average rating was applied to the two size categories since the number of 

units is assumed to be distributed evenly. Therefore, the average rating is 0.238 

MMBtu/hr for units in this size range. 

3. The current emissions rate is based on the current rule requirement of 55 ppmv 

(0.068 lb NOx/MMBtu). 

4. Since instantaneous water heaters heat water only when needed, it was 

assumed that each household would utilize the unit for an average of 3 hours per 

day. 

Potential Emissions at 55 ppmv 

Emissions1 = (average rating) x (emission rate) x (capacity factor) x (hours/day) 

 x (ton/lb) 

Emissions1 = (0.238 MMBtu/hr) x (0.068 lb NOx/MMBtu) x (0.22) x (3 hr/day) x (1 

ton/2,000 lb) 

Emissions1 = 5.34 x 10-6 tons of NOx/day = 0.0019 tons of NOx/year 

Potential Emissions at 20 ppmv 

Emissions2 = (average rating) x (emission rate) x (capacity factor) x (hours/day) 

 x (ton/lb) 

Emissions2 = (0.238 MMBtu/hr) x (0.024 lb NOx/MMBtu) x (0.22) x (3 hr/day) x 

(1 ton/2,000 lb) 

Emissions2 = 1.88 x 10-6 tons NOx/day = 0.0007 tons of NOx/year 

Emissions Reduction = 0.0019 – 0.0007 

Emissions Reduction = 0.0012 tons NOx/year 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-23 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Cost Effectiveness of Reducing the Instantaneous Water Heater Limit 

BAAQMD found that water heaters in the size range of 0.075 through 0.4 MMBtu/hr 

vary in cost from $2,500 to $10,000 plus installation. The additional cost for low-NOx 

water heaters to achieve 20 ppmv was estimated to be $200 per unit. The following 

assumptions were made in the cost effectiveness calculations:

1. Cost differential between a 55 ppmv and 20 ppmv unit was assumed to be $200. 

2. Lifetime of an instantaneous water heater is 10 years at 10% interest. To 

account for this, the annualized capital equipment cost will be calculated by 

multiplying the total capital cost by the capital recovery factor of 0.1627. 

Annual Cost = (cost differential) x 0.1627 

Annual Cost = ($200) x 0.1627 

Annual Cost = $32.54/year 

Cost Effectiveness = Annual Cost / Annual Emissions Reduction 

Cost Effectiveness = ($32.54/year) / (0.0012 tons of NOx/year) 

Cost Effectiveness = $27,117/ton of NOx 

Although the cost effectiveness for a 20 ppmv instantaneous water heater is slightly 

above the BACT cost effectiveness threshold for NOx reductions ($24,500/ton of NOx), 

the cost of the low-NOx unit is at most an extra $200 per household. This cost would 

not be incurred by a specific facility or operator and it represents a small fraction of the 

total cost of the unit that is estimated to be $2,500-$10,000. Also, with an estimated 

lifetime of at least 10 years for these units, the extra $200 would be spread out over a 

10 year period. Therefore, amending Rule 4308 to lower the limit for instantaneous 

water heaters is recommended. 

Mobile Home Exemption 

The possibility of removing the exemption for water heaters used in mobile homes from 

Rule 4308 was explored as a potential opportunity that could result in gradual emission 

reductions as existing higher emitting water heaters are replaced by newer low-NOx 

models. However, as discussed above, other air districts do not regulate mobile home 

water heaters within the size range of Rule 4308. In addition, after researching the size 

of mobile home water heaters, it was found that mobile home water heaters are not 

available in the 0.075-2.0 MMBtu/hr size range. Four mobile home retailers and three 

mobile home manufacturers were contacted to inquire about the size of mobile home 

water heaters. All seven contacts stated that the average size of a mobile home water 

heater is 30-40 gallons whereas a 0.075 MMBtu/hr water heater is approximately 80 

gallons. One manufacturer and one retailer stated that 50 gallon mobile home water 

heaters are available but rarely used. If the exemption for mobile home water heaters in 

Rule 4308 were to be removed, it would not result in any additional emissions 

reductions since units do not exist in this size range. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-24 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Recreational Vehicle Exemption 

The potential opportunity to reduce emissions by removing the exemption for 

recreational vehicles (RVs), per EPA’s suggestion in the 2011 TSD for the approval of 

the 2009 amendments to this rule, was explored. While the EPA TSD for Rule 4308 

included this recommendation, the recommendation is not a RACT requirement as 

demonstrated by EPA’s approval of the rule into the State Implementation Plan (SIP) as 

RACT. 

During the last rule-amending project, stakeholder input was received indicating that 

there are very few units in RVs that fall under the size category subject to this rule that 

also run on Public Utilities Commission (PUC) quality natural gas. As noted in the 2009 

staff report, most units in RVs are 12 gallons, which is smaller than the 80 gallon size of 

a typical 0.075 MMBtu/hr unit7

. Also, RV units are typically not used on a frequent basis 

and thus are small contributors to the NOx emissions of this source category. Air 

Districts such as SCAQMD and BAAQMD include this exemption in their rules. 

Removing this exemption would result in little to no emissions reductions because of the 

lack of availability of these units and the intermittent use of units in RVs. Due to the lack 

of potential emission reductions, there is no recommendation for amending this rule to 

remove this exemption. 

Risk-based Strategy Analysis 

The emissions from units subject to Rule 4308 contribute 1.4% of average winter NOx, 

4.9% of average winter SOx, and 1.1% of average winter PM2.5 emitted from stationary 

and area sources in the 2012 emission inventory. These units are primarily fired on 

PUC-quality natural gas, which is generally considered a clean burning fuel with low 

SOx and PM emissions. Overall, Rule 4308 has significantly reduced NOx and SOx 

emissions from these units and has assisted in reducing PM2.5 concentrations through 

reductions of these key precursors. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4308. 

Regulatory Action 

District analysis identified low-NOx instantaneous water heaters between 0.075-0.4 

MMBtu/hr as an opportunity to reduce emissions from this source category. Units 

between 0.075-0.4 MMBtu/hr that meet a NOx emissions limit of 20 ppmv are readily 

available in the Valley at an additional cost of $100-$200 per unit. The District 

recommends amending Rule 4308 to lower the emissions limit of these units from 55 

ppmv to 20 ppmv of NOx. 

 

7

 Linebach, Katy. (2009). Final Staff Report for Amendments to Rule 4308 (Boilers, Steam Generators, and Process 

Heaters—0.075 MMBtu/hr to less than 2.0 MMBtu/hr). Fresno, CA: San Joaquin Valley Air Pollution Control District. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-25 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Incentive Action 

Boilers, steam generators, and process heaters subject to Rule 4308 are regulated units 

that have already implemented controls to significantly reduce NOx emissions; as such, 

opportunities for incentive programs are minimal. There are no recommendations for 

incentive actions at this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for units 

subject to Rule 4308. Through its Technology Advancement Program, the District will 

continue to seek potential feasible and low-cost technologies that may provide for 

additional emission reduction opportunities in this category. 

Policy Initiatives 

The District’s current legislative platform includes support for the increased 

development and use of cleaner-burning fuels. The recommendation is to continue 

supporting the current legislative platform but there are no recommendations for new 

policy initiatives at this time. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. The District does not have recommendations for new education and outreach 

efforts for these sources. The District will continue to work closely with affected sources 

to ensure successful compliance. 

 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-26 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.1.4 Rule 4309 Dryers, Dehydrators, and Ovens 

Source Category 

Rule 4309 is applicable to any dryer, dehydrator, or oven that is fired on gaseous fuel, 

liquid fuel, or is fired on gaseous and liquid fuel sequentially, and the total rated heat 

input for the unit is 5.0 million British thermal units per hour (5.0 MMBtu/hr) or greater. 

The purpose of this rule is to limit NOx and carbon monoxide (CO) emissions from 

these units, which result from the combustion of fuel in the burners. The rule enforces 

NOx emission limits between 3.5-12 ppmv for four categories of equipment, achieving 

approximately 34% control of total NOx emissions. 

Rule 4309 was adopted on December 15, 2005 and has not been amended. EPA 

finalized approval of Rule 4309 on May 30, 2007 and deemed this rule as being at least 

as stringent as established RACT requirements. 

Emission Inventory 

Pollutant

2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.67 0.68 0.72 0.74 0.76 0.78 0.80 0.82

NOx 0.20 0.17 0.18 0.19 0.19 0.20 0.20 0.21

SOx 0.39 0.40 0.42 0.43 0.44 0.45 0.47 0.48

Winter Average - Tons per day

PM2.5 0.65 0.65 0.69 0.71 0.73 0.75 0.77 0.78

NOx 0.18 0.15 0.16 0.16 0.17 0.17 0.18 0.18

SOx 0.32 0.32 0.34 0.35 0.36 0.37 0.38 0.39

Regulatory Evaluation 

How does District Rule 4309 compare with federal rules and regulations? 

Rule 4309 is equivalent to the applicable federal standards and guidelines. Rule 4309 

is as stringent as the federal Alternative Control Techniques (ACT) (EPA –453/R-94-004 

“Emissions from Cement Manufacturing”, updated September 2000), as determined in 

the 2005 Rule Consistency Analysis for Rule 4309. Federal requirements such as New 

Source Performance Standards (NSPS), National Emission Standards for Hazardous 

Air Pollutants (NESHAP), and Maximum Achievable Control Technology (MACT) 

requirements are not applicable to this source category; additionally, there are no EPA 

Control Techniques Guidelines (CTG) or Best Available Control Technology (BACT) 

requirements listed for this category. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-27 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

How does District Rule 4309 compare to rules in other air districts? 

When comparing Rule 4309 to other California air districts’ rules for similar sources, no 

other air district was found to contain a rule for dryers, dehydrators, and ovens. 

BAAQMD (Regulation 12 Rule 3—Asphalt Air Blowing), SCAQMD (Rule 470—Asphalt 

Air Blowing), and VCAPCD (Rule 69—Asphalt Air Blowing) only regulate asphalt plants 

and Rule 4309 is more stringent than the requirements in all three rules. SMAQMD 

does not have an analogous rule to Rule 4309. 

Rule 4309 was also compared to SCAQMD and BAAQMD BACT requirements. Since 

SCAQMD and BAAQMD only regulate asphalt plants, the only differences between 

District rule requirements and other air districts’ BACT requirements apply to 

requirements for asphalt facilities. 

BACT comparisons revealed that the use of Public Utilities Commission (PUC) quality 

natural gas fuel was part of the NOx and SOx BACT requirements for asphalt plants in 

the District, BAAQMD, and SCAQMD. In addition, the NOx limit for asphalt plants in 

BAAQMD BACT guidelines is 3.9 ppmv at an oxygen correction factor of 19% by 

volume of O2 (19% O2), whereas Rule 4309 has a limit of 4.3 ppmv for gaseous fuel 

and 12 ppmv for liquid fuel @ 19% O2. These potential opportunities were evaluated 

and have been included in a discussion of the feasibility of both requirements in the 

Asphalt Plants section of the emission reduction opportunities discussion. 

As previously stated, this rule satisfies RACT requirements; any additional requirements 

would be more stringent and go beyond RACT. In addition to being one of the most 

stringent rules in the nation for this source category, any new unit brought to the Valley, 

as well as any major modifications to existing units, would trigger Best Available Control 

Technology (BACT) requirements. Subsequently, these new or modified units would be 

required to use technology and control emissions beyond those established as RACT 

and implement the best available emission controls, as required by District Rule 2201 

(New and Modified Stationary Source Review Rule). 

Emission Reduction Opportunities 

The adoption of Rule 4309 has considerably reduced NOx and PM emissions from this 

source category. The emissions inventory for NOx from dryers, dehydrators, and ovens 

has dropped from 1.93 tpd in 2005 to 0.17 tpd in 2012. Although this source category 

had a relatively small emissions inventory prior to the adoption of Rule 4309, 

stakeholders have installed control equipment and modified their operations 

considerably to reduce emissions to ultra-low levels. Given the significant effort already 

made to reduce emissions from this source category, there are little remaining 

opportunities for obtaining additional emissions reductions. For the sake of 

thoroughness, the possibility of further reducing emissions from these units is evaluated 

in the following discussion. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-28 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Asphalt Plants 

As mentioned above, PUC-quality natural gas fuel is part of the BACT requirements for 

asphalt plants for the District, BAAQMD, and SCAQMD. There are currently 11 asphalt 

plants in the Valley that do not utilize PUC-quality natural gas because some facilities 

are physically too far removed from natural gas lines to use natural gas. Nine of these 

asphalt plants use LPG fuel or propane to comply with the same gaseous fuel fired limit 

as PUC-quality natural gas-fired facilities. The other two facilities utilize diesel gas; 

however, neither facility operates full time and their combined NOx emissions are less 

than 2 tons per year. Therefore, requiring natural gas for all asphalt facilities is not a 

feasible opportunity that would generate significant emission reduction benefit. 

The potential opportunity for emission reductions by lowering the emissions limits for 

asphalt plants from the current NOx limits of 4.3 ppmv (gaseous fuel) and 12 ppmv 

(liquid fuel) to make them closer or equivalent to the BAAQMD BACT limit of 3.9 ppmv 

@ 19% O2 was also evaluated. To meet this limit, operators would need to install lowNOx burners or modify existing burners to comply with lower limits; however, all of the 

asphalt plants have already installed new low-NOx burners or modified their units to 

meet the 4.3 ppmv @ 19% O2 and 12 ppmv @ 19% O2 emissions limits in Rule 4309. 

Based on District permit records, a good portion of the asphalt units fired on gaseous 

fuel would be in compliance with a 3.9 ppmv @ 19% O2 NOx limit. However, reducing 

the limit to 3.9 ppmv @ 19% O2 would reduce the margin of compliance the facility has, 

and would make it more difficult for the facility to show continued compliance. In 

addition, reducing the limit from 4.3 ppmv to 3.9 ppmv would be an administrative 

change in nature, since it would not require any additional control equipment or changes 

in operating techniques or practices to comply, and it would not generate additional 

emissions reductions from these units. 

A higher NOx limit is required for the liquid fuel fired facilities due to the characteristics 

of liquid fuels. In BAAQMD’s BACT guideline for hot mix asphalt facilities, there is a 

clause that states, “For remote locations where natural gas is not available, liquefied 

petroleum gas may be permitted up to 38 ppmvd NOx @ 15% O2 and fuel oil < 0.05 wt. 

% sulfur may be permitted up to 55 ppmvd NOx @ 15% O2.” This equates to 12.24 

ppmv @ 19% O2 for liquefied petroleum gas and 17.73 ppmv @ 19% O2 for fuel oil. 

The District’s Permits department enforces a limit of 4.3 ppmv @ 19% O2 for liquefied 

petroleum gas and 12 ppmv for other liquid fuels. Therefore, the District’s requirements 

are more stringent than both limits in the BAAQMD BACT guideline. 

Dehydrators 

Rule 4309 requires dehydrators be fired on PUC-quality natural gas. The potential 

opportunity to further reduce emissions by requiring the use of low-NOx burners during 

the 2005 rule adoption was evaluated; however, this option was deemed infeasible due 

to the potential negative effects on product quality. Additionally, enforcing the 

emissions limits was found to be potentially infeasible because monitoring and source 

testing of dehydrators is difficult to perform, if not impossible. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-29 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

In the 2005 staff report for Rule 4309, a cost effectiveness analysis was conducted that 

compared the use of PUC-quality natural gas and the installation of low-NOx burners on 

dehydrators. 

The costs in the staff report included not only replacements of all of the burners in the 

current units with low-NOx burners, but also an additional dryer that would need to be 

installed to keep a facility’s throughput the same. This evaluation yielded the following 

results: 

• Cost ($/year): $2,885,925 

• Potential Emissions Reductions (tons per year): 58.57 

• Cost Effectiveness ($/ton): $49,273 

At a cost effectiveness of approximately $50,000/ton of NOx reduced, requiring lowNOx burners for dehydrators is not a cost effective option for dehydrators in the Valley. 

If the figure was adjusted to today’s value, low-NOx burners would be even less cost 

effective. 

Dryers 

The potential opportunity to add a requirement for the use of dust collection devices, 

such as baghouses, was considered for the reduction of PM2.5. Through the District’s 

New Source Review Rule (Rule 2201), dust collection devices are already in place in 

the permit requirements for units that create PM emissions from handling the products 

they are drying. These facilities install baghouses or cyclones because they do not 

want to blow their product out of their stack. While baghouses can foster PM2.5 

reductions, cyclones are generally not as effective in removing fine particulate matter.8

The potential installation of baghouses on dryers was researched. However, it is 

technologically infeasible to install a baghouse for some of the dryers subject to Rule 

4309. The purpose of a dryer is to remove moisture from a product, which means that 

the exhaust from dryers have a high humidity. Baghouses can have problems with high 

humidity exhaust streams because the bags become caked. The air stream would have 

to be dried somehow before entering the baghouse. As a result, this is not a feasible 

opportunity at this time. 

The potential opportunity to reduce emissions by removing the exemption for column 

dryers and dryers with no stack and one or more sides open to the atmosphere was 

also considered. However, as was true during the 2005 rule adoption, compliance with 

the proposed limits would be difficult to determine reliably given the design of these 

units. Column dryers have large fans to move the warm air through the material and air 

escapes through screens that cover the side of the dryer. Similarly, dryers with no stack 

and at least one side open deal with air escape, which makes monitoring and testing 

emissions difficult, if not impossible. Since source testing of these types of dryers is 

 

8

 Northeast States for Coordinated Air Use Management. (November 2008) Applicability and Feasibility of NOx, 

SO2, and PM Emissions Control Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-30 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

difficult due to the fact that there is not a stack where all emissions are exhausted, this 

is not a technologically feasible opportunity at this time. 

At this time, the District’s analysis indicates that there are no feasible opportunities for 

additional emission reduction regulatory strategies for this source category. 

Risk-based Strategy Analysis 

The emissions from units subject to Rule 4309 contribute 3.9% of average winter SOx 

and 1.2% of average winter PM2.5 emitted from stationary and area sources in the 

2012 emission inventory. These units are primarily fired on PUC-quality natural gas, 

which is generally considered a clean burning fuel with low SOx and PM emissions. 

Overall, Rule 4309 has significantly reduced NOx and SOx emissions from these units 

and has assisted in reducing PM2.5 concentrations through reductions of these key 

precursors. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4309. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4309. 

Incentive Action 

Dryers, dehydrators, and ovens subject to Rule 4309 are regulated units, which makes 

the opportunities for incentive programs minimal. There are no recommendations for 

incentive actions at this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for units 

subject to Rule 4309. Through its Technology Advancement Program, the District will 

continue to seek potential feasible and low-cost technologies that may provide for 

additional emission reduction opportunities in this category. 

Policy Initiatives 

The District’s current legislative platform includes support for the increased 

development and use of cleaner-burning fuels. The recommendation is to continue 

supporting the current legislative platform but there are no recommendations for new 

policy initiatives at this time because the rule already requires effective emission control 

technologies. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-31 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for new education and outreach efforts for 

these sources. The District will continue to work closely with affected sources to ensure 

successful compliance. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-32 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.1.5 Rule 4320 Advanced Emission Reduction Options for Boilers, 

Steam Generators, and Process Heaters Greater than 5.0 

MMBtu/hr 

Source Category 

This rule applies to any gaseous fuel or liquid fuel fired boiler, steam generator, or 

process heater with a total rated heat input greater than 5 million British thermal units 

per hour (MMBtu/hr). The purpose of Rule 4320 is to limit NOx and carbon monoxide 

(CO) emissions from boilers, steam generators, and process heaters of this size range. 

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

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

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

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

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

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

amended twice. 

The most recent rule amendment in October 2008 was initially proposed to lower the 

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

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

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

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

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

Rule 4306 have undergone several generations of NOx controls, and consequently, 

certain applications of SCR may not be feasible due cost effectiveness and/or 

technological infeasibility because of physical limitations. Therefore, the lower NOx 

limits were included in new Rule 4320 and an option was provided in the rule that allows 

for the payment of an annual emissions fee based on total actual emissions, rather than 

installation of additional NOx controls. These fees are used by the District to achieve 

cost effective NOx reductions through District incentive programs, the District’s 

Technology Advancement Program, and other routes. The previous versions of Rule 

4305 and 4306 combined with the implementation of Rule 4320 results in approximately 

96% control of NOx emissions from this source category, once all of the compliance 

deadlines are in effect in 2014. EPA finalized approval for Rule 4320 on March 25, 

2011 and deemed this rule as being at least as stringent as established RACT 

requirements. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-33 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day 

PM2.5 1.46 1.31 1.26 1.24 1.22 1.20 1.18 1.16

NOx 2.76 1.49 1.34 1.25 1.21 1.17 1.14 1.10

SOx 1.53 0.87 0.35 0.35 0.34 0.34 0.33 0.32

Winter Average - Tons per day 

PM2.5 1.43 1.28 1.24 1.22 1.20 1.18 1.16 1.14

NOx 2.66 1.43 1.29 1.20 1.16 1.13 1.09 1.06

SOx 1.49 0.85 0.35 0.34 0.34 0.33 0.32 0.32

Regulatory Evaluation 

How does District Rule 4320 compare with federal rules and regulations? 

Rule 4320 is equivalent to the applicable federal standards and guidelines. Rule 4320 

is as stringent as the EPA Best Available Control Technology (BACT) requirements, 

Alternative Control Techniques (ACT) (EPA –453/R-94-022 “Alternative Control 

Techniques Document – NOx Emissions from Industrial/Commercial/Institutional 

Boilers”, dated March 1994 and EPA – 452/R-93-008 “Alternative Control Techniques 

Document—NOx Emissions from Utility Boilers”, dated March 1994), New Source 

Performance Standards (NSPS) (40 CFR 60 Subpart D (Standards of Performance for 

Fossil-Fuel Fired Steam Generators for Which Construction Commenced After August 

17, 1971) and 40 CFR 60 Subpart Dc (Standards of Performance for Small IndustrialCommercial-Institutional Steam Generating Units)), and Maximum Achievable Control 

Technology (MACT) (40 CFR 63 Subpart DDDDD (NESHAP for Industrial, Commercial, 

and Institutional Boilers and Process Heaters)) requirements. There are no EPA 

Control Techniques Guidelines (CTGs) for this category. 

How does District Rule 4320 compare to rules in other air districts? 

Rule 4320 was compared to other California air districts’ rules for similar sources and 

was found to be at least as stringent as the analogous rules for SCAQMD (Rule 1146—

Emissions of Nitrogen from Industrial, Institutional, and Commercial Boilers, Steam 

Generators, and Process Heaters), BAAQMD (Regulation 9 Rule 7—Nitrogen Oxides 

and Carbon Monoxide from Industrial, Institutional and Commercial Boilers, Steam 

Generators and Process Heaters and Regulation 9 Rule 10—Nitrogen Oxides and 

Carbon Monoxide from Boilers, Steam Generators and Process Heaters in Petroleum 

Refineries), SMAQMD (Rule 411—NOx from Boilers, Process Heaters and Steam 

Generators), and VCAPCD (Rule 74.15—Boilers, Steam Generators and Process 

Heaters). Rule 4320 also meets or exceeds the established BACT requirements for 

these units at BAAQMD and SCAQMD. Rule 4320 currently dictates SJVAPCD BACT 

requirements for Valley sources. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-34 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Emission Reduction Opportunities 

Over the years, the District has adopted numerous generations of rules and rule 

amendments for boilers greater than 5 MMBtu/hr that have significantly reduced NOx 

and PM emissions from this source category. The emissions inventory for NOx from 

these boilers has dropped from 40.2 tpd in 1993 to 1.49 tpd in 2012. As part of these 

regulatory efforts, hundreds of boilers in the Valley have been equipped with the best 

available NOx and PM control technologies. Additional emissions reductions are 

forthcoming with existing Rule 4320 as more compliance dates approach in the next 

couple of years. Given the significant effort already made to reduce emissions from this 

source category, there are little remaining opportunities for obtaining additional 

emissions reductions. For thoroughness, the possibility of further reducing emissions 

from boilers greater than 5 MMBtu/hr is evaluated in the following discussion. 

Low Temperature Oxidation 

Emerging technologies that may have the potential to reduce emissions were 

researched. A Low Temperature Oxidation (LTO) System was installed at a dairy in the 

SCAQMD and was able to reach NOx limits between 1.0 - 3.2 ppmv for loads 4.1 - 13 

MMBtu/hr. The LTO system utilizes ozone to oxidize and control various pollutants, 

including NOx. According to the SCAQMD BACT database information, capital and 

installation costs ranged from $360,000 - $400,000 for the LTO system when it was 

installed in 19979

. Installation within the South Coast region was heavily subsidized 

with government funding and the installation costs appear cost prohibitive for an 

installation that is not subsidized. In addition, the LTO system is classified as “Other 

Technologies” in the SCAQMD BACT guidelines, which means that the technology has 

not met the achieved in practice (AIP) criteria of six months of continuous operation at a 

minimum of 50% operating capacity and does not qualify as the lowest achievable 

emission rate (LAER). Since the technology has not been achieved in practice and cost 

prohibitive without significant subsidies, this is not a feasible opportunity at this time. 

EMx 

The potential for emissions reductions through EMx, the second generation of the 

SCONOx technology that is a post-combustion control that reduces NOx, SOx, CO, and 

volatile organic compound (VOC) emissions, was researched. This technology has not 

been AIP in the District and there is no available data that indicates that SCONOx or 

EMx has been installed on boilers even though the manufacturer’s website states that 

the technology is transferrable to industrial boilers. Based on research of the best 

available controls from EPA and other air districts, the SCONOx and EMx systems have 

only been utilized by power plants for control of turbine emissions. In fact, cost 

effectiveness analyses conducted by the District for the installation of SCONOx/EMx 

units on large power plant turbine installations within the San Joaquin Valley have been 

found to not be cost effective. Given the high cost effectiveness demonstrated for 

turbines and lack of demonstrated practice with boilers, the District does not expect this 

technology to be feasible or cost effective for reducing emissions from this category. 

 

9

 (2012). SCAQMD Best Available Control Technology (BACT) Database. Diamond Bar, CA: South Coast Air Quality 

Management District. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-35 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

PM2.5 Limits for Alternative Fuels 

The majority of boilers (>5 MMBtu/hr) in the Valley combust Public Utilities Commission 

(PUC) quality natural gas, which contains a very low sulfur content and inherently has 

low emissions. Few boilers in the Valley use alternative fuels for their combustion 

processes. Alternative fuels include digester gas, produced gas, and liquid fuel. Units 

fired on digester gas or produced gas are already required to use inlet gas scrubbers to 

meet District rule requirements. Current rule language requires that liquid fuel shall be 

used only during a PUC-quality natural gas curtailment period provided it contains no 

more than 15 ppm sulfur. While the use of liquid fuel is strictly limited, the feasibility of 

reducing PM emissions through adding PM2.5 limits for units using liquid fuel was 

explored as part of the District’s comprehensive control measure evaluation. 

There are 62 units that utilize liquid fuel in the Valley (>5 MMBtu/hr) with a combined 

emissions inventory of approximately 0.02 tons per year of total PM. The low emissions 

inventory is attributed to the fact that these units either utilize liquid fuel as a backup if 

there is a natural gas curtailment or are minimally operated units. The following three 

technologies were researched as potential opportunities to reduce PM emissions: 

baghouses, electrostatic precipitators (ESPs), and wet scrubbers. Baghouses control 

total PM and PM2.5 emissions by 90-99%; ESPs control total PM and PM2.5 emissions 

by 90-99%; and wet scrubbers control large particulates (>PM5) by 99% and PM2.5 

emissions by approximately 50%10. Currently, there are a few crude oil-fired or field 

gas-fired steam generators operating in crude oil production facilities that are required 

by their permits to operate SOx scrubbers and ESPs. However, baghouses are 

typically not used with liquid-fired boilers due to the potential clogging of the baghouse11

and are therefore not a recommended technology due to infeasibility and safety issues. 

PM Potential Emissions Reductions for an ESP and Scrubber 

For the purposes of these calculations, the following assumptions were made: 

1. For simplicity, the analysis will evaluate the cost effectiveness of these 

technologies for total PM reductions from liquid fuel fired units. 

2. The PM control efficiency of an ESP is 99%. 

3. The PM control efficiency of a scrubber is 99%. 

Potential Emissions ReductionsESP = (Total PM Emissions) x (Control Efficiency) 

Potential Emissions ReductionESP = 0.02 tons/year X 0.99 

Potential Emissions ReductionESP = 0.0198 tons/ year (tpy) 

Potential Emissions Reductions scrubber = (Total PM Emissions) x (Control Efficiency) 

Potential Emissions Reduction scrubber = 0.02 tons/year X 0.99 

Potential Emissions Reduction scrubber = 0.0198 tons/ year (tpy) 

 

10 Northeast States for Coordinated Air Use Management. (November 2008) Applicability and Feasibility of NOx, 

SO2, and PM Emissions Control Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. 

11 Northeast States for Coordinated Air Use Management. (November 2008) Applicability and Feasibility of NOx, 

SO2, and PM Emissions Control Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-36 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Annualized Cost of an ESP and Wet Scrubber 

The capital cost for the installation of an ESP for a 1-5 MMBtu/hr boiler ranges from 

$90,000 - $100,000 and the annual maintenance cost is $1,000-$2,000.12 For the wet 

scrubber system, EPA estimated the annualized cost at $5,300-$102,000 per sm3/sec 

at an average air flow rate of 0.7- 47 sm3/sec.13 The following assumptions in the cost 

effectiveness calculations: 

1. The capital cost of an ESP for a 5 MMBtu/hr boiler is assumed to be $100,000. 

2. The annual maintenance cost of an ESP for a 5 MMBtu/hr boiler is assumed to 

be $2,000. 

3. The annualized cost of a wet scrubber system is assumed to be the median of 

the range above ($53,650 per sm3/sec). 

4. The average air flow rate for a wet scrubber system is assumed to be the median 

of the range above (23.85 sm3/sec). 

5. The total capital and maintenance cost of an ESP will be calculated by 

multiplying the cost of 1 unit by the total number of units. 

6. The total annualized cost of a wet scrubber will be calculated by multiplying the 

annualized cost of 1 unit by the total number of units. 

7. Lifetime of the ESP is 10 years at 10% interest. To account for this, the 

annualized capital cost will be calculated by multiplying the total capital cost by 

the capital recovery factor of 0.1627 and adding the annual maintenance costs. 

Annual CostESP = (Total Capital Cost) x (0.1627) + (Annual Maintenance Cost x 62) 

Annual CostESP = ($100,000 x 62) x (0.1627) + ($2,000 x 62) 

Annual CostESP = $1,132,740/year 

Annual Costscrubber = (Annualized Cost of 1 unit) x (Number of Units) x 

(Average Flow Rate) 

Annual Costscrubber = ($53,650/ sm3

/sec) x (62) x (23.85 sm3/sec) 

Annual Costscrubber = $79,332,255 year 

Cost Effectiveness of an ESP and Wet Scrubber 

Cost Effectiveness = Annual Cost / Annual Emissions Reductions 

Cost EffectivenessESP = ($1,132,740/year) / (0.0198 tons/ year) 

Cost EffectivenessESP = $57,209,091/ton of PM 

Cost Effectivenessscrubber = ($79,332,255/year) / (0.0198 tons/ year) 

Cost Effectivenessscrubber = $4,006,679,545/ton of PM 

 

12 Catherine Roberts. (March 2009) Information on Air Pollution Control Technology for Woody Biomass Boilers. 

Environmental Protection Agency Office of Air Quality Planning and Standards and Northeast States for Coordinated 

Air Use Management. 

13 (2002). Air Pollution Control Technology Fact Sheet: Spray-Chamber/Spray-Tower Wet Scrubber. Environmental 

Protection Agency.
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-37 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

As illustrated above, neither PM control technology is a cost effective option for this 

source category. The cost of the ESP technology does not include costs of retrofitting 

equipment and/or the facility or compliance monitoring costs, which would drive the cost 

effectiveness up even more. In addition, the annualized costs provided by EPA for the 

wet scrubber system are in 2002 dollars, which means the value above would be even 

greater if it were adjusted to 2012 dollars. 

 

At this time, the District’s analysis indicates that there are no feasible opportunities for 

additional emission reduction regulatory strategies for this source category. 

Risk-based Strategy Analysis 

The emissions from units subject to Rule 4320 contribute 3.0% of average winter NOx, 

10.3% of average winter SOx, and 2.3% of average winter PM2.5 emitted from 

stationary and area sources in the 2012 emission inventory. These units are also fired 

on PUC-quality natural gas, which is generally considered a clean burning fuel with low 

SOx and PM emissions. Overall, Rule 4320 has significantly reduced NOx and SOx 

emissions from these units and has assisted in reducing PM2.5 concentrations through 

reductions of these key precursors. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4320.

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4320. 

Incentive Action 

Boilers subject to Rule 4320 are regulated units that have been subject to several 

generations of regulations; as such, the opportunities for incentive programs are 

minimal. There are no recommendations for incentive actions at this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for units 

subject to Rule 4320. Through its Technology Advancement Program, the District will 

continue to seek potential feasible and low-cost technologies that may provide for 

additional emission reduction opportunities in this category. 

Policy Initiatives 

The District’s current legislative platform includes support for the increased 

development and use of cleaner-burning fuels. The recommendation is to continue 

supporting the current legislative platform but there are no recommendations for new 

policy initiatives at this time because the rule already requires the most effective 

emission control technologies.
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-38 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. The District does not have recommendations for new education and outreach 

efforts for these sources. The District will continue to work closely with affected sources 

to ensure successful compliance. 

 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-39 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.1.6 Rule 4352 Solid Fuel Fired Boilers, Steam Generators, and 

Process Heaters 

Source Category 

The purpose of Rule 4352 is to limit NOx and carbon monoxide (CO) emissions from 

any boiler, steam generator or process heater fired on solid fuel. Prior to September 14, 

1994 solid fuel fired units were exempt from the requirements of District Rule 4305. The 

adoption of Rule 4352 established NOx limits of 200 parts per million volume (ppmv) for 

municipal solid waste facilities (MSW), 0.35 pounds per million British thermal units per 

hour (lb/MMBtu) for biomass facilities, and 0.20 Ib/MMBtu for all other solid fuel fired 

units. Since its adoption, the rule has been amended three times. The recent 

December 2011 amendments strengthened the rule by lowering NOx emissions limits 

for all three source categories. However, no emissions reductions were quantified 

because the rule amendments were meant to satisfy EPA RACT requirements and all 

units were determined to be operating at the proposed emission limits. EPA finalized 

approval of Rule 4352 on November 6, 2012 and deemed this rule as being at least as 

stringent as established RACT requirements. 

While previous rule-amending projects for Rule 4352 have not quantified specific 

emissions reductions, the increasing presence of biomass facilities in the Valley is 

fostering emissions reductions. As an energy source, biomass can either be used 

directly or converted into other energy products such as biofuel. Biomass facilities in 

the Valley reduce the amount of pollutants created by open burning practices and the 

landfilling of potential biofuels such as agricultural materials, and urban and forest wood 

waste products by utilizing these materials. To date, agricultural burning has been 

reduced by 70% and approximately 90% of agricultural burning is projected to be 

eliminated in the coming years. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.54 0.64 0.69 0.74 0.79 0.81 0.85 0.87

NOx 3.98 4.38 4.59 4.77 4.97 5.07 5.18 5.26

SOx 1.34 1.25 1.25 1.28 1.32 1.36 1.38 1.40

Winter Average - Tons per day

PM2.5 0.56 0.67 0.72 0.76 0.81 0.84 0.87 0.90

NOx 4.05 4.46 4.67 4.86 5.06 5.16 5.28 5.35

SOx 1.35 1.26 1.27 1.29 1.34 1.37 1.40 1.41

 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-40 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Regulatory Evaluation 

How does District Rule 4352 compare with federal rules and regulations? 

Rule 4352 is equivalent to the applicable federal standards and guidelines. Rule 4352 

is as stringent as the federal Alternative Control Techniques (ACT) (EPA –453/R-94-022 

“Alternative Control Techniques Document – NOx Emissions from 

Industrial/Commercial/Institutional Boilers”, dated March 1994 and EPA – 452/R-93-008 

“Alternative Control Techniques Document—NOx Emissions from Utility Boilers”, dated 

March 1994), New Source Performance Standards (NSPS) (40 CFR 60 Subpart D 

(Standards of Performance for Fossil-Fuel Fired Steam Generators for Which 

Construction Commenced After August 17, 1971) and 40 CFR 60 Subpart Db 

(Standards of Performance for Industrial-Commercial-Institutional Steam Generating 

Units)), and Maximum Achievable Control Technology (MACT) requirements (40 CFR 

63 Subpart DDDDD (NESHAP for Industrial, Commercial, and Institutional Boilers and 

Process Heaters)). Additionally, there are no EPA Control Techniques Guidelines 

(CTG) listed for this category. 

Rule 4352 was also compared to EPA Best Available Control Technology (BACT) 

standards and it was noted that Selective Catalytic Reduction (SCR) systems, 

scrubbers, electrostatic precipitators, and baghouses are amongst the technologies 

considered to be BACT for this source category. See the Emission Reduction 

Opportunities section for a discussion regarding these technologies. 

 

How does District Rule 4352 compare to rules in other air districts? 

Rule 4352 was compared to several other air districts’ rules. Per the 2011 Staff 

Report14, it was determined there are currently no solid fuel fired units subject to the 

NOx emission limits in the following rules in other air districts: 

• BAAQMD Regulation 9 Rule 7 (Nitrogen Oxides and Carbon Monoxide from 

Industrial, Institutional and Commercial Boilers, Steam Generators and Process 

Heaters), 

• BAAQMD Regulation 9 Rule 11 (Nitrogen Oxides and Carbon Monoxide from 

Electric Power Generating Steam Boilers), 

• VCAPCD Rule 74.15 (Boilers, Steam Generators and Process Heaters), 

• SCAQMD Rule 1146 (Emissions of Oxides of Nitrogen from Industrial, 

Institutional, and Commercial Boilers, Steam Generators and Process Heaters), 

• SMAQMD Rule 411 (NOx from Boilers, Process Heaters and Steam 

Generators). 

 

 

14 Corless, N., DeMaris, F. (2011). Revised Proposed Amendments to Rule 4352 (Solid Fuel Fired Boilers, Steam 

Generators and Process Heaters). Fresno, CA: San Joaquin Valley Air Pollution Control District. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-41 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Units subject to District Rule 4352 would be exempt from the following rules in other air 

districts: 

• VCAPCD Rule 59 (Electrical Power Generating Equipment—Oxides of Nitrogen 

Emissions), 

• VCAPCD Rule 74.15 (Boilers, Steam Generators and Process Heaters), and 

• SCAQMD Rule 1135 (Emissions of Oxide of Nitrogen from Electric Power 

Generating Systems) exempt sources burning solid fuels. 

In addition to being one of the most stringent rules in the nation for this source category, 

any new unit brought to the Valley, as well as any major modifications to existing units, 

would trigger BACT requirements. Subsequently, these new or modified units would be 

required to use technology and control emissions beyond those established as RACT 

and implement the best available emission controls as required by District Rule 2201 

(New and Modified Stationary Source Review Rule). 

Emission Reduction Opportunities 

Rule 4352 has been amended numerous times making it one of the most stringent rules 

in the country for this source category. Facilities subject to this rule have invested 

millions of dollars to implement innovative control technologies and have significantly 

reduced emissions from solid fuel fired boilers. The increased presence of biomass 

facilities in the Valley, from either new facilities or other solid fuel fired boilers that have 

converted to biomass, continues to significantly reduce NOx and PM emissions from 

open burning practices. Given the significant efforts and investments already made to 

reduce emissions from this source category, there are little remaining feasible 

opportunities for obtaining additional cost effective emissions reductions. For 

thoroughness, the possibility of further reducing emissions from these units was 

evaluated and cost effectiveness analyses were still performed as part of the District’s 

comprehensive control measure evaluation. 

Selective Catalytic Reduction 

When comparing Rule 4352 to EPA and other air districts’ BACT requirements, it was 

noted that SCR systems are considered BACT. A SCR system reduces NOx emissions 

by converting the emissions to water and elemental nitrogen. The staff report for the 

December 2011 amendment of this rule demonstrated that this technology is not cost 

effective as either a retrofit or new system. The following potential emissions reductions 

and cost effectiveness figures were included in the 2011 Staff Report: 

Table D-3 Emissions Reductions and Cost Effectiveness of Solid Fuel Fired 

Boilers by Fuel Type

Fuel Type Baseline 

Emissions 

(tons/yr) 

Controlled 

Emissions 

(tons/yr) 

Emissions 

Reduced 

(tons/yr) 

Adjusted 

Annualized 

Cost ($/yr) 

Cost 

Effectiveness 

($/ton) 

MSW 438 124 314 3,672,939 30,806 

Biomass 337.26 67.46 269.8 14,661,434 54,342 

Other 306.6 61.3 245.3 14,661,434 59,769 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-42 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

While these calculations were based off of a new installation of SCR, a retrofit system 

would include additional expenses and present even higher cost effectiveness figures. 

Controls for Direct PM2.5 Emissions 

The potential opportunity of specifying required controls for direct PM2.5 emissions, per 

EPA’s suggestion in the 2009 and 2012 TSD for the rule, was researched. Three 

technologies were recognized as being able to potentially reduce direct PM2.5 

emissions: electrostatic precipitators (ESPs), baghouses, and cyclones. 

An ESP is a particulate collection device that removes particles from a flowing gas using 

the force of an electrostatic charge with a 90 - 99.9% control efficiency of PM2.5 for 

solid-fuel fired boilers within the 100-500 MMBtu/hr size range of District units15. A 

baghouse, on the other hand, is a technology in which particulates are removed from a 

stream of exhaust gases as the stream passes through a large cloth bag. Baghouses 

have a PM2.5 removal effectiveness of 90-99.9% for solid fuel fired boilers in the size 

range of District units16. Coal and coke-fired units generally use baghouses, but 

biomass boilers usually use ESPs because of the health and safety risk of the burning 

embers causing a fire in the baghouse. However, when cyclones are combined with the 

use of a baghouse, the burning embers are extinguished and allow for the use of a 

baghouse in a biomass facility17. This also reduces acid gases and some PM2.5 

compared to the use of a baghouse alone. 

All of the facilities subject to Rule 4352 have installed either a baghouse or ESP 

particulate matter removal system due to permitting requirements. Since the control 

efficiency ranges for both technologies are equivalent, there are currently no other PM 

controls more effective than current practices. 

Controls for SOx Emissions 

Potential opportunities to reduce SOx emissions from this source category were also 

researched. Most facilities subject to Rule 4352 currently inject limestone into the 

combustion chamber to react with fuel sulfur and produce various sulfate compounds, 

which can then be removed by the ESP or baghouse. This control technology typically 

achieves around 50% control of SOx emissions18; however, the emissions reduced are 

less for a low sulfuric fuel due to the lower concentration of sulfur dioxide (SO2) initially 

in the combustion products. 

 

15 Senior, C., Afonso, R. (January 2009). Applicability and Feasibility of NOx, SO2, and PM Emissions Control 

Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. Northeast States for Coordinated Air Use 

Management. 

16 Senior, C., Afonso, R. (January 2009). Applicability and Feasibility of NOx, SO2, and PM Emissions Control 

Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. Northeast States for Coordinated Air Use 

Management. 

17 Roberts, C. (2009). Information on Air Pollution Control Technology for Woody Biomass Boilers. Northeast States 

for Coordinated Air Use Management and the EPA Office of Air Quality Planning and Standards. 

18 (2001). Technical Advice on Air Pollution Control Technologies for Coal-fired Power Plants. Edmonton, AB: Alberta 

Research Council Inc.
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-43 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Scrubbers are an add-on control technology that can achieve 70-95% control of SOx 

emissions for solid fuel fired boilers19. The only MSW facility in the Valley currently 

utilizes a semi-dry scrubber system to control SOx emissions. Therefore, the District 

calculated the average cost effectiveness of a scrubber system for biomass and 

coal/coke facilities. 

The District conducted a SOx BACT evaluation for a local power generation facility that 

was installing a biomass boiler and determined the capital costs for a wet scrubber 

system are approximately $5.8 million. The annualized capital equipment cost is 

calculated by multiplying the installed equipment cost by the capital recovery factor of 

0.1627. 

Annual Capital Costs (ACcapital) 

ACcapital= $5,800,000 X 0.1627 

ACcapital= $943,660/year 

In addition, this system has additional costs for the sodium hydroxide reagent used in 

the scrubber which are estimated to be an additional $642,000 per year. Thus, the total 

annual cost would be: 

Total Annual Costs (ACtotal) 

ACtotal = Capital Costs + Reagent Costs = ($943,660/year) + ($642,000/year) 

ACtotal = $1,585,660/year 

Cost effectiveness is calculated by dividing the annual cost by the annual emissions 

reductions from District standard emissions. One cost effectiveness analysis was 

conducted for the biomass and coal/coke fired units in the Valley because the four 

coal/coke fired units are fired on biomass part of the time. 

The average SOx emissions limit of these units, based on District Permits SOx 

emissions limits, is 0.044 lb/MMBtu and the average heat input is 341 MMBtu/hr. An 

emissions factor of 0.27 lb/MMbtu at 24 hours per year is assumed to reflect the time 

needed for the startup and shutdown period, when the exhaust temperature is not high 

enough for controls to be fully effective. Therefore, those numbers were utilized to 

calculate annual standard emissions as follows: 

 

 

19 Senior, C., Afonso, R. (January 2009). Applicability and Feasibility of NOx, SO2, and PM Emissions Control 

Technologies for Industrial, Commercial, and Institutional (ICI) Boilers. Northeast States for Coordinated Air Use 

Management. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-44 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Annual Standard Emissions (AEstandard) 

AEstandard = [(0.044 lb/MMBtu) x (341 MMBtu/hour) x (8,760 hour/year)] + [(0.27 

lb/MMBtu) x (24 hour/year) x (341 MMBtu/hr)] 

AEstandard = 133,644.7 lb/year 

Potential emissions, using the technologically feasible emission limit of 0.012 lb/MMBtu 

that is achieved by the use of a wet scrubber system, can be calculated as follows: 

Annual Emissions with Wet Scrubber System (AEscrubber) 

AEscrubber = [(0.012 lb/MMBtu) x (341 MMBtu/hour) x (8,760 hour/year)] + [(0.27 

lb/MMBtu) x (24 hour/year) x (341 MMBtu/hour)] 

AEscrubber = 38,055.6 lb/year 

Therefore, the cost effectiveness would be: 

Cost Effectiveness (CE) 

CE= ($1,585,660/year) ÷ [(133,644.7 lb/year – 38,055.6 lb/year) x (1 ton/2,000 lb)] 

CE = $33,177/ton 

It is important to note that the cost effectiveness analysis above does not reflect the 

costs of additional electricity consumption, additional labor costs, additional solid waste 

disposal, and other operational changes or additions that would be required to comply 

with the lower limit. The option of scrubbers is not a cost effective option, and therefore, 

is not feasible. 

There are no additional technologies available to reduce SOx emissions from solid fuel 

fired units. 

Start-up Periods 

The possibility of reducing the allowed start-up period of solid fuel fired boilers was 

considered, since facilities are exempt from emissions limits during this period. 

Facilities subject to Rule 4352 are currently subject to a start-up limit of 96 

hours. Operators currently limit their start-up and shut-down times as much as possible 

since down time results in reduced productivity and profits. However, facilities 

periodically perform “cold repairs” on their solid fuel fired boilers for maintenance or 

trouble-shooting purposes. This requires operators to completely shut down the boilers, 

which in turn requires a longer start-up period to return to correct operating temperature. 

When the solid fuel fired boilers are starting up, the units are not operating with a full 

load which reduces emissions. Therefore, this is not a technologically feasible option 

for solid fuel fired facilities given the needs of current work practices. 

At this time, the District’s analysis indicates that there are no feasible opportunities for 

additional emission reduction regulatory strategies for this source category. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-45 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Risk-based Strategy Analysis 

The emissions from units subject to Rule 4352 contribute 9.2% of average winter NOx 

and 15.3% of average winter SOx emitted from stationary and area sources in the 2012 

emission inventory. Overall, Rule 4352 has significantly reduced NOx and SOx 

emissions from these units and has assisted in reducing PM2.5 concentrations through 

reductions of these key precursors. 

Control Measure Commitments

The following is a summary of recommended commitments for Rule 4352. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4352. 

Incentive Action 

Boilers subject to Rule 4352 are regulated units that have been subject to several 

generations of regulations; as such, the opportunities for incentive programs are 

minimal. As discussed above, funding or tax credits aimed at reducing emissions from 

biomass facilities in the Valley are available through some short-term programs such as 

the Existing Renewable Facilities Program through the California Energy Commission 

(CEC) and federal corporate tax credits from a federal program called the Renewable 

Electricity Program Tax Credit. Although there are no recommendations for new 

incentive actions at this time, the recommendation is to support agencies to continue 

the funding of existing incentive programs. 

Technology Advancement Action 

There are no recommendations for any specific technology advancement actions to 

reduce emissions from solid fuel fired boilers at this time. Through its Technology 

Advancement Program, the District will continue to seek potential feasible and low-cost 

technologies that may provide for additional emission reduction opportunities in this 

category. 

Policy Initiatives 

The District’s current legislative platform includes support for the continued operation of 

biomass facilities and increased development and use of cleaner-burning fuels. The 

recommendation is to continue supporting the current legislative platform but there are 

no recommendations for new policy initiatives at this time because the rule already 

requires the use of effective emission control technologies. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-46 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for new education and outreach efforts for 

these sources. The District will continue to work closely with affected sources to ensure 

successful compliance. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-47 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.1.7 Rule 4702 Internal Combustion Engines 

Source Category 

This rule applies to any internal combustion (IC) engine rated at 25 brake horsepower 

(bhp) or greater. The purpose of this rule is to limit NOx, carbon monoxide (CO), 

volatile organic compounds (VOC), and SOx emissions from units subject to this rule. 

The District’s original IC rule, Rule 4701 (Internal Combustion Engines – Phase 1), was 

adopted on May 21, 1992, superseded by newly adopted Rule 4702 on August 21, 

2003, and has subsequently been amended four times. The rule established NOx limits 

between 25-50 ppmv with 90-96% control for non-agricultural operations rich-burn 

engines and 65-75 ppmv with 85-90% control for non-agricultural operations lean-burn 

engines. Amendments have strengthened the rule by regulating emissions from 

agricultural operations sources and achieving approximately 84% control of agricultural 

operations emissions from this source category. The most recent rule amendment in 

August 2011 added reporting and point-of-sale requirements for engines 25-50 bhp, 

which were previously unregulated, and implemented more stringent NOx limits for nonagricultural operations spark-ignited engines, further reducing emissions from this 

source category. EPA finalized approval for Rule 4702 on January 10, 2008 and 

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

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.81 0.53 0.51 0.44 0.34 0.33 0.32 0.31

NOx 20.18 12.53 11.93 8.63 6.67 6.24 5.99 5.80

SOx 0.19 0.15 0.15 0.13 0.12 0.11 0.11 0.11

Winter Average - Tons per day

PM2.5 0.58 0.39 0.38 0.33 0.27 0.26 0.26 0.25

NOx 14.03 8.85 8.41 6.18 4.87 4.61 4.45 4.32

SOx 0.15 0.13 0.13 0.11 0.10 0.10 0.10 0.10

Regulatory Evaluation 

How does District Rule 4702 compare with federal rules and regulations? 

Rule 4702 is equivalent to the applicable federal standards and guidelines. Rule 4702 

is as stringent as the federal Alternative Control Techniques (ACT) documents (EPA –

453/R-93-032 “Alternative Control Techniques (ACT) Document – NOx Emissions from 

Stationary Reciprocating Internal Combustion Engines”, dated July 1993), New Source 

Performance Standards (NSPS) (40 CFR 60 Subpart IIII (Standards of Performance for 

Stationary Compression Ignition Internal Combustion Engines) and 40 CFR 60 Subpart 

JJJJ (Standards of Performance for Stationary Spark Ignition Internal Combustion 

Engines)), Maximum Achievable Control Technology (MACT) NOx limits (40 CFR 63 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

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Subpart ZZZZ (NESHAP for Stationary Reciprocating Internal Combustion Engines)), 

and EPA Best Available Control Technology (BACT) requirements. Additionally, there 

are no EPA Control Techniques Guidelines (CTG) listed for this category. 

How does District Rule 4702 compare to rules in other air districts? 

Upon comparing Rule 4702 to other California air districts’ rules for similar sources, the 

rule was found to be at least as stringent as the analogous rules for BAAQMD 

(Regulation 9 Rule 8—Nitrogen Oxides and Carbon Monoxide from Stationary Internal 

Combustion Engines), SMAQMD (Rule 412—Stationary Internal Combustion Engines 

Located at Major Stationary Sources of NOx), and VCAPCD (Rule 74.9—Stationary 

Internal Combustion Engines). Rule 4702 also meets or exceeds the BACT 

requirements for BAAQMD. 

SCAQMD Rule 1110.2 (Emissions from Gaseous and Liquid-Fueled Engines) specifies 

a NOx limit of 11 ppmv for all units. Due to the large inventory of agricultural engines in 

the Valley that have only recently been required to install emission control devices and 

the difficulties of implementing a lower NOx standard for agricultural engines, as 

discussed below in “Further NOx Limitations”, an 11 ppmv NOx limit is not feasible for 

agricultural engines at this time. The SCAQMD 11 ppmv limit for non-agricultural 

operations engines fired on landfill gas or digester gas engines stated as being effective 

July 1, 2012, was based on a provision to complete a technology assessment by July 

2010. The limit will only be implemented if the result of SCAQMD’s technology 

assessment confirms that 11 ppmv is achievable. During a 2011 telephone 

conversation with SCAQMD during the rule development process of Rule 4702, District 

staff confirmed that the technology assessment would not be completed until 

2012. Therefore, the District did not propose changes to the current limit for nonagricultural waste gas fueled rich-burn engines of Rule 4702 until such time that South 

Coast AQMD’s technology assessment confirmed that it is technologically and 

economically feasible to achieve 11 ppmv for that category of non-agricultural units. 

In addition to being one of the most stringent rules in the nation for this source category, 

any new unit brought to the Valley, except rare instances where the new unit has a low 

bhp rating or if the applicant agrees to limit the daily hours of operation, as well as any 

major modifications to existing units, would trigger District BACT requirements. 

Subsequently, these new or modified units would be required to use technology and 

control emissions beyond those established as RACT and implement the best available 

emission controls, as required by District Rule 2201 (New and Modified Stationary 

Source Review Rule). 

Emission Reduction Opportunities 

In its continuous effort to improve air quality in the Valley, the District has adopted 

numerous amendments to the IC engine rule that have significantly reduced NOx and 

PM emissions from this source category. The emissions inventory for NOx from IC 

engines will be reduced by 71% over from 20.18 tons of NOx per day in 2007, to 5.8 

tons of NOx per day in 2019. . Significant emission reductions from agricultural IC 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-49 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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engines have been achieved through a combination of regulatory efforts and incentive 

actions, including the replacement of over 2,000 diesel irrigation pumps with electric 

motors since 2007. Additional emissions reductions are forthcoming with the existing 

Rule 4702 as compliance dates approach over the next six years. Given the significant 

efforts and investments already made to reduce emissions from this source category, 

there are little remaining feasible opportunities for obtaining additional emissions 

reductions. While no significant additional opportunities have been identified, the 

District evaluated several potential additional areas based on comments received during 

development of this plan. 

Further SOx and Particulate Matter Limitations 

Most non-agricultural engines and many agricultural engines are fired on Public Utilities 

Commission (PUC) quality natural gas, and are inherently low-emitters of SOx and 

PM2.5 emissions. Current Rule 4702 contains stringent requirements requiring the 

combustion of PUC-quality natural gas, or other equivalent ultra-low sulfur fuels, and 

diesel engines subject to Rule 4702 are required to be EPA Tier 3 or Tier 4 certified, 

depending on the size of the engine and the annual operating hours. EPA Tier 3 and 4 

certifications require the units to meet low PM limits and Tier 4 engines are required to 

meet even lower PM limited through the use of particulate filters. Given the low PM2.5 

and SOx emissions from IC engines and existing rule requirements, no further 

requirements are needed to address PM2.5 and SOx emissions. 

Further NOx Limitations 

With regard to non-agricultural engines, new more stringent NOx limits were recently 

adopted in August 2011. The District conducted a thorough analysis in support of this 

recent rule amendment that considered all available control technologies, including their 

feasibility and cost effectiveness. The District subsequently adopted stringent limits with 

compliance dates ranging from 2014 through 2017. Based on this recent action and 

ongoing rule requirements, there are no additional emission reduction opportunities for 

non-agricultural engines at this time. 

The District adopted requirements in 2005 that established stringent requirements for 

reducing emissions from PUC-quality natural gas (spark-ignited) and diesel-fired 

(compression-ignited) agricultural engines. These requirements were the first of their 

kind in the nation, and established a timetable for phasing in new engine and control 

technologies for a previously unregulated source category. Overall, these requirements 

reduce emissions from agricultural engines by 84% when fully implemented, with 

significant investments being made by the affected stakeholders to comply with the rule. 

Additionally, the District and United States Department of Agriculture – Natural 

Resources Conservation Service (USDA-NRCS) have also made significant 

investments to provide incentives to accelerate the transition to cleaner engine 

technologies. One prime example of this effort was the collaborative public/private 

partnership involving the District, USDA-NRCS, agricultural stakeholders, and public 

utilities to incentivize the replacement of diesel irrigation pump engines with electric 

motors. This effort resulted in the conversion of over 2,000 diesel irrigation engines to 

electric motors. Agricultural operations are still in the process of implementing the new 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-50 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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standards or have only recently come into compliance with the stringent standards 

under Rule 4702. Compliance dates for agricultural operations engines range from 

2009 to 2010 for spark-ignited engines and 2010 through 2018 for compression-ignited 

engines. 

The District considered the possibility of reducing the NOx emissions limit for sparkignited agricultural operations engines to 11 ppmv; however, as previously mentioned, 

these engines have only recently been required to install emission control devices and 

comply with the current NOx limits in Rule 4702. As discussed in the 2011 Final Staff 

Report for the Revised Proposed Amendments to Rule 4702, the District is still 

evaluating the effectiveness and implementation issues associated with the control 

systems currently in place for agricultural spark-ignited engines, which include a 3-way 

catalytic converter, air/fuel ratio controller, and oxygen sensor. These systems have 

faced challenges due to the nature of agricultural engine installations, including remote 

locations, fluctuations in gas pressures, and unattended operations. While the 

technologies are capable of meeting the 150 ppmv and 90 ppmv NOx emissions limits 

currently in place for agricultural spark-ignited engines, additional time is needed to fully 

evaluate the effectiveness of these control devices and determine if it is technologically 

feasible to reach 11 ppmv with these controls. 

Additionally, the current emissions limits are appropriate for agricultural spark-ignited 

engines considering the potential economic impacts that more stringent NOx limits 

could create for Valley agriculture. Agriculture is economically depressed as evidenced 

by continued economic assistance from the federal government in the form of 

subsidies/grants to even the economic playing field resulting from increased importation 

of cheaper cost products from foreign countries into the U.S. Unlike agricultural diesel 

(compression-ignited) engines, agricultural spark-ignited engines are not eligible for 

Moyer incentive funding which has helped reduce the economic impacts associated with 

compliance costs for diesel engines. Furthermore, agriculture’s inability to pass the 

increased production costs on to consumers make it difficult for agriculture to absorb the 

compliance costs associated with more stringent limits for agricultural spark-ignited 

engines. 

Another important consideration is that the NOx limits in place prevent operators from 

replacing agricultural spark-ignited engines with diesel engines. In light of the different 

requirements, and related compliance costs, for spark-ignited engines and diesel 

engines, the District was made aware during the 2005 amendment of Rule 4702 that 

operators would likely replace an agricultural spark-ignited engine with a diesel engine if 

the emission limits for spark-ignited engines were too stringent. To prevent, or 

minimize, these instances, the District made the requirements for spark-ignited engines 

and compression-ignited engines as comparable as reasonable; as supported by the 

rule limits and compliance dates. Agricultural spark-ignited engines with higher NOx 

emissions limits have sooner compliance dates (2009-2010) and agricultural diesel 

engines with more stringent NOx limits have a longer compliance timeline (2010-2018). 

Reducing the spark-ignited NOx emissions limits could potentially prompt agricultural 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

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operators to switch to diesel engines and thus increase PM2.5 emissions for this source 

category. 

The potential for changing the exemption requirements for emergency standby engines 

and low-use engines was evaluated during the 2011 rule amendment process, it was 

determined that the existing requirements are consistent with ARB RACT/BARCT 

Determination for Spark-Ignited Engines and ARB Airborne Toxics Control Measures 

(ATCM). The emissions from these units are relatively minor, and controlling these 

emissions is subsequently cost ineffective. 

The level of stringency associated with existing Rule 4702 requirements is further 

supported by EPA’s full approval of Rule 4702. In the technical support document 

(TSD) published in August 2007 for the approval of Rule 4702, EPA determined that the 

requirements are, “consistent with EPA regulations, and relevant policy and guidance 

regarding enforceability, BACM/BACT, RACM/RACT, and SIP relaxations.”20

 

Additionally, EPA stated that, “Submitted Rule 4702 continues to implement 

BACM/BACT and other SIP approval criteria for stationary internal combustion 

engines...Because the criteria for BACM/BACT are stricter than for RACT, by meeting 

BACT requirements submitted Rule 4702 also fulfills RACT.”21 

Given the significant emissions reductions that have been achieved and will continue to 

be achieved under the existing rule, significant costs associated with these 

requirements, and the District’s analysis and related EPA findings, there are no feasible 

opportunities for additional emission reduction regulatory strategies for this source 

category. 

Risk-based Strategy Analysis 

The emissions from units subject to Rule 4702 contribute 18.2% of average winter NOx 

emitted from stationary and area sources in the 2012 emission inventory. These units 

are primarily fired on PUC-quality natural gas, which is generally considered a clean 

burning fuel with low SOx and PM emissions. While many agricultural diesel engines 

have been replaced with electric motors over recent years, remaining engines have 

been replaced, or will soon be replaced, with new, certified, cleaner diesel engines. 

Given the rural nature of the emissions, District health risk assessments of these newer 

diesel engines have concluded that the toxic health risk associated with the new 

engines are generally not significant. Overall, Rule 4702 has significantly reduced NOx 

and SOx emissions from these units and has assisted in reducing PM2.5 concentrations 

through reductions of these key precursors. 

 

20 (2008, January 10). Revisions to the California State Implementation Plan, San Joaquin Valley Air Pollution Control 

District and 

Sacramento Metropolitan Air Quality management District. 73 Fed. Reg. 7, pp. 1818 – 1822. 

21 Donez, F. (August 2007).Technical Support Document for EPA’s Notice of Proposed Rulemaking and Direct Final 

Rule for the California State Implementation Plan San Joaquin Valley Unified Air Pollution Control District Rule 4702, 

Internal Combustion Engines – Phase 2. San Francisco, CA: Environmental Protection Agency, Region IX Air 

Division.
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D-52 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4702. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4702. Existing sources are in the process of complying with 

new standards in current rule language thus continuing to reduce emissions from these 

sources. 

Incentive Action 

As discussed above, the District implements the stationary agricultural irrigation pump 

engine program component of the Heavy-Duty Engine Program. This program provides 

incentives for both the conversion of Tier 1 and Tier 2 engines to lower NOx and PMemitting Tier 4 engines and for the electrification of diesel engines, as the District highly 

prioritizes electrification efforts to achieve zero and near-zero emissions from engines. 

The following incentives are offered through this program: 

• Prior to the January 1, 2015 (or 12 years from installation) Rule 4702 compliance 

deadline for the conversion of Tier 1 and Tier 2 engines to Tier 4 engines, the 

program will offer incentive funding for the replacement of Tier 1 and Tier 2 

engines with the latest tier certified engine technology or electric motors. 

• The District will continue to offer incentive funding for the replacement of Tier 3 

certified engines with electric motors. 

• The District will also continue to offer incentive funding for the installation of 

electric motors, rather than diesel engines, on new wells. 

The District will consider the possibility of providing further incentives to further promote 

the replacement of agricultural IC engines with electric motors, including, but not limited 

to providing additional incentives for the high cost associated with utility line extensions 

to remote irrigation pump installations. 

Technology Advancement Action 

One of the 11 projects selected in 2011 for the District’s Technology Advancement 

Program is aimed at demonstrating that a compact Selective Catalytic Reduction (SCR) 

device on a biogas-powered engine can reduce NOx emissions to ultra-low levels. This 

new technology has the potential of providing a low cost option for reducing emissions 

from biogas-powered engines, particularly for dairy and other digester applications. 

Through its Technology Advancement Program, the District will continue to seek 

potential feasible and low-cost technologies that may provide for additional emission 

reduction opportunities in this category. 

Policy Initiatives 

The District’s current legislative platform includes support for the increased 

development and use of cleaner-burning fuels, incentive funding through the Carl Moyer 

Program, and the continuation of air quality funding in the Farm Bill. The District 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

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recommends continued support of these funding streams to continue providing 

incentives for accelerated reductions from engines in this category. The District will also 

consider pursuing a renewed public/private collaborative partnership similar to the 

previously discussed partnership to provide further incentives for replacing remaining 

agricultural IC engines with electric motors. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. The District does not have recommendations for new education and outreach 

efforts for these sources. The District will continue to work closely with affected sources 

to ensure successful compliance. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-54 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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D.1.8 Rule 4703 Stationary Gas Turbines 

Source Category 

The provisions of this rule are applicable to all stationary gas turbine systems, which are 

subject to District permitting requirements, and with electrical generation ratings equal 

to or greater than 0.3 megawatt (MW) or a maximum heat input rating of more than 3 

million British Thermal Units per hour (MMBtu/hr), and that are used for the generation 

of electrical power. The purpose of this rule is to limit NOx emissions from these 

stationary gas turbines. 

Rule 4703 was adopted on August 18, 1994. Since its adoption, the rule has been 

amended six times. The latest rule amendment in September 2007 strengthened the 

rule by establishing more stringent NOx limits for existing stationary gas turbines. EPA 

finalized approval for Rule 4703 on October 21, 2009 and deemed this rule as being at 

least as stringent as established RACT requirements. NOx emissions have been 

controlled by over 86% for this source category. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 1.75 1.60 1.51 1.45 1.48 1.52 1.52 1.53

NOx 6.87 3.24 3.09 3.00 3.05 3.11 3.12 3.13

SOx 0.48 0.43 0.40 0.38 0.38 0.39 0.40 0.40

Winter Average - Tons per day

PM2.5 1.72 1.58 1.49 1.43 1.46 1.49 1.50 1.50

NOx 6.82 3.21 3.07 2.98 3.03 3.08 3.10 3.11

SOx 0.47 0.42 0.39 0.37 0.37 0.38 0.39 0.39

Regulatory Evaluation 

How does District Rule 4703 compare with federal rules and regulations? 

Rule 4703 is equivalent to the applicable federal standards and guidelines. Rule 4703 

is as stringent as the federal Alternative Control Techniques (ACT) (EPA –453/R-93-007 

“NOx Emissions from Stationary Combustion Turbines”, dated January 1993), New 

Source Performance Standards (NSPS) (40 CFR 60 Subpart GG (Standards of 

Performance for Stationary Gas Turbines) & Subpart KKKK(Standards of Performance 

for Stationary Combustion Turbines)), and Maximum Achievable Control Technology 

(MACT) requirements (40 CFR 63 Subpart YYYY (NESHAP for Stationary Combustion 

Turbines)); additionally, there are no EPA Control Techniques Guidelines (CTG) listed 

for this category. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-55 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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How does District Rule 4703 compare to rules in other air districts? 

When comparing Rule 4703 to SCAQMD (Rule 1134—Emissions of Oxides of Nitrogen 

from Stationary Gas Turbines), BAAQMD (Regulation 9 Rule 9—Nitrogen Oxides from 

Stationary Gas Turbines), SMAQMD (Rule 413—Stationary Gas Turbines), and 

VCAPCD (Rule 74.23—Stationary Gas Turbines), the rule was found to be at least as 

stringent as these other rules. 

In addition to being one of the most stringent rules in the nation for this source category, 

any new unit brought to the Valley, as well as any major modifications to existing units, 

would trigger Best Available Control Technology (BACT) requirements. Subsequently, 

these new or modified units would be required to use technology and control emissions 

beyond those established as RACT and implement the best available emission controls, 

as required by District Rule 2201 (New and Modified Stationary Source Review Rule). 

Emission Reduction Opportunities 

The District has adopted numerous rule amendments to the turbine rule that have 

successfully and significantly reduced emissions from this source category. The 

emissions inventory for NOx from turbines has been reduced from 31.9 tons per day 

(tpd) in 1994 to 3.24 tpd in 2012. Significant emission reductions have been achieved 

through the implementation of the most stringent regulations in the nation for this source 

category and significant investments by stakeholders to implement effective and 

innovative emission control technologies. The District has achieved substantial NOx 

emissions reductions in the past year as compliance dates went into effect at the 

beginning of 2012. Given the significant efforts and investments already made to 

reduce emissions from this source category, there are little remaining feasible 

opportunities for obtaining additional emissions reductions. For the sake of 

thoroughness, the possibility of further reducing emissions from turbines is evaluated in 

the following discussion. 

BACT Comparisons 

Comparisons of this rule with the District, BAAQMD, and SCAQMD BACT requirements 

showed that some BACT emissions limits are more stringent than Rule 4703 limits. For 

units greater than 3 MW, some of the District’s NOx limits ranged from 3-5 ppmv, 

whereas the BACT limits ranged from 2-3 ppmv. For units less than 3 MW, the District’s 

NOx limit was 9 ppmv, whereas the BACT limit was 5 ppmv. The BACT guidelines list 

Selective Catalytic Reduction (SCR) and SCONOx as the emissions control 

technologies used to achieve emission limits in the range of 2-5 ppmv. Although lower 

emission limits are potentially achievable for this source category, BACT requirements 

are imposed on new or modified turbine installations where ultra-low NOx controls can 

be installed and the equipment and the facility can be designed to function with this new 

technology. Rule 4703 is a prohibitory rule that has undergone several generations of 

NOx limits for existing units in the Valley; facilities comply with these limits by retrofitting 

their existing equipment. Requiring the installation of entirely new turbine systems is 

extremely expensive and not cost effective, and therefore not required of facilities. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-56 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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Selective Catalytic Reduction 

Many of the larger units (> 3MW) have already employed SCR to achieve the 5 ppmv 

limits in place. Therefore, the District evaluated the potential opportunity to employ 

SCR for units less than 3 MW. 

A SCR system reduces NOx emissions by converting the emissions to water and 

elemental nitrogen. Ammonia is generally injected into the exhaust stream and reacts 

with the nitrogen. Due to the high cost of SCR systems, they are typically used for 

controlling emissions from larger units, greater than 3 MW, that generally create more 

emissions. The cost effectiveness of an SCR system for a 1 MW unit was calculated 

based on the cost effectiveness methodologies in the 2007 Staff Report for Rule 4703 

and some of the newer methodologies used to calculate the cost effectiveness of SCR 

in the August 2011 Staff Report for Rule 4702. The tables below present the total 

annual costs for a new SCR system and a retrofit system. 

 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-57 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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Table D-4 SCR Annual Costs for a New Installation on a 1 MW Turbine 

ITEM SOURCE COST

Turbine Rating 1 MW 

SCR Cost/KW $125/KW 

Middle point between 

high and low 

estimate from R4703 

analysis 

 

Operating Hours 7884 hrs/year 

Direct Capital Costs 

Total Purchased Equip Cost $125/KW x 1000 KW $125,000 

Freight 5% Purchased Equip. Cost (PEC) Rule 4702 $6,250 

Sales Tax 8.25% PEC Rule 4702 $10,313 

Direct Installation Costs 25% PEC Rule 4702 $31,250

Total Direct Capital Costs $172,813

Indirect Capital Costs 

Facilities 5% PEC Rule 4702 $6,250 

Engineering 10% PEC Rule 4702 $12,500 

Process Contingency 5% PEC Rule 4702 $6,250 

Total Indirect Capital Costs $25,000

Project Contingency 20% PEC R4702 $25,000 

Total Capital Costs (TCC) Direct Capital + Indirect Capital + 

Project Contingency R4702 $222,813 

Annualized Capital Costs 

(10 years @ 10%) 0.1627*TCC R4702 $36,252 

 

Direct Annual Costs 

Operating Costs 

Operator 0.5 hr/shift, $25/hr OAQPS $13,688 

Supervisor 15% of operator OAQPS $2,053 

Maintenance Costs 

Labor 0.5 hr/shift, $25/hr OAQPS $13,688 

Material 100% of labor cost OAQPS $13,688 

Utility Costs 

Electricity Costs Variable $5,747 

Cat. Replacement MHIA $5,621 

Cat. Disposal OAQPS $211 

Ammonia Variable $1,008 

NH3 Inject Skid MHIA $2,916 

Total Direct Annual Costs $58,620

Indirect Annual Costs 

Overhead 60% of Operating and 

Maintenance OAQPS $25,870 

Administrative 0.02 x PEC OAQPS $2,500 

Insurance 0.01 x PEC OAQPS $1,250 

Property Tax 0.01 x PEC OAQPS $1,250 

Capital Recovery 0.13 x PEC OAQPS $16,250 (10% int. rate, 15 yr period) 

Total Indirect Annual 

Costs $47,120 

Total Annual Costs Annualized capital + Direct Annual 

+ Indirect Annual $141,992 

 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-58 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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Table D-5 SCR Annual Costs for a Retrofit on a 1 MW Turbine 

ITEM SOURCE COST

Turbine Rating 1 MW 

SCR Cost/KW $325/KW 

Middle point between 

high and low 

estimate from R4703 

analysis 

 

Operating Hours 7884 hrs/year 

Direct Capital Costs 

Total Purchased Equip Cost $325/KW x 1000 KW $325,000 

Freight 5% Purchased Equip. Cost (PEC) Rule 4702 $16,250 

Sales Tax 8.25% PEC Rule 4702 $26,813 

Direct Installation Costs 25% PEC Rule 4702 $81,250

Total Direct Capital Costs $449,313

Indirect Capital Costs 

Facilities 5% PEC Rule 4702 $16,250 

Engineering 10% PEC Rule 4702 $32,500 

Process Contingency 5% PEC Rule 4702 $16,250 

Total Indirect Capital Costs $65,000

Project Contingency 20% PEC R4702 $65,000 

Total Capital Costs (TCC) Direct Capital + Indirect Capital + 

Project Contingency R4702 $579,313 

Annualized Capital Costs 

(10 years @ 10%) 0.1627*TCC R4702 $94,254 

 

Direct Annual Costs 

Operating Costs 

Operator 0.5 hr/shift, $25/hr OAQPS $13,688 

Supervisor 15% of operator OAQPS $2,053 

Maintenance Costs 

Labor 0.5 hr/shift, $25/hr OAQPS $13,688 

Material 100% of labor cost OAQPS $13,688 

Utility Costs 

Electricity Costs Variable $5,747 

Cat. Replacement MHIA $5,621 

Cat. Disposal OAQPS $211 

Ammonia Variable $1,008 

NH3 Inject Skid MHIA $2,916 

Total Direct Annual Costs $58,620

Indirect Annual Costs 

Overhead 60% of Operating and 

Maintenance OAQPS $25,870 

Administrative 0.02 x PEC OAQPS $6,500 

Insurance 0.01 x PEC OAQPS $3,250 

Property Tax 0.01 x PEC OAQPS $3,250 

Capital Recovery 0.13 x PEC OAQPS $42,250 (10% int. rate, 15 yr period) 

Total Indirect Annual 

Costs $81,120 

Total Annual Costs Annualized capital + Direct Annual 

+ Indirect Annual $233,994 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-59 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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Potential Emissions Reduction Methodology 

The estimated current annual NOx emissions and the estimated potential annual NOx 

emissions were calculated using the following equation: 

NOx = LF x MMBtu/hr x HR x EF/ 2,000 lb/ton 

Where: 

NOx = Current annual NOx emissions or potential annual NOx 

emissions in tons/year 

LF = turbine load factor 

MMBtu/HR = heat input rating 

HR = annual hours of operation 

EF = NOx emission factor in pounds per MMBtu 

Where: 

EF = NOx emission factor in ppmv x 0.00366 

ppmv = NOx emissions in parts per million corrected to 15% oxygen 

0.00366 = Conversion factor used: 0.00366 lb/MMBtu per ppmv NOx 

The estimated annual NOx emissions reduction was calculated using the following 

equation: 

NOx Emissions Reduction = Current annual NOx emissions - Potential annual NOx 

 emissions. 

Potential Emissions Reduction Calculation 

The emissions reduction calculations below utilized the following information: 

Loading factor = 0.75 

Heat input rating for a 1 MW unit = 15 MMBtu/hr 

Annual Hours of Operation = 7884 hours 

Current Emission Factor in Rule 4703 = 9 ppmv 

Potential Emissions Factor through the use of SCR = 5 ppmv 

Current NOx = LF x MMBtu/hr x HR x EF / 2,000 lb/ton 

 = 0.75 x 15 x 7884 x (9 x 0.00366) / 2000 

 = 1.46 tons/year 

Potential NOx = LF x MMBtu/hr x HR x EF / 2,000 lb/ton 

 = 0.75 x 15 x 7884 x (5 x 0.00366) / 2000 

 = 0.81 tons/year 

Emissions Reduction = Current NOx emissions - Potential NOx emissions 

 = 0.65 tons/year 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-60 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Table D-6 SCR Cost Effectiveness 

Type of 

Installation MW MMBtu/hr 

Current 

NOx 

Emission 

Factor 

(EF), 

ppmv 

Potential 

NOx EF, 

ppmv 

NOx 

Reduction 

(Tons/Year) 

Total 

Annual 

Cost ($) 

Cost 

Effectiveness 

($/ton) 

New 1 15 9 5 0.65 $141,992 $218,449 

Retrofit 1 15 9 5 0.65 $233,994 $359,991 

Therefore, even though some of the BACT emissions limits for units less than 3 MW are 

more stringent than the current limit of 9 ppmv, this is not a cost effective option. 

EMx 

Certain BACT limits for simple cycle plants were achieved through the use of SCONOx. 

This multifaceted technology reduces NOx, SOx, carbon monoxide (CO), and volatile 

organic compound (VOC) emissions and is stated as achieving NOx levels less than 1.5 

ppmv by its manufacturer. One issue with the use of SCONOx is that it requires steam 

to operate and simple cycle plants do not generate steam. Therefore, a simple cycle 

facility would have to add a boiler to their facility to generate steam for the SCONOx 

system, making the addition of this technology more costly. The District is not aware of 

any SCONOx applications on simple cycle plants.22 While SCONOx is better suited for 

combined cycle turbines, this technology has not been achieved in practice (AIP) yet in 

the District. 

BAAQMD evaluated SCONOx, now known as the EMx system, for turbines in a recent 

Final Determination of Compliance (FDOC) for the Oakley Generating Station. The 

FDOC states that EMx could potentially be an improvement over SCR as an add-on 

control device for achieving NOx reductions – assuming it can achieve the same level of 

NOx control – because it does not use ammonia. Ammonia has the potential, under 

certain atmospheric conditions, to react with nitric acid in the atmosphere to form 

ammonium nitrate, which can be a form of PM2.5. However, based on the 

implementation of EMx at a facility in Shasta County, BAAQMD voiced some concerns 

for its use. 

EMx has never been used on a large utility-scale turbine and so there is no data on 

which to make a direct evaluation of how well the technology would work on larger 

turbines. EMx has been used on a smaller aeroderivitive turbine at the Redding Power 

Plant Unit No. 5, a 45-MW combined-cycle facility in Shasta County, CA. The Shasta 

County Air Quality Management District evaluated EMx at the Redding facility under a 

demonstration NOx limit of 2.0 ppm, which SCR can consistently achieve. After three 

years of operation, the Shasta County AQMD evaluated whether the facility was 

meeting this demonstration limit with EMx, and concluded that “Redding Power is not 

 

22 Brian K. Lusher. (June 2010). Final Determination of Compliance: Marsh Landing Generating Station. San 

Francisco, CA: Bay Area Air Quality Management District. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

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able to reliably and continuously operate while maintaining the NOx demonstration limit 

of 2.0 ppmvd @ 15% O2.”

23

 

The FDOC states that although the EMx manufacturer maintains that such problems 

have been overcome, concerns remain about how consistently the technology would be 

able to perform. Recent communications between BAAQMD and Shasta County Air 

District confirmed that the earlier conclusions about the achievability of a lower limit 

remain valid.24 In addition, monthly reports of Continuous Emissions Monitoring System 

(CEMS) data submitted by Redding Power Plant to Shasta County Air District during 

2007 and 2008 indicated that emissions have often been substantially higher.25 

Furthermore, the data from Redding is from a smaller aeroderivitive turbine, and there is 

no guarantee that if it were scaled up for uses on utility-size turbines that it would even 

be able to achieve the performance required from larger turbines. For these reasons, 

BAAQMD concluded that EMx is not as developed as SCR at this time and cannot 

achieve the same level of emissions performance that SCR is capable of. 

SCAQMD is currently funding a research project that will study and demonstrate the 

feasibility of control technologies to reduce PM2.5 and ultrafine particulate emissions 

from natural gas-fired turbine power plants. EMx is one of the two technologies that 

were selected for demonstration and the project is expected to be completed by the end 

of 2012. The findings of this report could potentially be beneficial for evaluating the 

feasibility of EMx applications for turbines in the future. 

SOx 

The implementation of sulfur dioxide (SO2) limits at least as stringent as the 

requirements in 40 CFR 60 Subpart KKKK (Standards of Performance for Stationary 

Combustion Turbines) was considered for Rule 4703. Fuel treatment sulfur removal 

systems were recognized as being able to reduce SOx emissions from turbines, other 

than those fired on Public Utilities Commission (PUC) quality natural gas. One Valley 

facility is in the process of installing SCR onto their digester gas-fired turbine to meet 

the Rule 4703 limit. To do this, they must install a fuel pretreatment system that 

removes H2S and siloxanes, as they can damage the SCR catalyst if not removed. 

Other landfill and digester-gas turbines outside the District are also using these 

systems. 

There are only 5 facilities in the Valley that utilized a fuel other than natural gas for their 

turbines in 2011. Each of those facilities operates on natural gas the majority of the 

time and operates on an alternate fuel part-time. Three of those facilities fired on diesel 

gas, while the other two operated on digester gas. Due to California Diesel Fuel 

requirements, the diesel facilities in the Valley are limited to a sulfur content of 0.0016 

lb-SO2/MMBtu. PUC-quality natural gas typically has a sulfur content of 0.00285 lb-

 

23 Letter from R. Bell, Air Quality District Manager, Shasta County Air Quality Management District, to R. Bennett, 

Safety & Environmental Coordinator, Redding Electric Utility, June 23, 2005. 

24 Kathleen Truesdell. (January 2011). Final Determination of Compliance: Oakley Generating Station. San 

Francisco, CA: Bay Area Air Quality Management District. 

25 Kathleen Truesdell. (January 2011). Final Determination of Compliance: Oakley Generating Station. San 

Francisco, CA: Bay Area Air Quality Management District.
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

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SO2/MMBtu and digester turbines are limited to 0.016 lb-SO2/MMBtu per District 

permits’ requirements. By comparison, the Subpart KKKK limit is much higher at 0.060 

lb-SO2/MMBtu and all of the units in the Valley are achieving much lower SO2 limits. 

Adding a SO2 limit similar to Subpart KKKK to the rule will not foster additional 

emissions reductions for Valley facilities. 

PM2.5 

PM2.5 reduction technologies for turbines were also researched in an effort to conduct 

a PM2.5 technology cost effectiveness analysis. Post-combustion controls, including 

baghouses, electrostatic precipitators, and scrubbers were examined since these 

technologies can be used to remove PM2.5 emissions from exhaust gas streams 

As previously mentioned, every unit in the Valley subject to Rule 4703 operated on 

strictly natural gas, with the exception of 5 facilities that operated on an alternate fuel 

part-time in 2011. Based on District Permits records and information in the BAAQMD 

FDOC for the Oakley Generating Station, electrostatic precipitators, baghouses, and 

scrubbers have not been achieved-in-practice for natural gas-fired turbines. These 

devices are normally used on solid fuel fired sources or others with high PM emissions, 

and are not used in natural gas-fired applications, which have inherently low PM 

emissions. The District is not aware of any gas turbine that has ever been required to 

use add-on controls such as these. BAAQMD reviewed the EPA BACT/LAER 

Clearinghouse and confirmed that EPA has no record of any post-combustion 

particulate controls that have been required for natural gas-fired gas turbines.26

 

Furthermore, these devices would not be technologically feasible to implement for 

certain facilities. As noted in the BAAQMD FDOC, if add-on control equipment were 

installed, it would create significant backpressure that would significantly reduce the 

efficiency of a power plant and would cause more emissions per unit power produced. 

Moreover, these devices are designed to be applied to emissions streams with far 

higher particulate emissions, and they would have very little effect on the low-PM 

emissions streams from natural gas-fired facilities in further reducing PM emissions.27 It 

takes an emissions stream with a much higher grain loading for these types of 

abatement devices to operate efficiently. This low level of abatement efficiency (if any) 

also means that these types of control devices would not be cost effective, even if they 

could feasibly be applied to this type of source. For these reasons, post-combustion 

particulate control equipment is not technologically feasible for units subject to Rule 

4703. 

 

 

26 Kathleen Truesdell. (January 2011). Final Determination of Compliance: Oakley Generating Station. San 

Francisco, CA: Bay Area Air Quality Management District. 

27 Kathleen Truesdell. (January 2011). Final Determination of Compliance: Oakley Generating Station. San 

Francisco, CA: Bay Area Air Quality Management District.
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As previously mentioned, SCAQMD is currently funding a research project that will 

study and demonstrate the feasibility of control technologies to reduce PM2.5 and 

ultrafine particulate emissions from natural gas-fired turbine power plants. Sulfur 

removal and the EMx multi-pollutant control system are the two technologies which 

were selected for demonstration. The findings of this report could potentially be 

beneficial for evaluating the cost effectiveness and feasibility of applying these 

emerging technologies to turbines in future rule-amending projects. 

At this time, the District’s analysis indicates that there are no feasible opportunities for 

additional emission reduction regulatory strategies for this source category. 

Risk-based Strategy Analysis 

The emissions from units subject to Rule 4703 contribute 6.6% of average winter NOx, 

5.1% of average winter SOx, and 2.8% of average winter PM2.5 emitted from stationary 

and area sources in the 2012 emission inventory. These units are primarily fired on 

PUC-quality natural gas, which is generally considered a clean burning fuel with low 

SOx and PM emissions. Overall, Rule 4703 has significantly reduced NOx and SOx 

emissions from these units and has assisted in reducing PM2.5 concentrations through 

reductions of these key precursors. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4703. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4703. 

Incentive Action 

Stationary gas turbines subject to Rule 4703 are regulated units that have been subject 

to several generations of regulations; as such, the opportunities for incentive programs 

are minimal. There are no recommendations for incentive actions at this time.

Technology Advancement Action 

There are no recommendations for a new technology advancement project specific to 

units subject to Rule 4703. Through its Technology Advancement Program, the District 

will continue to seek potential feasible and low-cost technologies that may provide for 

additional emission reduction opportunities in this category. 

Policy Initiatives 

The District’s current legislative platform includes support for the increased 

development and use of cleaner-burning fuels. The recommendation is to continue 

supporting the current legislative platform but there are no recommendations for new 

policy initiatives at this time because the rule already requires the use of the most 

effective emission control technologies. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

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Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. The District does not have recommendations for new education and outreach 

efforts for these sources. The District will continue to work closely with affected sources 

to ensure successful compliance. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-65 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.2 INDUSTRIAL PROCESSES 

The San Joaquin Valley air basin (Valley) is home to a wide range of industries and 

industrial processes. The industrial sector is a vital contributor to the health of the 

Valley’s economy, and has made important contributions to air quality improvement. 

Whether coming under regulation for the first time or having undergone several 

generations of retrofit rules, the reductions achieved represent significant investments of 

finances and energy. 

While the broad category of Industrial Processes includes many source categories, for 

the purposes of this appendix, this discussion is limited to the reduction of animal 

matter, flares, lime kilns, activities involving sulfur, and glass melting furnaces. Other 

industry groups and technologies addressed in this plan but not addressed in this 

section are discussed in other parts of this appendix. 

The control measure source categories discussed in this section affect several 

industries in the Valley including, but not limited to the glass and related products, 

manufacturing, food and agricultural material processing, acid plants, oil and gas 

production, sewage treatment, landfills, incinerators, and petroleum refining industries. 

Existing Control Strategies 

Due to the degree of difficulty and enormity of the challenge that the Valley faces in 

meeting the National Ambient Air Quality Standards (NAAQS), the District recognizes 

that prohibitory rules alone are not enough to reduce emissions to meet attainment 

requirements and protect public health. The District’s longstanding, progressive 

strategy for reducing emissions is a multifaceted effort that includes incentive programs 

and policy initiatives in addition to prohibitory rules. The following discussion 

summarizes both the existing District efforts to reduce emissions from this source 

category, and evaluations for potential opportunities for further emissions reductions. 

Incentive Programs 

Incentive programs are an integral part of the emission reduction efforts of the District, 

especially where the District lacks direct jurisdiction in establishing emission control 

requirements. The emission units within the Industrial Processes category are located 

at stationary sources and are subject to rules that have undergone several amendments 

and continue to be some of the most stringent rules in the nation; opportunities for 

incentive programs for units subject to these rules are minimal. The District is not 

currently implementing incentive programs specific to units used in industrial processes 

subject to rules in this category.

Policy Initiatives 

Similar to the Incentive Programs, the District’s policies and Legislative Platform are 

important components to the District’s strategy to attain federal ambient air quality 

standards. The District utilizes policies and the legislative platform to bring attention to 

major issues that have a direct impact on the Valley’s air quality. The District does not 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-66 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

currently have a portion of the legislative platform dedicated specifically to this control 

measure source category. 

Rules and Regulations 

The following is a list of rules specific to the Industrial Processes category. Each of the 

following rules will be evaluated to examine potential opportunities for additional 

emissions reductions. 

Table D-7 Current Industrial Process Rules 

Rule Last Amended/ 

Adopted

Rule 4104 Reduction of Animal Matter 12/17/1992 

Rule 4311 Flares 06/18/2009 

Rule 4313 Lime Kilns 03/27/2003 

Rule 4354 Glass Melting Furnaces 05/15/2011 

Rule 4802 Sulfuric Acid Mist 12/17/1992 
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D.2.1 Rule 4104 Reduction of Animal Matter 

Source Category 

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

including rendering, cooking, drying, dehydration, digesting, evaporating, and protein 

concentration. Adopted on May 21, 1992 and amended for District rule number 

reorganization on December 17, 1992, Rule 4104 requires 100% VOC capture and a 

high level of destruction (1,200 degree for 0.3 seconds). Rule 4104 was adopted 

primarily to control pathogens. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.05 0.05 0.06 0.06 0.06 0.06 0.06 0.06

NOx 0 0 0 0 0 0 0 0

SOx 0.05 0.06 0.06 0.06 0.06 0.06 0.07 0.07

Winter Average - Tons per day

PM2.5 0.05 0.05 0.06 0.06 0.06 0.06 0.06 0.06

NOx 0 0 0 0 0 0 0 0

SOx 0.05 0.06 0.06 0.06 0.06 0.06 0.07 0.07

Regulatory Evaluation 

How does District Rule 4104 compare with federal rules and regulations? 

No applicable federal standards and guidelines, such as Control Techniques Guidelines 

(CTG), Alternative Control Techniques (ACT), New Source Performance Standards 

(NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAP), and 

Maximum Achievable Control Technology (MACT) requirements have been identified 

for this source category. 

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

Rule 4104 is as stringent or more stringent than the following similar regulations in other 

air districts in California: SCAQMD Rule 472 (Reduction of Animal Matter); BAAQMD 

Regulation 12 Rule 2 (Rendering Plants); SMAQMD Rule 410 (Reduction of Animal 

Matter); and VCAPCD Rule 58 (Reduction of Animal Matter). 

EPA finalized approval for Rule 4104 on March 9, 2010 and deemed this rule RACT. 

There are no animal rendering Best Available Control Technology (BACT) guidelines 

that include any additional control technologies. 
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D-68 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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Emission Reduction Opportunities 

Facilities generally use steam from a boiler (indirect-fired) or a rotary dryer (direct-fired) 

for their operations; NOx emissions are generated from these combustion units. 

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

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

Rule 4104 effectively controls emissions from units subject to this rule, this 

effectiveness limits opportunities for additional emission reduction opportunities. The 

emission control equipment generally includes a condenser for VOC control, and a 

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

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

baghouse. For the sake of thoroughness, the District analyzed the potential of packed 

bed scrubbers and regenerative thermal oxidizers to further reduce emissions from units 

subject to Rule 4104. 

Packed Bed Scrubbers 

The potential opportunity to reduce emissions if facilities were to replace their thermal 

oxidizers with packed bed scrubbers is analyzed in the following discussion. In certain 

installations, packed bed scrubbers may be more efficient at removing PM from the 

exhaust and additionally do not create NOx or SOx. However, determining the scrubber 

medium may take some experimenting to ensure it does not cause an increase in 

emissions or violate other District rules. It would also need to be replaced periodically, 

adding to the cost of upkeep. Thermal oxidizers do not present similar issues. Also, 

facilities subject to Rule 4104 produce only a very small amount of directly emitted 

PM2.5 and are otherwise already required to have a high level of control for emissions. 

Therefore, the current requirements are as stringent as possible for these types of 

facilities. 

Regenerative Thermal Oxidizers 

The potential opportunity to reduce emissions from facilities by replacing thermal 

oxidizers with regenerative thermal oxidizers (RTO) with heat recovery, which is a 

current practice in place at some facilities in the Valley, is also considered for this 

analysis. RTO devices use less supplementary fuel. While using less fuel may reduce 

NOx emissions, this is not necessarily the case. The PM control efficiency is nearly the 

same for both thermal oxidizers and RTOs and the total NOx emissions from this 

category is relatively small given that there are only a few units subject to this rule that 

are not already subject to other combustion rules limiting NOx emissions. Any new 

units would be evaluated through the District’s Best Available Control Technology New 

Source Review requirements. 

There are no feasible opportunities for additional emission reduction regulatory 

strategies for this source category. The District will continue to evaluate the potential for 

additional emissions reductions from this source category through future plan 

development projects. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-69 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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Risk-based Strategy Analysis 

The emissions from this source category contribute 0.7% of average winter SOx, and 

0.1% of average winter PM2.5 emitted from stationary and area sources in the 2012 

emission inventory. The emissions from this source category are relatively small 

contributors to the Valley inventory throughout the year; the emissions are consistent 

and have no elevated emission levels in the winter months. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4104. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4104. 

Incentive Action 

There are no recommendations for incentive actions for this source category at this 

time.

Technology Advancement Action 

There is no recommendation for a new technology advancement project for units 

subject to Rule 4104. Through its Technology Advancement Program, the District will 

continue to seek potential feasible and low-cost technologies that may provide for 

additional emission reduction opportunities in this category. 

Policy Initiatives 

The District does not currently have any policy initiatives specific to units subject to this 

rule. There are no recommendations for new policy initiatives specific to these units. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for additional education and outreach efforts 

for these sources. The District will continue to work closely with affected sources to 

ensure successful compliance. 
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D.2.2 Rule 4311 Flares 

Source Category 

The purpose of Rule 4311 is to limit volatile organic compounds (VOC), NOx, and SOx 

emissions from any operation involving the use of flares, with the exception of a few 

types of sources identified in the rule. Flaring is a high temperature oxidation process 

used to burn combustible components, mostly hydrocarbons, of waste gases from 

industrial operations. The majority of waste gases flared are natural gas, propane, 

ethylene, propylene, butadiene and butane. During combustion, gaseous hydrocarbons 

react with atmospheric oxygen to form carbon dioxide (CO2) and water. In some waste 

gases, carbon monoxide (CO) is the major combustible component. Flares generate air 

pollutants such as NOx, sulfur dioxide, carbon monoxide, and particulate matter. 

Additionally, there is a possibility of release of hydrocarbons if they have not been 

completely combusted, seen by the naked eye as smoke. Complete combustion 

requires proper mixing of air and waste gas. There are two general types of flares, 

open and enclosed flares. Flares are further categorized by the height of the flare tip, 

and by the method of enhancing combustion by mixing at the flare tip (i.e., steamassisted, air-assisted, pressure assisted, or non-assisted). Elevated flares are more 

common and have larger capacity than ground flares. Flares are normally used to 

dispose of low volume continuous emissions, but are designed to handle large 

quantities of waste gases associated with plant emergencies. Flare gas volumes can 

vary from a few cubic meters per hour during regular operations up to several thousand 

cubic meters per hour during major upsets. 

This rule was originally adopted June 2002 to establish flaring requirements and reduce 

emissions from flares, and has been amended twice since then. The most recent 

amendment was made in September 2009 to incorporate requirements for flare 

minimization plans and to make existing requirements for sulfur emissions more 

stringent. EPA finalized approval for the most recent amendments to Rule 4311 on 

November 3, 2011 and deemed this rule as meeting established RACT standard 

requirements. 
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D-71 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.12 0.13 0.13 0.13 0.14 0.14 0.14 0.14

NOx 0.38 0.38 0.39 0.39 0.39 0.39 0.39 0.39

SOx 0.24 0.25 0.26 0.26 0.26 0.26 0.26 0.27

Winter Average - Tons per day

PM2.5 0.12 0.13 0.13 0.13 0.14 0.14 0.14 0.14

NOx 0.38 0.38 0.39 0.39 0.39 0.39 0.39 0.39

SOx 0.24 0.25 0.26 0.26 0.26 0.26 0.26 0.27

Regulatory Evaluation 

How does District Rule 4311 compare with federal rules and regulations? 

Rule 4311 is as stringent as or more stringent than the two New Source Performance 

Standards (NSPS) that are applicable to this source category, (40 CFR 60.18 – General 

Control Device Requirements and 40 CFR 65.147 – Flares). There are no applicable 

Control Techniques Guidelines (CTG), Alternative Control Techniques (ACT), National 

Emission Standards for Hazardous Air Pollutants (NESHAP) or Maximum Achievable 

Control Technology (MACT) requirements for this source category. 

 

How does District Rule 4311 compare to rules in other air districts? 

The standards of Rule 4311 were compared to rules for similar source categories in 

other air districts in California, and determined to be as stringent, or more stringent, than 

other air districts’ rules for flaring activities. Specifically, this rule was compared to the 

following rules: SCAQMD Rule 1118 (Emissions from Refinery Flares); BAAQMD 

Regulation 12 Rule 11 (Flare Monitoring at Petroleum Refineries); BAAQMD Regulation 

12 Rule 12 (Flares at Petroleum Refineries); and Santa Barbara County Air Pollution 

Control District Rule 4359 (Flares and Thermal Oxidizers). SMAQMD and VCAPCD do 

not have flare specific prohibitory rules. 

Rule 4311 was found to be more stringent than the flare rules in other districts in that 

Rule 4311 is applicable to any operation that uses flares, while other districts limit 

applicability to oil and gas production, petroleum refineries, natural gas services, and 

similar industries. Additionally, Rule 4311 does not have as many exemptions as other 

air districts, for example Santa Barbara’s rule has exemptions for the burning of sulfur in 

the manufacturing of sulfur compounds while District Rule 4311 does not contain these 

exemptions. Similarities between Rule 4311 and the flare rules in other districts include 

the requirement to submit and maintain flare minimization plans, monitoring, 

recordkeeping, and reporting requirements, and NOx and VOC emissions standards for 

ground-level enclosed flares. 
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Emission Reduction Opportunities 

Rule 4311 is one of the most stringent rules in the nation for flaring activities, and was 

approved by EPA into the California State Implementation Plan (SIP) as meeting RACT 

requirements in November 2011. Overall, additional opportunities to further reduce 

emissions from flares and flaring activities in the Valley were not identified. The 

November 2011 EPA technical support document (TSD) for the approval of the 2009 

amendments to Rule 4311 includes recommendations by EPA for exploring additional 

recordkeeping and monitoring requirements. A thorough analysis was performed of the 

recordkeeping and monitoring requirements during the rule-amending project, as 

discussed in the final draft staff report for the adopted rule. Existing recordkeeping and 

monitoring requirements are appropriate for facilities in the Valley to demonstrate 

compliance with rule requirements. No emission reductions, or other benefits to air 

quality, would result from amending the recordkeeping and monitoring requirements. 

Additionally, the EPA recommendations are not RACT requirements as demonstrated 

by EPA’s approval of the rule into the SIP as RACT. The 2011 EPA TSD also 

recommended the District consider creating a separate rule for refinery and non-refinery 

flare rules. Both types of flares are included in the current version of District Rule 4311. 

No emission reductions would be gained by the bifurcation of the existing rule; 

therefore, bifurcation is not recommended as a part of this plan. 

Sections 6.2.2 and 6.2.3 of Rule 4311 require facilities subject to flare minimization 

plans (FMP) to submit annual reports to the District with “Reportable Flaring Event” and 

“Annual Monitoring Report” data by a July 31, 2012 deadline. Analysis of the submitted 

data and comparisons of that data against the submitted FMPs will provide an 

opportunity to evaluate potential emission reduction opportunities from this category. 

Risk-based Strategy Analysis 

The emissions from units subject to Rule 4311 contribute 0.8% of average winter NOx, 

and 3.0% of average winter SOx emitted from stationary and area sources in the 2012 

emission inventory. The emissions from this source category are a relatively small 

contributor to overall Valley emissions throughout the year, with no elevated emission 

levels in the winter months. Emissions from this category are well-controlled through 

existing Rule 4311 requirements. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4311. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4311. EPA comments presented in the November 2011 

TSD regarding additional recordkeeping and monitoring requirements will be reevaluated as appropriate the next time that Rule 4311 is amended. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

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Further study of the FMPs and annual reportable flaring event data and the annual 

monitoring report data to determine if there are any opportunities to reduce additional 

emissions from facilities subject to Rule 4311 is recommended. 

Incentive Action 

Facilities that use flares are regulated sources that have been subject to several 

generations of rules, and Rule 4311 is one of the most stringent rules in the nation for 

flaring activities, which minimizes opportunities for incentive actions. There are no 

recommendations for incentive actions at this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for units 

subject to Rule 4311. Through its Technology Advancement Program, the District will 

continue to seek potential feasible and low-cost technologies that may provide for 

additional emission reduction opportunities in this category. 

Policy Initiatives 

The District is not currently supporting any policy initiatives specific to flares, and there 

are no recommendations for new policy initiatives for these sources. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. No new education and outreach efforts are recommended for these sources 

at this time. The District will continue to work closely with affected sources to ensure 

successful compliance. 
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D.2.3 Rule 4313 Lime Kilns 

Source Category 

Rule 4313 limits NOx emissions from the operation of lime kilns. Lime kilns are used in 

a variety of manufacturing and processing operations, including food and agriculture. 

There are currently no lime kilns currently operating in the Valley. There were a total of 

three lime kilns in the Valley, used at two sugar processing plants; however, these 

plants have been non-operational since 2008. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0 0 0 0 0 0 0 0

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day

PM2.5 0 0 0 0 0 0 0 0

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Regulatory Evaluation 

There are no opportunities for reduced emissions in the Valley from this source 

category; there are no lime kilns operating in the Valley. 

Emission Reduction Opportunities 

There are no opportunities for reducing emissions in the Valley from this source 

category. If an operator were to bring a lime kiln to the Valley with the intention of 

operating it, that lime kiln would be subject to District Rules 2201 (New and Modified 

Stationary Source Review Rule), and 4001 (New Source Performance Standards), 

among others, and would be required to meet District Best Available Control 

Technology (BACT) requirements. 

Risk-based Strategy Analysis 

No health risks are associated with lime kilns in the Valley. 

Control Measure Commitments 

There are no recommendations for future control measure commitments for Rule 4313. 
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D.2.4 Rule 4354 Glass Melting Furnaces 

Source Category 

The provisions of Rule 4354 are applicable to glass melting furnaces in the Valley. 

There are seven glass-making facilities with a total of 13 glass-melting furnaces subject 

to Rule 4354 in the Valley. Industrial glass making is a continuous process with raw 

materials supplied to the furnace at the front end, and product taken off the line at the 

back end of the process. The raw materials for making glass are silica sand and soda 

ash. Melting these basic materials and forming them into the desired product geometry 

creates the final glass product. The different end products vary widely in raw material 

additives, processing equipment and conditions, and product quality requirements. 

Rule 4354 was adopted September 14, 1994 and has been subsequently amended six 

times. This rule is one of the most stringent rules of its kind in the nation, and is 

successful in limiting NOx, SOx, volatile organic compounds (VOC), carbon monoxide 

(CO), and PM emissions from glass melting furnaces. Rule 4354 was amended 

September 16, 2010 to strengthen NOx limits in the rule; EPA finalized approval for 

these amendments on August 29, 2011 and deemed this rule as RACT. Rule 4354 was 

subsequently amended again in May 19, 2011 to implement updated start-up 

requirements; EPA proposed approval of these amendments on November 5, 2012. As 

a result of this stringent prohibitory rule and continuing efforts on behalf of this industry to 

reduce emissions, the Valley is home to glass-making facilities with glass melting furnaces 

that utilize the most advanced low-NOx firing technology. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.60 0.45 0.47 0.48 0.49 0.50 0.51 0.51

NOx 7.75 6.13 4.02 4.12 4.22 4.31 4.35 4.39

SOx 3.04 1.86 1.80 1.82 1.85 1.87 1.88 1.89

Winter Average - Tons per day

PM2.5 0.60 0.45 0.47 0.48 0.49 0.50 0.51 0.51

NOx 7.75 6.12 4.02 4.12 4.21 4.31 4.35 4.39

SOx 3.04 1.85 1.80 1.82 1.85 1.87 1.88 1.89

Regulatory Evaluation 

How does District Rule 4354 compare with federal rules and regulations? 

This rule is more stringent than federal rules and regulations. This rule was compared 

to the following federal rules and regulations: federal Alternative Control Techniques 

(ACT) (EPA-435/R-94-037 – Alternative Control Techniques Document – NOx 

Emissions from Glass Manufacturing); the one National Emission Standard for 

Hazardous Air Pollutants (NESHAP) that is applicable to glass melting furnaces (40 
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CFR 61 Subpart N (National Emission Standard for Inorganic Arsenic Emissions from 

Glass Manufacturing Plants); the following two Maximum Achievable Control 

Technology (MACT) standards, 40 CFR 63 Subpart NNN (National Emission Standards 

for Hazardous Air Pollutants for Wool Fiberglass Manufacturing Plants), and 40 CFR 63 

Subpart SSSSSS (National Emission Standards for Hazardous Air Pollutants for Glass 

Manufacturing Area Sources). There is no Control Techniques Guidelines (CTG) for 

this source category. 

How does District Rule 4354 compare to rules in other air districts? 

The emission limits of Rule 4354 depend on the type of glass produced, furnace firing 

technology and the emission-averaging period. Evaluation of glass melting prohibitory 

rules in other air districts in California revealed that this rule is more stringent than 

equivalent rules in other air districts. Rules evaluated include SCAQMD Rule 1117 

(Emissions of Oxides of Nitrogen from Glass Melting Furnaces) and BAAQMD 

Regulation 9 Rule 12 (Nitrogen Oxide Emissions from Glass Melting Furnaces). 

VCAPCD and SMAQMD do not have a specific prohibitory rule for this source category. 

Emission Reduction Opportunities 

Rule 4354 is among the most stringent rules in the nation for glass melting furnaces. 

The NOx emission limits contained within Rule 4354 require the installation of the best 

available NOx technology (i.e. oxy-fuel firing or SCR systems), with a compliance 

deadline of January 1, 2014; there are no feasible opportunities to further reduce NOx 

emissions from glass melting furnaces at this time. 

District staff considered lowering the existing SOx limits for container plants from current 

limits of 0.9 and 1.1 lbs of SOx per ton of glass depending on cullet content to the 

District Best Available Control Technology (BACT) limit of 0.8 lbs/ton. The analysis 

below indicates that it is not reasonably feasible to reduce SOx limits from RACT levels 

to BACT levels. 

The glass container industry is mandated by the State of California to use a minimum 

quantity of recycled glass (cullet) as part of the production process. The quantity of 

clear glass cullet available to glass manufacturers is very limited; therefore, cullet with a 

large portion of colored glass is included in each batch. The continued use of mixed 

color cullet is critically important to meeting California’s recycling goals. Due to the 

variable quality of mixed color cullet, SOx emissions produced by the melting of 

recycled cullet are also variable. Container glass manufacturers control multiple 

furnaces as a single unit, meaning that the exhaust from multiple furnaces are ducted 

together and the total emissions are averaged over the total amount of glass pulled from 

all furnaces. Because emissions are averaged across furnaces, EPA requires that 

there be a 10% air quality benefit, meaning that the overall limit for multiple furnaces be 

10% less than the limit for a single furnace. This imposes the lowest SOx emission limit 

on container glass furnaces, but allows operators to install one control device per facility 

rather than one add-on control device per furnace. SOx emissions limits for container 

glass were adopted at 1.1 pounds per ton of glass produced if the operator uses at least 
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25% by weight of mixed color cullet and a limit of 0.9 pounds per ton of glass produced 

for all other container glass manufacturing. If the District were to lower the limits in the 

rule to the BACT limit of 0.8 lbs/ton, then the 10% required air quality benefit for multiple 

furnaces extend beyond BACT, which is not feasible. The 0.8 lbs/ton BACT limit is 

equivalent to the 0.9 lbs/ton limit with the additional EPA required 10% air quality 

benefit. 

At this time, the District’s analysis indicates that there are no feasible opportunities for 

additional emission reduction regulatory strategies for this source category. 

Risk-based Strategy Analysis 

The emissions from units subject to Rule 4354 contribute12.6% of average winter NOx, 

and 22.5% of average winter SOx emitted from stationary and area sources in the 2012 

emission inventory. Emissions from this source are consistently emitted throughout the 

year with no peak emission in winter months. NOx emissions from these sources have 

been significantly reduced through this rule, which is one of the most stringent rules in 

the nation. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4354. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4354. 

Incentive Action 

There are no technologies that could reduce emissions beyond that already required in 

the rule and achieved by facilities; therefore, there are no recommendations for 

incentive actions for glass melting furnaces. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for units 

subject to Rule 4354. Through its Technology Advancement Program, the District will 

continue to seek potential feasible and low-cost technologies that may provide for 

additional emission reduction opportunities in this category. 

Policy Initiatives 

The District does not currently support any legislative activities specific to glass melting 

operations; there are no recommendations for new policy initiatives at this time. 
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Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. The District does not have recommendations for new education and outreach 

efforts for these sources. The District will continue to work closely with affected sources 

to ensure successful compliance. 
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D.2.5 Rule 4802 Sulfuric Acid Mist 

Source Category 

The purpose of Rule 4802 is to limit sulfuric acid emissions from any sulfuric acid 

production unit that was constructed or modified before August 17, 1971. The rule was 

adopted on May 21, 1992 and applies to only one facility in the Valley. The EPA 

approved Rule 4802 into the SIP on June 8, 1999.28 District Rule 4802 limits sulfuric 

acid mist to 0.30 pounds per short ton of acid produced. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.0004 0.0003 0.0004 0.0004 0.0004 0.0004 0.0004 0.0004

NOx 0.027 0.022 0.022 0.022 0.023 0.023 0.023 0.024

SOx 0.95 0.76 0.78 0.79 0.79 0.81 0.81 0.83

Winter Average - Tons per day

PM2.5 0.0004 0.0003 0.0004 0.0004 0.0004 0.0004 0.0004 0.0004

NOx 0.027 0.022 0.022 0.022 0.023 0.023 0.023 0.024

SOx 0.95 0.76 0.77 0.78 0.79 0.80 0.81 0.83

Regulatory Evaluation 

How does District Rule 4802 compare with federal rules and regulations? 

The rule reflects conformance with 40 CFR Part 60.30d Subpart Cd—Emissions 

Guidelines and Compliance Times for Sulfuric Acid Production Units (Part 60 of the 

CFS is Standards of Performance for New Stationary Sources (NSPS)), which sets 

emission limits for sulfuric acid mist at 0.5 pounds per ton of acid produced for sulfuric 

acid production plants operating before August 17, 1971. 

There is one sulfuric acid plant in the Valley; this plant has been in operation since 

before August 17, 1971, and it is subject to the requirements of District Rule 4802. 40 

CFR Part 60.30d Subpart Cd—Emissions Guidelines and Compliance Times for Sulfuric 

Acid Production Units establishes emission limits for such sulfuric acid plants. 40 CFR 

Part 60.80 Subpart H—Standards of Performance for Sulfuric Acid Plants, sets 

emission limits for sulfuric acid plants constructed or modified after August 17, 1971. 

There are no other federal guidelines, including Control Techniques Guidelines (CTG), 

Alternative Control Technology (ACT), Maximum Achievable Control Technology 

(MACT), and National Emission Standards for Hazardous Air Pollutants (NESHAP), that 

apply to the control of sulfuric acid mist. The Best Available Control Technology (BACT) 

 

28 (1999, June 8). Approval and Promulgation of Implementation Plans; California State Implementation Plan 

Revision, South Coast Air Quality Management District, San Joaquin Valley Unified Air Pollution Control District, 

Siskiyou County Air Pollution Control District, and Bay Area Air Quality Management District, 64 Fed. Reg. 109, pp. 

30396–30398. (to be codified at 40 CFR Part 52) 
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determination for controlling sulfuric acid mist involves the use of candle filters (fiber bed 

mist eliminators), which reduce emissions to 0.10 pounds per ton of 100% sulfuric acid 

when measured as a three-hour average. 

How does District Rule 4802 compare to rules in other air districts? 

BAAQMD Regulation 9, Rule 1 (Sulfur Dioxide), regulates all sulfur dioxide emissions 

including sulfuric acid mist plants constructed or modified after August 17, 1971; the rule 

limits emissions from any source in the sulfuric acid plant effluent process gas 

containing sulfur dioxide in excess of 300 ppm by volume calculated at 12% oxygen. 

BAAQMD’s Regulation 12, Rule 6 (Acid Mist from Sulfuric Acid Plants) requires that an 

operator not emit from a sulfuric acid production unit gases which contain acid mist 

expressed as H2SO4 in excess of 0.15 g per kg (0.3 lb/T) of acid produced. No other 

district-specific rules were indicated. SCAQMD Rule 469 (Sulfuric Acid Units) has the 

same limit as District Rule 4802. Both SMAQMD and VCAPCD regulate sulfuric acid 

mist through their new source review process, but do not have specific sulfuric acid mist 

rules. 

Emission Reduction Opportunities 

Only one facility in the Valley—a sulfuric acid plant—is subject to Rule 4802 (Sulfuric 

Acid Mist). This facility was in operation before 1971 and is limited by this rule to 0.30 

pounds of acid mist per ton of acid produced. The facility uses a mist eliminator to 

remove fine particles from the acid gas stream, which has been determined to meet 

BACT requirements. By definition of Rule 4802, no new facility within the Valley will be 

subject to this rule. Instead, all new facilities would be subject to Rule 2201 (New and 

Modified Stationary Source Review Rule) and would be required to implement BACT 

level controls. 

An identified potential opportunity to reduce emissions from this source category would 

be to reduce the allowed limit for sulfur emissions from 0.30 pounds per ton produced to 

0.1 pound per ton produced, consistent with EPA’s BACT determination. Source tests 

conducted in 2010 and 2011 at the single facility permitted under Rule 4802, showed an 

actual sulfuric acid mist emission rate of 0.09 pound per ton using existing technology. 

Hence, the facility is meeting the current national BACT standard with the most 

advanced technology currently available and enforced through existing permit 

requirements, despite the fact that their current permit and Rule 4802 do not set that 

requirement. Therefore, the District has determined that there are no potential 

opportunities to further reduce emissions from this source category. 

Risk-based Strategy Analysis 

The emissions from this source category contribute 9.2% of average winter SOx emitted 

from stationary and area sources in the 2012 emission inventory. As demonstrated in 

the emission inventory table above, these emissions are consistent throughout the year 

with no elevated emission levels in winter months. 

 
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Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4802. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4802. 

Incentive Action 

The one unit subject to Rule 4802 is currently a regulated source that has been subject 

to this rule since 1992 and no new technologies were identified to further reduce 

emissions. There are no recommendations for incentive actions at this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for units 

subject to Rule 4802. Through its Technology Advancement Program, the District will 

continue to seek potential feasible and low-cost technologies that may provide for 

additional emission reduction opportunities in this category. 

Policy Initiatives 

The District is not currently supporting any policy initiatives specific to sulfuric acid mist 

operation and there are no recommendations for new policy initiatives for these 

sources. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. No new education and outreach efforts are recommended for these sources 

at this time. The District will continue to work closely with affected sources to ensure 

successful compliance. 

 
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D.3 MANAGED BURNING 

Managed burning is the controlled burning of materials. There are three types of 

managed burning that occur in the Valley including open burning of agricultural 

materials, hazard reduction burning, and prescribed burning. This managed burning 

control measure source category affects burning and disposal activities conducted by 

the agricultural industry, residents in the wildland/urban interface, and land 

management agencies operating on the San Joaquin Valley floor and within the 

National Parks and Forests. 

For many years, the District managed the smoke impacts from the open burning of 

agricultural materials through a system of county-wide burn/no burn days. In 2004, the 

District established the Smoke Management System (SMS), a more refined method of 

authorizing or prohibiting individual burns, based on modeled smoke impacts. The SMS 

user considers projected meteorological conditions and air quality forecasts to 

determine the allowable amount and location of agricultural burning. Properly managed 

burning allocations under the existing District SMS ensures that air quality and health 

impacts of open burning of agricultural materials are minimized to the fullest extent, 

reducing public exposure to smoke and contributing to improvements to general air 

quality in the Valley. Under the SMS, agricultural burning is prohibited on days when an 

exceedance of a federal standard is forecast to occur. The implementation of the 

District’s SMS, District Rule 4103 (Open Burning), and the use of sustainable 

agricultural practices have reduced the amount of materials being burned, thus resulting 

in reduced PM2.5 emissions. 

Until recently, Land Management Agencies (LMAs) operated under a policy where 

naturally ignited wildfires (i.e. lightning strikes) were viewed as unhealthy and 

destructive for the ecosystem, and therefore were actively suppressed upon discovery. 

As this policy continued through the decades, the amount of fuel (dead plant materials, 

etc.) in the Sierra Nevada Mountains grew, which increased the likelihood of 

uncontrollable wildfires. It was later determined that fire is a natural part of the 

ecosystem, and that fire is necessary to reduce fuels on the forest floors to give space 

and a chance for new trees to grow, thus ensuring the health and continuity of the 

ecosystem. To achieve this, LMAs within the Valley currently conduct prescribed 

burning to reduce fuels in areas that are determined to be overgrown. Through these 

efforts, LMAs are able to burn on days when it is favorable from both meteorological 

and air quality considerations. Through District Rule 4106, a LMA must request 

authorization from the District before beginning a prescribed burn operation. This gives 

the District the discretion to not allow prescribed burning on days when dispersion 

and/or air quality is poor. This reduces emissions and protects public health by only 

allowing prescribed burning on days when smoke dispersion is favorable, thus reducing 

the chance for high concentrations of smoke to occur in nearby communities. 
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Similarly, hazard reduction burning occurs in communities that are within the 

wildland/urban interface, where homes and businesses in the foothills are often 

surrounded by dry brush. This fuel must be disposed of each year to ensure a barrier of 

fire protection of 100 feet in all directions, per Section 4291 of the California Public 

Resources Code. This disposal is usually in the form of burning, and as with prescribed 

burning, this is only allowed if the District forecasts favorable meteorological and air 

quality conditions. 

Existing Control Strategies 

Due to the degree of difficulty and enormity of the challenge that the Valley faces in 

meeting the National Ambient Air Quality Standards (NAAQS), the District recognizes 

that prohibitory rules alone are not enough to reduce emissions to meet attainment 

requirements and protect public health. The District’s longstanding, progressive 

strategy for reducing emissions is a multifaceted effort that includes incentive programs 

and policy initiatives in addition to prohibitory rules. The following discussion 

summarizes both the existing District efforts to reduce emissions from this source 

category, and evaluations for potential opportunities for further emissions reductions. 

Incentive Programs 

Incentive programs are an integral part of the emission reduction efforts of the District, 

especially where the District lacks direct jurisdiction in establishing emission control 

requirements. The District is not currently implementing any incentive programs specific 

to this category. However, the District is actively seeking technology advancement 

projects to further develop low-emissions options for the handling of the wide variety of 

organic materials in the Valley. 

Policy Initiatives 

Similar to the Incentive Programs, the District’s policies and Legislative Platform are 

important components to the District’s strategy to attain federal ambient air quality 

standards. The District utilizes policies and the legislative platform to bring attention to 

major issues that have a direct impact on the Valley’s air quality. The District’s 

legislative platform currently includes the following items that are applicable to managed 

burning categories. 

The biomass industry utilizes agricultural materials that would otherwise be burned 

using open burning methods. To maintain the viability of biomass power-generating 

plants, the District supports legislation that would provide for the continued operation of 

strategically located biomass facilities to provide disposal options for agricultural, urban, 

and forest wood materials. Subsidies and/or preferential utility rates for power produced 

from biomass can serve as measures to enhance the economic feasibility of this 

alternative. 

Reducing wildfires and the resulting air pollutants requires a sustained and multi-faceted 

approach that employs effective measures to reduce fuel supplies and adequate 

resources to manage fires when they occur. Towards that end, the District supports 
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policies and initiatives that would encourage rapid disposal of the fuel supply, including 

the following: 

• Additional financial and staffing resources for public and private land managers 

to conduct prescribed burning as an effective means for reducing fuel supplies 

that lead to large and uncontrollable wildfires. 

• Additional resources to manage wildfires when they occur. 

• Lessening or removal of contradictory environmental protection policies that 

prohibit the use of mechanized methods, or prescribed burning to reduce fuels 

when those are the only feasible methods available. 

• Changes in the federal policies that better incorporate air quality concerns by 

shifting focus to prescribed burning and employing fire management techniques 

that reduce air quality impacts when wildfires occur. 

Rules and Regulations 

The following is a list of rules specific to the Managed Burning category. Each of the 

following rules will be evaluated to examine potential opportunities for additional 

emissions reductions. 

Table D-8 Current Managed Burning Rules 

Rule Last Amended/ 

Adopted

Rule 4103 Open Burning 04/15/2010 

Rule 4106 Prescribed Burning and Hazard Reduction 

Burning

06/21/2001 
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D.3.1 Rule 4103 Open Burning 

Source Category 

This source category includes the open burning of materials such as agricultural 

materials, diseased materials, and contraband materials, as well as fires set for fire 

department training purposes. Rule 4103 was originally adopted on June 18, 1992 and 

it has since been amended several times to incorporate state law requirements. The 

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

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

(Prescribed Burning and Hazard Reduction Burning). 

Rule 4103 and the District’s Smoke Management System (SMS) have reduced the total 

acreage of agricultural materials burned in the Valley by 80% since 2002. California 

Senate Bill (SB) 705 (2003, Florez; California Health and Safety Code Section (CH&SC) 

41855.5 and 41855.6) established a schedule for specific types of agricultural materials 

to no longer be burned, but allowed some postponement of the phase-out where 

justified by technical and economic impediments. In an effort to implement SB 705 and 

enhance the procedures for open burn requests, in 2004 the District established the 

SMS, a more refined method of authorizing or prohibiting individual burns, based on 

modeled smoke impacts. Under the SMS, agricultural burning is prohibited on days 

when an exceedance of a federal standard is forecast to occur. 

In 2010, the District evaluated each crop category identified in CH&SC Section 41855.5 

to determine any technologically and economically feasible alternatives to open burning. 

After working extensively with stakeholders to understand viable alternatives to burning 

and associated costs, the District provided recommendations for allowing or prohibiting 

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

Report and Recommendations on Agricultural Burning. The District amended Rule 

4103 in April 2010 to incorporate CH&SC requirements and require the District to review 

its determinations for any postponed crops and materials at least once every five years. 

EPA finalized approval for Rule 4103 on January 4, 2012 and deemed this rule as at 

least meeting RACT requirements. The District most recently re-evaluated the 

availability of alternatives to open burning in May 2012. The District found the 

recommendations for postponement of certain crop categories are still valid and 

submitted a report of those findings to ARB, of which they concurred. 
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Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 5.87 4.54 4.51 4.50 4.49 4.47 4.46 4.45

NOx 4.30 3.46 3.44 3.43 3.42 3.41 3.40 3.38

SOx 0.11 0.09 0.09 0.09 0.09 0.09 0.09 0.09

Winter Average - Tons per day

PM2.5 9.32 6.67 6.63 6.61 6.59 6.57 6.55 6.53

NOx 6.84 5.07 5.04 5.02 5.01 4.99 4.97 4.96

SOx 0.17 0.13 0.13 0.13 0.13 0.13 0.13 0.13

Regulatory Evaluation 

How does District Rule 4103 compare with federal rules and regulations? 

There are no specific federal guidelines for Open Burning in terms of New Source 

Performance Standards (NSPS), Control Techniques Guidelines (CTG), Maximum 

Achievable Control Technology (MACT) and National Emission Standards for 

Hazardous Air Pollutants (NESHAP). 

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

No rules or Best Available Control Technology (BACT) guidelines in other California air 

districts are more stringent than the current Rule 4103. Rule 4103 sets the standard for 

agricultural burning programs, with extensive resources dedicated to implementing the 

District’s smoke management program. Under Rule 4103 and the SMS, potential 

burning is evaluated and authorized only when the burning will not cause a significant 

impact on air quality. 

The analogous rules of other California air districts evaluated for this plan include 

SCAQMD Rule 444 (Open Burning); BAAQMD Regulation 5 (Open Burning); SMAQMD 

Rule 407 (Open Burning); and VCAPCD Rule 56 (Open Burning). 

Emission Reduction Opportunities 

The District evaluated the feasibility and cost effectiveness of alternatives to burning in 

the 2010 Final Staff Report and Recommendations for Agricultural Burning (2010 

Report). The District determined, and ARB concurred, that there were no economically 

feasible alternatives to open burning of certain crop categories as outlined in the 2010 

Report; this conclusion was reaffirmed in the 2012 Update: Recommendations on 

Agricultural Burning (2012 Report). 
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Citrus Orchard Removal Threshold 

The District has determined that citrus orchard removals less than 3,500 acres, under 

certain circumstances should still be allowed to burn when no other cost effective and 

feasible alternatives are available based on factors identified and discussed in length in 

the 2010 and 2012 Reports. For the largest citrus growers (>3,500 acres), the District 

determined that it is economically feasible to send citrus orchard removal matter to 

biomass plants, as described in June 27, 2011 and October 12, 2012 letters to EPA that 

provided further clarification on this issue. Therefore, open burning of citrus orchard 

removals for large citrus growers (>3,500 acres) is not allowed. These determinations 

are based on the ability of large growers to provide a steady demand for chippers, the 

availability of chipping equipment, and the currently reduced supply of urban wood 

materials as fuel for biomass plants due to the economic downturn. 

Open Burning 

Burning of citrus orchard removal materials (less than 3,500 acres) is not automatically 

allowed, rather, each request to burn citrus orchard removals is evaluated on a case-bycase basis under the District’s agricultural burn permit program, which does not allow 

burning if it will cause or contribute to the exceedance of air quality standards. To more 

specifically describe the criteria for case-by-case evaluations (and as described in the 

June 27, 2011 and October 12, 2012 letters to EPA), the District annually evaluates and 

determines the feasibility of further prohibiting open burning of these materials based on 

the availability of sufficient biomass capacity and economically feasible chipping 

services. As of July 2011, the prohibition threshold is established as citrus farms with a 

combined acreage of 3,500 acres or greater. Consistent with this criteria, any request 

(beyond the 15 acre allowance provided for all citrus orchard removals) from citrus 

farms to open burn orchard removals are evaluated on a case-by-case basis. 

The following is a summary of the analysis the District used to make the citrus 

determinations; these contributing factors will be re-evaluated in 2015 as committed to 

in the 2010 Rule 4103 amendment. 

Alternatives to Open Burning 

The alternative to open-burning citrus orchard removal material is to chip the material 

and send it to biomass plant. Biomass plant capacity and the availability of 

economically feasible chipping services were evaluated in order to determine the 

feasibility of this alternative to open burning citrus orchard removals. Concerns raised 

in the 2010 Report remain valid of whether or not biomass plants will accept citrus along 

with the additional processing and costs that are required to make the citrus chips 

acceptable as fuel, especially once the economy improves and construction material is 

more abundant. 

• Chipping. The adobe soil in which citrus crops are usually grown is extremely 

difficult to remove from the extensive root system of citrus trees. Separating the 

roots from the trunk prior to chipping, as well as screening the chipped root material 

to remove excessive soil clumps all increase the costs associated with chipping 

citrus material. 
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• Biomass. Biomass facilities have a limited capacity for citrus orchard removals due 

to the composition of the citrus materials as discussed in detail in the 2010 Report. 

In addition, ground citrus wood produces stringy material and takes longer to dry out 

enough to burn properly. As a result, biomass facilities which do accept citrus 

material will blend up to 30% of citrus material with other crops to promote better 

flow of the material through the equipment. There is uncertainty in the amount of 

citrus orchard removal biomass facilities will accept in the future as biomass facilities 

have not committed to burning a specific amount of agricultural material. As 

described in the 2012 Report, there has not been a significant increase in biomass 

fuel consumption or storage capacity from the addition of new/converted facilities. 

Previously, monetary incentives have also been provided to increase use of biomass 

and offset the cost of chipping services. However, these monetary incentive programs 

are short-term in nature, either because the program sunsets within a few years, 

funding for the program has to be re-appropriated, or funding per project is for a limited 

period. Funding previously available for chipping agricultural materials provided by the 

Natural Resources Conservation Service (NRCS) was discontinued in 2012, making it 

more cost prohibitive to completely prohibit open burning. Therefore, there are currently 

no long-term federal or state funding commitments for the operation of biomass facilities 

or development of alternatives to burning. The 2010 Report specified that Rule 4103 is 

as stringent as economically and technologically feasible. Therefore, there are no 

additional identified opportunities for emissions reductions from this source category at 

this time. This category will be re-evaluated in 2015 as committed to in the 2010 Rule 

4103 amendment. 

Risk-based Strategy Analysis 

The emissions from this source category contribute10.0% of average winter NOx, and 

12.2% of average winter PM2.5 emitted from stationary and area sources in the 2012 

emission inventory. District regulatory efforts have fostered significant reductions in 

emission from this source category. Although winter emissions are slightly elevated 

compared to summer emission levels, the District’s Smoke Management System (SMS) 

prohibits agricultural burning on days when an exceedance of federal standards is 

forecast to occur, thus reducing potential public health impacts from this source 

category. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4103. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4103. The District carefully manages agricultural burning 

with its SMS and continues to consider the economic feasibility of burning alternatives 

on a case-by-case basis and in accordance with the five year evaluation period outlined 

in Rule 4103. 
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Incentive Action 

Over the past ten years, the Natural Resources Conservation Service (NRCS) has 

encouraged growers to chip or shred prunings from almond and walnut orchards by 

providing a cost-share basis through the Environmental Quality Incentives Program. 

According to conversations with NRCS staff, the program was not continued into 2012. 

Technology Advancement Action 

The District is currently funding a project through its Technology Advancement Program 

which will test a prototype device to reduce emissions from the burning of raisin trays. 

While this project, as well as many others, are in the process of developing alternatives 

to reduce emissions, it is still under evaluation and not yet commercially available. 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 

Policy Initiatives 

The District currently supports legislation that would provide for the continued operation 

of strategically located biomass facilities to provide disposal options for agricultural, 

urban, and forest wood waste. Subsidies and/or preferential utility rates for power 

produced from biomass can serve as measures to enhance the economic feasibility of 

this alternative. The recommendation is to continue supporting the current legislative 

platform but there are no recommendations for new policy initiatives at this time.

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for additional education and outreach efforts 

for Rule 4103 at this time. The District will continue to work closely with affected 

sources to ensure successful compliance. 
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D.3.2 Rule 4106 Prescribed Burning and Hazard Reduction Burning 

Source Category 

This source category includes all prescribed burning within the District. It also includes 

hazard reduction burning in the wildland/urban interface. Rule 4106 was adopted in 

June 2001. The adoption of Rule 4106 was not aimed at reducing the total emissions 

from this category as the District recognizes the importance of both prescribed burning 

and hazard reduction burning, but rather the adoption of established tools that the 

District could use to manage smoke emissions in the Valley. Through these tools, the 

District has expended considerable resources to ensure that the ignition of burn projects 

is only allowed when air quality and dispersion conditions are favorable, thus lessening 

the health impacts on Valley citizens and on air quality in the Valley. 

 

EPA finalized approval for Rule 4106 on February 27, 2002. Rule 4106 was evaluated 

in the RACT State Implementation Plan (SIP) demonstration, however the Technical 

Support Document (TSD) states the rule is not subject to RACT because it is not a 

Control Techniques Guidelines (CTG) category and it does not regulate major sources. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 9.31 9.32 9.32 9.32 9.33 9.33 9.33 9.33

NOx 3.26 3.26 3.26 3.26 3.26 3.26 3.26 3.26

SOx 0.99 0.99 0.99 0.99 0.99 0.99 0.99 0.99

Winter Average - Tons per day

PM2.5 0.72 0.73 0.73 0.74 0.74 0.74 0.75 0.75

NOx 0.21 0.21 0.21 0.21 0.21 0.22 0.22 0.22

SOx 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.05

Regulatory Evaluation 

How does District Rule 4106 compare with federal rules and regulations? 

There is currently no federal guidance given for this source category under the federal 

Alternative Control Techniques (ACT), New Source Performance Standards (NSPS), 

National Emission Standards for Hazardous Air Pollutants (NESHAP), Maximum 

Achievable Control Technology (MACT), and Control Techniques Guidelines (CTG). 

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

Upon comparing Rule 4106 to other California air districts’ rules for similar sources, it 

has been determined that Rule 4106 is as stringent as the following analogous rules: 

SCAQMD Rule 444 (Open Burning); BAAQMD Regulation 5 (Open Burning); SMAQMD 

Rule 501 (Agricultural Burning); VCAPCD Rule 56 (Open Burning), and Placer County 
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APCD Rule 301 (Nonagricultural Burning Smoke Management) and Rule 303 

(Prescribed Burning Smoke Management). 

Prescribed Burning Emission Reduction Opportunities

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

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

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

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

on air quality and meteorological conditions. The District will continue to work with 

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

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

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

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

Valley. Diligent District analysis identified the following two potential opportunities to 

reduce emissions from this process: the use of firebox air curtain burners and increased 

communication between the District and LMAs in managing wild fires. 

 

Firebox Air Curtain Burners 

As opposed to burning, a LMA may be able to mechanically remove material from the 

project site. This could achieve a significant reduction in emissions, yet it is often not 

practical or possible to bring mechanical equipment to remote and dense forest lands. 

Mechanical removal is much more expensive for the LMA to reduce the fuels in an area 

as compared to burning, and is not physically possible for many sites, making it not a 

feasible alternative. However, assuming that a LMA could mechanically remove all of 

the material from a project burn site, and the material was placed in piles and prepared 

for burning, an alternative to open burning would be to use a firebox air curtain burner. 

A firebox air curtain burner is a device that circulates large volumes of air over a burning 

fire in an open topped fire proof metal box. When compared to open burning, firebox air 

curtain burners have been shown to greatly reduce PM and carbon dioxide emissions, 

but have greater emissions of NOx than open burning. Based on District analysis in 

2009, firebox air curtain burners on average cost $75,000, and the cost effectiveness 

was calculated at $40,308 per ton of PM2.5, and $238,182 per ton of NOx. This 

alternative is not cost effective and therefore not feasible. 

Wild Fires 

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

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

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

wildfires occur, the District works with the responsible LMA in managing the fire as the 

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

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

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

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

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

order to reduce emissions and impacts to Valley residents. 
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Hazard Reduction Burning Emission Reduction Opportunities 

Section 4291 of the California Public Resources Code states that structures must 

maintain a defensible perimeter of 100 feet in all directions; this defensible perimeter is 

commonly created through the clearing of vegetation. Although Section 4291 doesn’t 

require it, most of this vegetation is burned, because it’s less expensive, faster, and 

more convenient than other options. Potential opportunities evaluated in this plan 

development process included the reorganization of hazard reduction zones, and the 

feasibility of alternatives to burning the vegetation. 

Reorganization of Hazard Reduction Zones 

The possibility of reducing emissions by reorganizing the currently established hazard 

reduction zones is examined in the following discussion. Under Rule 4106, hazard 

reduction burning is only allowed when the District forecasts favorable air quality and 

dispersion conditions. Currently this forecast is based on a county-by-county basis, with 

appropriate elevation breaks. As an improvement to this zone system, and similar to 

agricultural burning, the Valley could be separated into smaller hazard reduction zones 

to provide more effective smoke management. Managing the allowance of hazard 

reduction burning under this type of scheme also has the potential to limit smoke 

impacts on residents. Establishing this type of management system would not cause an 

increase in costs for landowners, making this a cost effective opportunity. However, 

emissions reduced would be minimal, since the burning would still occur, just on 

different days when conditions are favorable. 

Alternatives to Burning 

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

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

communities that regularly conduct hazard reduction burning. These options are 

discussed below. 

Note that the year 2012 emissions inventory for the hazard reduction burning portion of 

this control measure category is 0.21 tons per day of PM2.5, 0.05 tons per day of NOx, 

and 0.0043 tons per day of SOx. So although the alternatives below may be 

successful, the reductions in the inventory will be minimal. 

Chipping 

As previously mentioned, one alternative to the open burning of material is to use a 

chipper to break down the material into small pieces suitable for landscaping, dust 

control cover, or biomass burning. Further evaluation of this alternative option revealed 

that chippers are not a viable alternative because the requirement of the defensible 

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

cleared and disposed of are leaves, pine needles, weeds, and some small brush, all of 

which are not considered acceptable materials for wood chippers. The amount of 

useable material produced from this type of chipping would be negligible at best. 
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Firebox Air Curtain Burners 

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

burner, which was described earlier. Based on the District’s analysis in 2009, the 

average cost of a firebox air curtain burner is $75,000. Through the use of a firebox air 

curtain burner for hazard reduction burning, the cost effectiveness of emissions 

reductions was determined to be $34,026 per ton of PM2.5, and $204,154 per ton of 

NOx. This is not cost effective, and therefore not recommended. 

Biomass Removal Program 

A potential opportunity to reduce emissions from hazard reduction burning by removing 

the biomass from the area and sending it for combustion at a biomass plant, similar to a 

program implemented by the Placer County Air Pollution Control District (Placer) was 

evaluated. Placer implemented a “Biomass Box” program beginning in the spring of 

2007 to collect and utilize biomass that would traditionally be collected and burned as a 

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

collected the biomass by distributing 20’ to 40’ industrial containers throughout 

participating communities in the county. When full, the containers were transported to 

another location where the materials were grinded into useable fuel that biomass 

energy companies accept. The chipped biomass was then loaded onto larger trucks 

and hauled to one of two biomass facilities. This was a very successful program for 

Placer, with net air pollution reductions at 88.6%, including 24.7 tons of particulates and 

4.0 tons of NOx reduced at a cost of $80,000. 

Evaluation of this program supports Placer’s assertion that this is a highly successful 

program and a similar program could benefit the Valley. However, the Valley faces 

several challenges in implementing such a program due to our unique geography. The 

Valley is considerably larger than Placer County with the Sierra Nevada mountain range 

stretching the length of the Valley. This poses two unique challenges to the feasibility of 

this program; the first being the challenge of distributing the boxes and the quantity of 

boxes needed to be effective, and the second challenge being the distance from the box 

collection locations to the biomass power plants. The Placer program estimated total 

transport miles for the entire program to be 14,800 miles. The mileage required in the 

Valley to distribute, collect, and transport the materials to a biomass power plant would 

be significantly more than Placer, which brings into issue the increased truck emissions. 

Additionally, as stated before, the annual emissions from hazard reduction burning in 

the Valley are 0.05 tpd of NOx and 0.21 tpd of PM2.5, meaning emissions reduced 

could be lower than those achieved in Placer. 
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Risk-based Strategy Analysis 

The emissions from this source category contribute 1.3% of average winter PM2.5 

emitted from stationary and area sources in the 2012 emission inventory. Because of 

the nature of the source of these emissions, the emissions are primarily a summer 

issue, as illustrated in the emission inventory table above. This source category does 

not significantly contribute to winter time PM2.5 concentrations; further control of this 

source would not make a significant impact towards the region’s attainment of the 

federal PM2.5 air quality standard. However, since wildfires can often heavily impact 

the health of Valley residents, prescribed and hazard reduction burning mitigate the 

impact that a wildfire can have on the landscape, thus reducing the public’s potential 

exposure to smoke. Continued support and management of this source category will 

ensure an improvement in both the health of the public and the ecosystems of the parks 

and forests within the San Joaquin Valley. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4106. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4106. Further study is recommended to determine the 

feasibility of utilizing a biomass removal program similar to that in Placer County. 

Incentive Action 

There are no incentive programs currently funded by the District specific to prescribed 

or hazard reduction burning. There are no recommendations for new incentive actions 

for this source category at this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 

 
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Policy Initiatives 

Reducing wildfires and the resulting air pollutants requires a sustained and multi-faceted 

approach that employs effective measures to reduce fuel supplies and adequate 

resources to manage fires when they occur. Towards that end, the District currently 

supports policies and initiatives that would encourage rapid disposal of the fuel supply, 

including the following: 

• Additional financial and staffing resources for public and private land managers 

to conduct prescribed burning as an effective means for reducing fuel supplies 

that lead to large and uncontrollable wildfires. 

• Additional resources to manage wildfires when they occur. 

• Lessening or removal of contradictory environmental protection policies that 

prohibit the use of mechanized methods, or prescribed burning to reduce fuels 

when those are the only feasible methods available. 

• Changes in the federal policies that better incorporate air quality concerns by 

shifting focus to prescribed burning and employing fire management techniques 

that reduce air quality impact when wildfires occur. 

While there are no recommendations for new policy initiatives, the recommendation is to 

continue supporting the policies and initiatives identified above. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. No new education and outreach efforts are recommended for these sources 

at this time. The District will continue to work closely with affected sources to ensure 

successful compliance. 
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D.4 AGRICULTURAL PROCESSES 

For many years, the Valley’s agricultural community has employed sound conservation 

management practices to safeguard the natural resources of the land. However, prior 

to 2004, agricultural operations were exempt from air permitting requirements in 

California. Agricultural processors were regulated as permitted sources; and regulation 

of agricultural emissions was limited to Title 13 restrictions on open burning. Particulate 

emissions for unpaved roads and storage piles were regulated through Regulation VIII, 

but only where the extent of these emissions exceeded threshold exemption values. 

In September 2003, Governor Gray Davis signed Senate Bill 700 (2003) which 

amended air pollution control requirements in the California Health and Safety Code to 

include requirements for agricultural sources of air pollution. Since then, the District has 

implemented a series of stringent regulatory changes that added more oversight to 

agricultural operations and set new emission control goals. The agricultural sector has 

responded with significant investments in new emission control programs, and 

considerable changes to their longstanding practices. Collectively, the mitigation 

measures implemented have met or exceeded desired PM10 and VOC emissions 

reductions. The agricultural community has also replaced thousands of old, highemitting diesel irrigation engines with cleaner, more efficient engines and electric motors 

with the assistance of District grant programs. 

This control measure source category includes in-field food and agriculture production, 

and food and agriculture product processing. For the discussions about engines or 

other combustion devices used at these sources, refer to the Combustion Devices 

control measure source category discussion of this appendix. 

Existing Control Strategies 

Due to the degree of difficulty and enormity of the challenge that the Valley faces in 

meeting the National Ambient Air Quality Standards (NAAQS), the District recognizes 

that prohibitory rules alone are not enough to reduce emissions to meet attainment 

requirements and protect public health. The District’s longstanding, progressive 

strategy for reducing emissions is a multifaceted effort that includes incentive programs 

and policy initiatives in addition to prohibitory rules. The following discussion 

summarizes both the existing District efforts to reduce emissions from this source 

category, and evaluations for potential opportunities for further emissions reductions. 

Incentive Programs 

Incentive programs are an integral part of the emission reduction efforts of the District, 

especially where the District lacks direct jurisdiction in establishing emission control 

requirements. The District is currently funding one incentive program that is specific to 

engines used in the agricultural sector. The stationary agricultural irrigation pump 

engine program component of the District’s Heavy-Duty Engine Program was created to 

assist agricultural stakeholders in replacing old polluting internal combustion engines 

with new more efficient and less polluting units or with electric units with zero emissions. 
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For more information about this incentive program please refer to the Combustion 

Devices control measure source category discussion of this appendix. 

In addition to District incentive programs, there are federal funding opportunities offered 

by various organizations including the Natural Resources Conservation Service (NRCS) 

and EPA. The Environmental Quality Incentives Program through NRCS for example, 

provides financial assistance to help plan and implement conservation practices 

specifically to help operators meet environmental regulations. The variety of programs 

that provide funding to agricultural operations have resulted in significant emissions 

reductions for the agricultural sector. 

Policy Initiatives 

Similar to the Incentive programs, the District’s policies and Legislative Platform are 

important components to the District’s strategy to attain federal ambient air quality 

standards. The District utilizes policies and the legislative platform to bring attention to 

major issues that have a direct impact on the Valley’s air quality. 

The District encourages federal support for the continuation of air quality funding in the 

Farm Bill that is designed to accelerate the replacement of agricultural equipment. As 

part of the efforts to attain federal air quality standards in the Valley, the California Air 

Resources Board (ARB) committed to reducing emissions from in-use agricultural 

equipment to achieve five to ten tons per day of NOx reductions in the Valley by 2017. 

This measure would accelerate fleet turnover of equipment with engines to new cleaner 

units that meet new engine NOx standards. This is being implemented through the 

District’s Tractor Replacement Program and the Natural Resource Conservation Service 

(NRCS) Conservation Innovation Grants program. These programs combined are on 

track to achieve the five to ten tons per day of NOx reductions by 2017.

The District supports efforts to secure federal funds and other mechanisms to achieve 

near-term reductions from agricultural equipment that can be credited to the SIP. 

Towards that end, the District supports the inclusion of continued air quality funding 

through the United States Department of Agriculture (USDA) in the Farm Bill, including 

funding to reduce emissions from agricultural equipment. 

Adoption of Senate Bill 705, which phases out the ability to burn certain agricultural 

material in the field, has underlined the importance of biomass facilities in providing a 

mechanism to dispose of this agricultural material. As such, the District supports efforts 

that provide cost effective alternatives to agricultural burning, including subsidies and/or 

preferential utility rates for power produced from biomass and additional research to 

identify other technologically and economically feasible alternatives. The legislative 

platform also supports energy efficiency/alternative energy policies and initiatives that 

will result in emissions reductions and cost effective alternatives to burning agricultural 

waste. 
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Rules and Regulations 

The following is a list of rules specific to the Agricultural Processes category. Each of 

the following rules will be evaluated to examine potential opportunities for additional 

emissions reductions. Refer to other sections of this appendix for discussions on other 

rules that may be applicable to the agricultural community, but that are not agriculturespecific. 

Table D-9 Current Agricultural Process Rules 

Rule Last Amended/ 

Adopted

Rule 4204 Cotton Gins 02/17/2005 

Rule 4550 Conservation Management Practices 08/19/2004 
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D.4.1 Rule 4204 Cotton Gins 

Source Category 

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

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

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

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

established RACT standards. 

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

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

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

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

for saw gins can be higher than that of a roller gin but a roller gin gives a higher quality 

end-product. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.24 0.23 0.24 0.23 0.23 0.24 0.24 0.24

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day

PM2.5 0.37 0.34 0.35 0.34 0.35 0.36 0.36 0.37

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Regulatory Evaluation 

How does District Rule 4204 compare with federal rules and regulations? 

There are no specific federal guidelines applying to cotton gins in terms of New Source 

Performance Standards (NSPS), Control Techniques Guidelines (CTG), Alternative 

Control Technology (ACT), Maximum Achievable Control Technology (MACT) and 

National Emission Standards for Hazardous Air Pollutants (NESHAP). There are 

currently no Best Available Control Technology (BACT) determinations more stringent 

than what is currently required in Rule 4204. 
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How does District Rule 4204 compare to rules in other air districts? 

There are no comparable rules in other air districts in California. Regulations on cotton 

ginning operations do exist in states other than California; upon evaluation of 

regulations in other states, new or more stringent device or stack requirements were not 

identified. The following regulations are included as a part of the District’s analysis: 

• New Mexico Administrative Code 20.2.66.1 Cotton Gins 

• Louisiana Environmental Regulatory Code 

• North Carolina Environmental Management Commissions, Dept. of Environment 

and Natural Resources, Division of Air Quality Article 21B of Chapter 143 

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

62.5, Standards No. 4 Emissions from Process Industries, Section V Cotton Gins 

• Oklahoma Dept. of Environmental Quality, Air Pollution Control, 252:100-23 

Cotton Gins 

• Texas Commission on Environmental Quality, Control of Air Pollution by Permits 

on Cotton Gin Facilities and Cotton Burr Tub Grinders 

Emission Reduction Opportunities 

Rule 4204 is among the most stringent rules in the nation for cotton gins and cotton 

ginning operations, leaving little remaining opportunities for additional emissions 

reductions. Research29 is in progress to determine accurate PM2.5 control efficiencies 

attributable to various types of control equipment utilized to reduce PM emissions from 

the ginning process. The impact of this regulation on PM2.5 emissions has not been 

determined as of yet. As indicated in the emission inventory above, the PM2.5 

emissions are a relatively small contributor to particulate matter emissions in the Valley. 

As a part of due diligence in evaluating potential opportunities to further reduce 

emissions in the Valley, the analysis below includes a discussion of research of the 

undetermined PM2.5 fraction of emissions from cotton ginning operations, and of 

potential, but not feasible, opportunities to reduce emissions further. 

Research and PM2.5 Fraction 

Research is currently being conducted by the United States Department of Agriculture – 

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

EPA, the California Air Resources Board (ARB) and the District to measure actual 

PM10 and PM2.5 emissions from stack sources and fugitive emissions in and around 

the ginning facility. This research will provide emission factors for comparison to 

previous estimations that are included in emission inventories and will provide data for 

both types of cotton gins currently in use in California. This project was designed to 

measure emissions from facilities with current emissions control technologies in place 

and to improve emission estimation by measurement with the highest quality methods 

and instruments. The project was not designed to evaluate new technologies or 

measures to further reduce emissions. Preliminary results for the seven gins that were 

 

29 Agricultural Research Service. (2012). 2011 Final Report for Characterization of Cotton Gin Particulate Matter 

Emissions. United States Department of Agriculture. 
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sampled for the project indicate the estimated ratio of PM2.5 to PM10 is approximately 

15%.30 This fraction of PM2.5 to PM10 is lower than indicated in the emissions 

inventory currently being used. According to the 2011 Final Report update31, this study 

will finish the laboratory analysis for the final gin in early 2012 and continue processing 

stack sampling data. 

1D-3D Cyclones with Expansion Chamber 

Currently, all cotton gins in the Valley are required to operate using a 1D-3D cyclone. 

About two thirds of the 1D-3D cyclones used in the Valley have an expanded chamber 

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

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

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

small-diameter (D/4) exit32. However, there is no completed research indicating the 

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

expanded chamber. As 1D-3D cyclones are already required by the current rule, and 

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

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

Loadout 

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

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

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

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

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

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

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

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

Mechanical Conveyance 

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

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

constructed or re-built cotton gins. Mechanical conveyance almost entirely eliminates 

emissions from gin trash handling exhaust streams, which were previously moved 

pneumatically. The gin trash handling systems only comprise a fraction of the 

emissions that are released from the full cotton ginning process. Newer or re-built gins 

are able to accommodate a mechanical conveyance system since they are able to 

design the gin around the equipment and space needed. Operators that have installed 

a mechanical conveyance system for their gin have had to build a lower floor, below the 

main level containing the major gin equipment, to house the mechanical conveyors. 

Therefore, as confirmed by industry representatives and equipment manufacturers, it is 

not technologically feasible to retrofit existing gins with a mechanical conveyance 

 

30 Agricultural Research Service. (2012). 2012 2nd Quarter Report for Characterization of Cotton Gin Particulate 

Matter Emissions. United States Department of Agriculture. 

31 Agricultural Research Service. (2012). 2011 Final Report for Characterization of Cotton Gin Particulate Matter 

Emissions. United States Department of Agriculture. 

32 Baker R.V. and Hughs S.E., 1998. Influence of Air Inlet and Outlet Design and Trash Exit Size on 1D3D Cyclone 

Performance. Transactions of the ASAE, vol. 42(1): 17-21.
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system to replace existing trash handling equipment. Additionally, any new facilities 

would trigger New Source Review requirements and would be required to implement 

BACT level controls. 

Plenum Chambers 

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

placed upstream of selected cyclones to remove large trash. Studies have been 

inconclusive in demonstrating an increase in PM control efficiency with the utilization of 

a plenum chamber. Most cotton ginning facilities that have chosen to install plenum 

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

prolonging the life of the cyclones, and not for increased particulate matter controls. 

The District’s analysis indicates that there are no feasible opportunities for additional 

emission reductions for this source category. 

Risk-based Strategy Analysis 

The emissions from this source category contribute 0.6% of average winter PM2.5 

emitted from stationary and area sources in the 2012 emission inventory. The 

emissions from this source category are relatively small throughout the year, with no 

significant increase in emission levels in the winter months. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4204. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4204. 

Incentive Action 

Units subject to Rule 4204 are currently regulated stationary sources making 

opportunities for incentive actions minimal; there are no recommendations for incentive 

actions at this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 

Policy Initiatives 

The District does not currently have any policy initiatives specific to cotton ginning 

activities. There are no recommendations for new policy initiatives specific to these 

units.
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Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for additional education and outreach efforts 

for these sources. The District will continue to work closely with affected sources to 

ensure successful compliance. 
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D.4.2 Rule 4550 Conservation Management Practices 

Source Category 

Rule 4550 was adopted on August 19, 2004 to help bring the Valley into attainment of 

federal PM10 standards, and applies to on-field farming and agricultural operation sites 

located within the Valley. Rule 4550 has served as a model for other regions seeking to 

reduce fugitive particulate emissions from agricultural sources. EPA finalized approval 

of Rule 4550 on February 14, 2006 and determined that the rule met Best Available 

Control Measure (BACM) requirements of Clean Air Act (CAA) 189(b). 

The District worked extensively with numerous stakeholders, growers, and the 

Agricultural Technical Committee for the San Joaquin Valleywide Air Pollution Study 

Agency (AgTech) for two years prior to developing the Conservation Management 

Practices (CMP) Rule. Rule 4550 is unique because it is intended primarily to reduce 

fugitive particulate matter emissions and is based upon a menu approach of control 

techniques to accommodate the variability of agricultural industries. The selected 

CMPs are listed on application forms that are submitted to the District for approval as a 

CMP Plan. The District worked with agricultural stakeholders and other agencies, such 

as the Natural Resources Conservation Service (NRCS), to ensure affected sources 

were assisted as much as possible in understanding and complying with the 

requirements of Rule 4550. Efforts included creating an informational pamphlet, 

assisting stakeholders through the application process, and extensive outreach through 

40 workshops throughout the Valley. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 19.31 18.90 18.74 18.66 18.57 18.49 18.41 18.33

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day

PM2.5 15.10 14.72 14.57 14.50 14.42 14.35 14.28 14.20

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0
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Regulatory Evaluation 

How does District Rule 4550 compare with federal rules and regulations? 

Federal requirements such as New Source Performance Standards (NSPS), National 

Emission Standards for Hazardous Air Pollutants (NESHAP), and Maximum Achievable 

Control Technology (MACT) requirements are not applicable to this source category; 

additionally, there are no EPA Control Techniques Guidelines (CTGs) or Alternative 

Control Techniques (ACTs) listed for this category. 

How does District Rule 4550 compare to rules in other air districts? 

Rule 4550, when compared to other California air districts’ rules for similar sources and 

is found to be at least as stringent as the analogous rules for Imperial County Air 

Pollution Control District (ICAPCD) Rule 806 (Conservation Management Practices) and 

SMAQMD Rule 215 (Agricultural Permit Requirements and New Agricultural Permit 

Review). SCAQMD and the Arizona Department of Environmental Quality have 

adopted agricultural best management practices programs, which were approved by 

EPA as Best Available Control Measures (BACMs); however, the District’s CMP rule 

exceeds these standards. Similar rules were not found for BAAQMD or VCAPCD. 

Emission Reduction Opportunities 

Rule 4550 was the first rule of its kind in the nation to target fugitive particulate 

emissions from agricultural operations. Through this rule, PM10 emissions have been 

reduced by 35.3 tons per day, which is approximately a 24% reduction for this source 

category. Similarly, implementation of Rule 4550 by agricultural operations has resulted 

in the reduction of PM2.5 emissions through the reduction of passes of agricultural 

equipment and implementation of other conservation practices. A full evaluation of the 

success seen through implementation of the Rule 4550 CMP Program can be found on 

the District’s website at: 

http://www.valleyair.org/farmpermits/updates/cmp_program_report_for_2005.pdf. 

While Rule 4550 has been successful in reducing both PM10 and PM2.5 emissions, 

recent studies have indicated that the PM2.5 fraction of emissions makes up a small 

portion of the total particulate emissions from agricultural operations. Additionally, 

particulate emissions from agricultural operations are geologic in nature. As described 

in Chapter 2 of this plan, these geologic particulate emissions make up a relatively small 

portion of the overall PM2.5 concentrations during the winter season, and have 

relatively low toxicity. Accordingly, particulate emissions from agricultural sources do 

not play a significant role with regard to attainment of the 24-hour PM2.5 standard 

addressed by this plan, and Rule 4550 is primarily a PM10 reduction strategy. EPA’s 

approval of Rule 4550 as BACM and the District’s review of similar rules in other 

regions also demonstrate that the District has adopted the most stringent rule of its kind. 

Given the relatively low contribution that emissions from this category make to the 

Valley’s 24-hour PM2.5 concentrations and current stringent requirements under Rule 
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4550, the District has not identified any additional opportunities for further emission 

reductions from this category. 

Risk-based Strategy Analysis 

Particulate matter emissions from agricultural operations are primarily geologic in 

nature, and do not constitute a significant fraction of the total PM2.5 concentrations 

during the winter season, the period during which exceedances for the 24-hour PM2.5 

standard are observed. As discussed in Chapter 2, research indicates that the geologic 

fraction of PM2.5 has a relatively low toxicity. Given the relative insignificance of PM2.5 

emissions from this category and the relative low toxicity, further reductions from this 

category will not significantly expedite attainment or provide accelerated health benefits. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4550. 

Regulatory Action 

There are no recommendations for additional regulatory actions for Rule 4550. The 

District will continue to work collaboratively with NRCS, researchers, and agricultural 

stakeholders to evaluate current and potential CMPs to determine if there are more 

effective options for reducing emissions. Further study through additional research on 

the PM2.5 fraction and effectiveness of CMPs in reducing PM2.5 emissions is 

recommended. 

Incentive Action 

There are no recommendations for new incentive actions at this time. 

Technology Advancement Action 

Through its Technology Advancement Program and other research efforts, the District 

will continue to seek projects that support the development of new technologies and 

practices that provide further potential options for reducing emissions from agricultural 

operations. One example of a research effort in this area includes a recent study aimed 

at understanding of the effectiveness of reducing particulate emissions through 

implementation of CMPs. This Regional Applied Research Effort (RARE) is a 

collaborative study by the District and EPA, and is focused on comparatively evaluating 

particulate emissions from conventional agricultural tillage methods and a CMP tillage 

method utilizing the Optimizer during after-harvest land preparation. The Optimizer is a 

tillage implement that incorporates functions from multiple conventional tillage 

implements into one piece of equipment. Preliminary results indicate that the Combined 

Operations tillage method reduced PM2.5 emissions by 29%, PM10 by 60%, and total 

suspended particulates (TSP) by 25%.33 The District will continue to seek additional 

opportunities for supporting the advancement of new technologies and practices in this 

area. 

 

33 Williams, D. et al. Los Banos, CA Fall 2007 Tillage Campaign: Data Analysis. 
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Policy Initiatives 

The District currently supports efforts to secure federal funds and other mechanisms to 

achieve near-term reductions from agricultural equipment that can be credited to the 

State Implementation Plan (SIP), and supports the inclusion of continued air quality 

funding through the NRCS in the Farm Bill, including funding to reduce emissions from 

agricultural equipment and conservation practices. Although there are no 

recommendations for new policy initiatives, the recommendation is to continue 

supporting the current District legislative platform items as identified above. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. The outreach program developed collaboratively with the USDA-NRCS and 

agricultural stakeholders to assist affected agricultural sources to understand and 

comply with Rule 4550 requirements has served as a model for other agencies seeking 

to adopt similar strategies. The District will continue to work closely with affected 

sources to ensure successful compliance. 
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D.5 RESIDENTIAL AND COMMERCIAL 

Significant emissions have been reduced in the Valley through several generations of 

regulations focused on industrial stationary sources. With emissions from stationary 

sources having been greatly reduced, the Valley is receiving diminishing returns from 

new controls on these stationary sources. The work of identifying more regulatory 

control measure source categories for stationary sources continues, but it is critical that 

Valley residents reduce emissions in their daily routines as well. 

Population-wise, the Valley is California’s fastest growing region, with its population 

expected to grow to over four and a half million by 2019, the expected attainment year 

for the 2006 PM2.5 standard. Increased population results in increased vehicle activity 

and consumer product use, which leads to increased pollutant emissions – potentially 

undermining progress made by regulations. 

The District’s regulatory jurisdiction is somewhat limited when it comes to pollutant 

sources linked to the general population. For example, ARB regulates consumer 

products. Also, since direct regulatory authority on motor vehicle tailpipe emissions 

rests with ARB and EPA, the District can only decrease pollutant emissions from 

vehicles through incentives, public outreach, and innovative regulations focused on 

fleets or indirect means (see Appendix C on mobile source control measures for more 

information). 

Through the District’s Rule 4901 (Wood Burning Fireplaces and Wood Burning 

Heaters), Valley residents are taking actions that are achieving significant reductions of 

health-impacting pollutants when and where these reductions are most 

needed. Through the District’s Healthy Air Living program, Valley residents (as well as 

businesses) are provided the tools to make air quality a priority in their day-to-day 

decisions. 

Additionally, emissions from under-fired charbroilers in the Valley continue to be a 

concern. Local restaurants using uncontrolled under-fired charbroilers can often heavily 

impact residents in the surrounding neighborhoods, especially on days when dispersion 

is poor. Emissions from this source are known to be hazardous to human health, and 

therefore reductions in this category would be valuable in light of the District’s Riskbased Strategy. 

There is potential for both regulatory and innovative approaches for reducing emissions 

from residential sources, as is shown in the following control measure source category 

discussion. 
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Existing Control Strategies 

Due to the degree of difficulty and enormity of the challenge that the Valley faces in 

meeting the National Ambient Air Quality Standards (NAAQS), the District recognizes 

that prohibitory rules alone are not enough to reduce emissions to meet attainment 

requirements and protect public health. The District’s longstanding, progressive 

strategy for reducing emissions is a multifaceted effort that includes incentive programs 

and policy initiatives in addition to prohibitory rules. The following discussion 

summarizes both the existing District efforts to reduce emissions from this source 

category, and evaluations for potential opportunities for further emissions reductions. 

Incentive Programs 

Incentive programs are an integral part of the emission reduction efforts of the District, 

especially where the District lacks direct jurisdiction in establishing emission control 

requirements. The District is currently funding two incentive programs that affect the 

residential sector. The Clean Green Yard Machine program has provided $1,472,977 in 

grant money toward the replacement of 8,600 gas-powered lawn mowers in the Valley. 

For more details on the Clean Green Yard Machine program and other programs 

related to lawn care refer to the Additional Sources section of this appendix. The Wood 

Stove Change Out program has provided $1,190,000 in grant money toward the 

replacement of 1,988 units, resulting in a reduction of 342 tons of particulate matter 

emissions in the Valley. 

In an effort to demonstrate and establish a proven technology for reducing emissions 

from under-fired charbroilers in the Valley, the District established the Charbroiler 

Incentive Program (ChIP) in October 2009, concurrent with the last amendment of Rule 

4692. Due to lack of participation from the industry, the program was extended until 

March 2011 and outreach efforts were increased. However, no applications for funding 

were submitted during the extended solicitation period. With new technology options 

potentially becoming available, the District will continue to seek local demonstration 

projects to develop control technology options. 

Policy Initiatives 

Similar to the Incentive Programs, the District’s policies and Legislative Platform are 

important components to the District’s strategy to attain federal ambient air quality 

standards. The District utilizes policies and the legislative platform to bring attention to 

major issues that have a direct impact on the Valley’s air quality. The District supports 

policies and has legislative platforms for energy efficiency and clean alternatives, and 

opposes legislation that limits the District’s ability to regulate the installation and 

utilization of wood-burning devices at residences. 

The District promotes energy efficiency and clean alternatives as they provide an 

opportunity for meaningful reductions in emissions in areas with well-established strong 

regulatory measures on stationary sources such as in the Valley. For more details 

about these efforts refer to the Additional Sources section of this appendix. 
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Rules and Regulations 

The following is a list of rules specific to the Residential and Commercial category. 

Each of the following rules will be evaluated to examine potential opportunities for 

additional emissions reductions. 

Table D-10 Current Residential and Commercial Rules 

Rule Last Amended/ 

Adopted

Rule 4692 Commercial Charbroiling 9/17/2009 

Rule 4901 Wood Burning Fireplaces and Wood 

Burning Heaters 10/16/2008 

Rule 4902 Residential Water Heaters 03/19/2009 

Rule 4905 Natural Gas-Fired, Fan-Type, Residential 

Central Furnaces 10/20/2005 
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D.5.1 Rule 4692 Commercial Charbroiling 

Source Category 

There are two types of commercial charbroilers: chain-driven and under-fired. A chaindriven charbroiler is a semi-enclosed broiler that moves food mechanically through the 

device on a grated grill to cook the food for a specific amount of time. An under-fired 

charbroiler has a metal "grid," a heavy-duty grill like that of a home barbecue, with gas 

burners, electric heating elements, or wood under the grid to cook the food. The smoke 

and vapors generated by cooking on either type of charbroiler contain water, volatile 

organic compounds (VOCs), and PM. Larger particles and grease are typically 

captured by the grease filter of the ventilation hood over the charbroiler. The remaining 

VOCs and PM2.5 are exhausted outside the restaurant, unless a secondary control is 

installed. 

 

Currently, District Rule 4692 reduces emissions by requiring catalytic oxidizers for 

chain-driven charbroilers that meet rule applicability thresholds. Charbroiler exhaust is 

directed through the catalytic oxidizer with little loss of temperature. As hightemperature exhaust goes through the heated catalyst, PM and VOC are oxidized to 

carbon dioxide and water vapor. This chemical reaction releases energy that heats the 

catalyst and is transferred to a heat recovery system, so no additional fuel is needed for 

the unit. 

The original rule, adopted in March 2002, reduced PM2.5 emissions from chain-driven 

charbroilers by 84%. The September 2009 rule amendment expanded rule applicability 

to more chain-driven charbroilers, reducing 25% of the remaining PM2.5 chain-driven 

charbroiler emissions. EPA finalized approval for Rule 4692 on November 3, 2011. 

The District evaluated Rule 4692 in its RACT State Implementation Plan (SIP) 

demonstration; however, EPA noted in its Technical Support Document (TSD) for the 

approval of Rule 4692 that the rule is not subject to RACT because it is not subject to 

Control Techniques Guidelines (CTG) requirements and it does not regulate major 

sources. 

The District created and implemented a pilot program, the Charbroiler Incentive 

Program (ChIP), to provide grant funding to cover a significant portion of the cost of 

installing particulate control devices on under-fired charbroilers. However, there has 

been no stakeholder interest in this program so far. Zero proposals were submitted, so 

no projects have been funded under ChIP. 
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The District has also been tracking and involved with technology demonstration projects 

for under-fired charbroilers at other agencies: 

• SCAQMD: South Coast has partnered with the University of California at 

Riverside to test control technologies for under-fired charbroilers at the College of 

Engineering’s Center for Environmental Research and Technology (CE-CERT). 

District staff participated in proposal review for this program in early 2012 and 

have been actively tracking the progress of this project, which should be 

complete by the end of 2012. 

• EPA: EPA contracted with Innova Tech, who has manufactured a low-cost and 

low-maintenance under-fired charbroiler filtration device. Initial testing of Innova 

Tech’s NovaMistTM aerosol particulate filtration technology has shown that their 

system has the capability of removing over 98% of aerosol particulates at 

particulate concentrations less than or equal to 40 μg/m3

, as well as a general 

VOC reduction of 42%. This control device is also self-cleaning, continually 

degreasing itself during use. The next step for Innova Tech is to partner with 

other corporations to aid in the commercialization and marketing of their product. 

Emission Inventory – All Charbroilers 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 2.85 2.89 2.98 3.03 3.08 3.13 3.17 3.22

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day

PM2.5 2.85 2.88 2.98 3.03 3.08 3.12 3.17 3.22

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

This emission inventory includes emissions from both chain-driven and under-fired 

charbroilers. Based on the data included in the District’s 2009 emission inventory 

methodology for commercial charbroiling, chain-driven charbroilers account for about 

42% of the charbroiling inventory, and under-fired charbroilers account for about 58% of 

the inventory. 

The emissions inventory above accounts for emissions reductions achieved by Rule 

4692’s controls on chain-driven charbroilers. The inventory above is grown in future 

years due to human population growth in the Valley.
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Emission Inventory – Under-Fired Charbroilers 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 1.66 1.68 1.73 1.76 1.79 1.82 1.84 1.87

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day

PM2.5 1.66 1.68 1.73 1.76 1.79 1.82 1.84 1.87

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

These emissions inventories include emissions from food cooking only, not from fuel 

use. The combustion of the fuel source for the cooking equipment is a very small 

component of the NOx and SOx emissions in the Stationary Source Fuel Combustion 

category, “Service and Commercial,” which is not reflected in the inventory for this 

control measure. 

Regulatory Evaluation 

How does Rule 4692 compare with federal rules and regulations? 

There is currently no guidance given for this source category under the federal 

Alternative Control Techniques (ACT) documents, the New Source Performance 

Standards (NSPS), the National Emission Standards for Hazardous Air Pollutants 

(NESHAP), and the Maximum Achievable Control Technology (MACT) requirements. 

Additionally, there is no EPA CTG listed for this category. 

How does Rule 4692 compare to rules in other air districts? 

Rule 4692 was compared to other California air districts’ rules for similar sources and 

was found to be more stringent than SCAQMD Rule 1138 (Control of Emissions from 

Restaurant Operations) and VCAPCD (Rule 74.25 Restaurant Cooking Operations). 

Rule 4692 and these two rules apply to chain-driven charbroilers only, and not underfired. However, the SCAQMD and VCAPCD rules apply to charbroilers cooking 875 

pounds of meat or more per week, whereas the District rule applies to charbroilers 

cooking 400 pounds of meat or more per week. BAAQMD Regulation 6 Rule 

2(Commercial Cooking Equipment) is applicable to chain-driven charbroilers in a 

restaurant that purchases 500 pounds of beef or more per week or an under-fired 

charbroiler in a restaurant that purchases 1,000 pounds of beef or more per week. 

SMAQMD does not currently have a rule for commercial charbroiling. 

As previously mentioned, BAAQMD Regulation 6 Rule 2 regulates both chain-driven 

and under-fired units. Newly installed under-fired units with more than 10 square feet of 

cooking area are required to limit emissions to 1 lb of PM10 per 1,000 lbs of cooked 
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beef. Effective January 2013, the same emissions requirements will also apply to preexisting units. However, as the BAAQMD rule is implemented, a significant portion of 

under-fired charbroilers are below the applicability thresholds for grill size or amount of 

food cooked, and are thus exempt from rule requirements. 

Emission Reduction Opportunities

Potential emission reduction opportunities from this source category include emissions 

from two types of charbroilers: chain-driven charbroilers and under-fired charbroilers. 

District Rule 4692 is one of the most stringent rules in the nation for chain-driven 

charbroilers and therefore the primary focus for potential emissions reductions as 

discussed below focus on the under-fired charbroilers. Discussions on both 

technologies are discussed below. 

Chain-Driven Charbroilers 

Rule 4692 requires emission controls for chain-driven charbroilers that cook 400 pounds 

of meat or more per week. In 2009, the amended rule was estimated to apply to about 

280 of the 427 chain-driven identified charbroilers of the Valley. This rule thus applies 

to about 65% of the units and a much greater percentage of the total emissions from 

chain-driven charbroilers since they are higher use. The applicability threshold for 

chain-driven charbroilers under Rule 4692 could be lowered to make smaller facilities 

subject to the rule. However, these currently-exempt chain-driven units are a very small 

portion of the total inventory for this category. Emissions reductions would be minimal 

and costly through this approach. Furthermore, the District’s applicability threshold is 

already lower than that of other air districts. 

Under-Fired Charbroilers 

Rule 4692 does not currently require emissions controls for under-fired charbroilers. 

Catalytic oxidizers are not effective for reducing emissions from under-fired charbroilers 

because the exhaust from these devices loses too much heat as it is directed to the 

control device, and the reactions at the catalyst cannot take place under this lower 

temperature. The following control strategies are more effective for under-fired 

charbroilers: 

• High efficiency particulate-arresting (HEPA) filtration systems: This system 

adds a HEPA filter to the appliance’s existing grease filters to effectively 

eliminate particulates down to about 0.3 microns in diameter. System 

maintenance is relatively easy to perform, but filters need to be regularly 

changed (perhaps weekly, depending on the amount of food cooked). 

 

• Electrostatic precipitators (ESPs): Exhaust particles become electrically 

charged as they pass through an electrically charged screen. These ionized 

particles are then collected by one of two oppositely-charged plates. ESP 

systems need filtration prior to the ESP itself to remove grease and larger 

particles from kitchen exhaust. These devices are cleaned daily with a clean-inplace system, and more thorough cleaning is required once or twice a year. 
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Routine maintenance often requires hiring an outside company, since the ESP 

plates can weigh as much as 75 pounds. 

• Wet scrubbers: A fine stream of water and detergent “washes” the particulates 

from the kitchen exhaust. The particulate/water/detergent mix is then filtered: 

the filtered water/detergent mix is recycled through to clean more exhaust, and 

the particulate-laden wash water is discharged to the sewer system. In addition 

to the cost of the system itself, associated water/sewer usage costs and 

detergent costs can be high, although recent improvements in design are 

improving system efficiencies. 

 

These controls for under-fired charbroilers were unproven and extremely costly as of 

the District’s 2009 amendment of Rule 4692. The costs of these under-fired charbroiler 

controls, as analyzed in 2009, ranged from $37,500 to $104,000, with a cost 

effectiveness of up to $58,200 per ton of PM2.5 reduced. However, the control 

technology for under-fired units has continued to develop over the past few years, in 

part through the SCAQMD and EPA technology demonstration efforts. Since underfired charbroilers are a larger part of the total commercial charbroiling inventory, and 

since these units are currently unregulated in the Valley, there is potential to achieve 

emissions reductions from under-fired charbroilers. 

In parallel with this plan, SCAQMD has also included a draft commitment in Chapter 4 

of their Draft 2012 AQMP to achieve a 1 tpd PM2.5 reduction from under-fired 

charbroilers, though the details of their approach are yet to be determined34. South 

Coast AQMD would submit their approach into the SIP once technically feasible and 

cost effective options are confirmed. 

Risk-based Strategy Analysis 

The emissions from units subject to Rule 4692 contribute 5.2% of average winter PM2.5 

emitted from stationary and area sources in the 2012 emission inventory. Although the 

emissions from commercial charbroiling are small in comparison to the total emissions 

inventory, this category is one of the largest single contributors of directly emitted PM2.5 

in the Valley. Photochemical modeling conducted for this plan shows that reducing 

commercial charbroiling emissions would contribute to improved PM2.5 air quality and 

PM2.5 attainment in the Valley. 

Furthermore, charbroiling emissions occur in populated areas. The PM2.5 species 

associated with charbroiling is organic carbon (OC) 35; as noted in Chapter 2, health 

research shows there is evidence of high toxicity and significant health effects 

associated with OC. Since the cooking of meat can release carcinogenic PM2.5 

species like polycyclic aromatic hydrocarbons (PAH), controlling emissions from underfired charbroilers would have a substantial positive impact on public health. The air 

quality impacts on neighborhoods near restaurants with under-fired charbroilers can be 

significant on days when meteorological conditions are stable, when dispersion is 

 

34 http://aqmd.gov/aqmp/2012aqmp/draft/Chapters/Ch4.pdf 

35 See Schauer and Cass (2000) Environmental Science and Technology, Vol. 34 (9), pp. 1821-1832.
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limited and emissions are trapped near the surface within the surrounding 

neighborhoods. This potential for neighborhood-level concentration of emissions during 

evening or multi-day stagnation events raises environmental justice concerns. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4692. 

Regulatory Action 

The recommendation is to amend Rule 4692 to reduce PM2.5 emissions from underfired charbroilers. As part of this process, the District would conduct a thorough review 

of all available information about under-fired charbroilers and under-fired charbroiler 

controls. The District would take advantage of the most recent technology 

demonstration information available and, if needed, initiate an independent technology 

demonstration. To allow sufficient time for this and other related rule development 

work, the recommendation is to amend Rule 4692 in 2016. The District estimates that 

this amendment would achieve, at minimum, a 20% reduction in the baseline emissions 

inventory for under-fired charbroilers. The modeling conducted for this plan shows that 

reducing emissions from under-fired charbroiling by 20% in Kern County is necessary 

for attainment; thus, by reducing emissions 20% Valley-wide, the District achieves 

significant health benefits Valley-wide per the District’s Risk-based Strategy. Refer to 

Chapter 9 for more details. 

Table D-11 Estimated Emissions Reductions 

 2007 2012 2014 2015 2016 2017 2018 2019 

PM2.5 Tons per day – winter season 

Kern County 

(Attainment Need) 0 0 0 0 0 0.1 0.1 0.1 

Other Valley Counties 0 0 0 0 0 0.3 0.3 0.3 

Valley-wide Total 0 0 0 0 0 0.4 0.4 0.4 

Incentive Action 

The District’s current ChIP is a pilot demonstration plan, rather than a more widelyavailable incentive program. After completion of a few pilot demonstration projects 

under ChIP, though, the District could consider expanding its charbroiling incentive 

efforts into a broader incentive program. Therefore, although there are no 

recommendations for new incentive actions at this time, the recommendation is to 

continue the District ChIP. 

Technology Advancement Action 

The District will also seek to identify restaurants to participate in the District’s existing 

ChIP pilot program to demonstrate promising under-fired charbroiler emissions controls 

in a working-restaurant setting in the Valley. Such a demonstration project could 

eventually be developed into a larger incentive program. Additionally, the District will 

continue to collaborate with EPA and South Coast technology demonstration efforts for 
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under-fired charbroiling. The South Coast project should be completed by the end of 

2012, and may yield useful information to assist in implementing emission reduction 

strategies for this category. 

Policy Initiatives 

The District is not currently supporting any policy initiatives specific to commercial 

charbroiling and there are no recommendations for new policy initiatives for this source. 

 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. It is recommended that the District provide strong stakeholder outreach in 

conjunction with the regulatory, incentives, and technology demonstration commitments 

as appropriate. The District will continue to work closely with affected sources to ensure 

successful compliance. 
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D.5.2 Rule 4901 Wood Burning Fireplaces and Wood Burning 

Heaters 

Source Category 

Residential wood burning is one of the Valley’s largest sources of directly-emitted 

PM2.5 in the winter. Rule 4901 (Wood Burning Fireplaces and Wood Burning Heaters) 

limits emissions from wood burning fireplaces, wood burning heaters, and outdoor wood 

burning devices. Rule 4901 also restricts the sale and transfers of non-compliant wood 

burning devices, and limits the installation of wood burning devices in new residential 

developments. 

Through the Check Before You Burn program, which is based on Rule 4901, the District 

has declared and enforced episodic wood burning curtailments, also called “No Burn” 

days, since 2003. Check Before You Burn and District Rule 4901 reduce harmful 

species of PM2.5 when and where those reductions are most needed: in impacted 

urbanized areas when the local weather is forecast to hamper PM dispersion. 

Rule 4901 was adopted in 1993 and has been amended twice. The adoption of Rule 

4901 established a public education program on techniques to reduce wood burning 

emissions. It also enforced EPA Phase II requirements for new wood burning heaters, 

prohibited the sale of used wood burning heaters, established a list of prohibited fuel 

types, and required the District to request voluntary curtailment of wood burning on days 

when the ambient air quality was unhealthy. 

In 2003, the rule was amended to include episodic wood burning curtailments when air 

quality was forecast to be at 150 or higher on the air quality index (AQI), which is 

equivalent to a PM2.5 concentration of 65 μg/m3. The 2003 amendments also added 

restrictions on the installation of wood burning devices in new residential developments, 

based on housing density. In 2008, the District amended Rule 4901 again, this time to 

lower the mandatory curtailment level to a PM2.5 concentration of 30 μg/m3 (based on 

EPA’s 2006 PM2.5 National Ambient Air Quality Standard (NAAQS) of 35 μg/m3 with 

an added margin of safety). The 2008 amendments also included a contingency 

measure to lower the wood burning curtailment level to 20 μg/m3 in the event that EPA 

finds that the Valley does not attain the 1997 PM2.5 air quality standard in 2014. EPA 

finalized approval for District Rule 4901 on November 10, 2009. 

Rule 4901 wood burning curtailments only apply in areas with natural gas service, and 

wood burning curtailments do not apply to homes for which wood burning is the only 

source of heat. Compared to other District rules, District Rule 4901 provides for the 

most cost effective means to reduce wintertime PM2.5 concentrations. Direct PM2.5 

emissions are controlled by approximately 14% for this source category during the wood 

burning season. The full effectiveness of the rule can be understated when considered 

in terms of annual average emissions or even “average winter emissions”. On a Valleywide “No Burn” day, Rule 4901 has the potential to reduce 16 tons of directly emitted 

PM2.5. 
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Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 10.63 4.48 4.28 4.28 4.28 4.28 4.28 4.28

NOx 1.20 0.50 0.48 0.48 0.48 0.48 0.48 0.48

SOx 0.20 0.08 0.08 0.08 0.08 0.08 0.08 0.08

Winter Average - Tons per day

PM2.5 20.72 8.73 8.35 8.35 8.35 8.35 8.35 8.35

NOx 2.35 0.98 0.94 0.94 0.94 0.94 0.94 0.94

SOx 0.39 0.16 0.15 0.15 0.15 0.15 0.15 0.15

Regulatory Evaluation 

How does District Rule 4901 compare with federal rules and regulations? 

Rule 4901 is as stringent as the current federal New Source Performance Standards 

(NSPS) (40 CFR 60 Subpart AAA (Standards of Performance for New Residential 

Wood Heaters). The District continues to track EPA’s current efforts to revise this 

NSPS. Additionally there are no EPA Control Techniques Guidelines (CTG), Alternative 

Control Techniques (ACT), National Emission Standards for Hazardous Air Pollutants 

(NESHAP), or Maximum Achievable Control Technology (MACT) guidelines for this 

source category. 

How does District Rule 4901 compare to rules in other air districts? 

Rule 4901 is compared to other air districts’ rules for similar sources, including 

Washington State’s Department of Ecology regulation Chapter 173-433 WAC (Solid 

Fuel Burning Devices); Colorado Air Quality Control Commissions Regulation No. 4, 

Spokane Regional Clean Air Agency Regulation I Article VIII; Oregon Department of 

Environmental Quality Division 262 (Heat Smart Program for Residential Woodstoves 

and Other Solid Fuel Heating Devices); SCAQMD Rule 445 (Wood Burning Devices); 

BAAQMD Regulation 6 Rule 3 (Wood-Burning Devices); Yolo-Solano Air Quality 

Management District Rule 2.40 (Wood Burning Appliances), and SMAQMD Rules 417 

(Wood Burning Appliances); and 421 (Mandatory Episodic Curtailment of Wood and 

other Solid Fuel Burning). SCAQMD Rule 445 prohibits installation of wood burning 

devices in new developments that have access to natural gas service. However, 

District Rule 4901 has the most stringent wood burning curtailment level, compared to 

those of other air districts. 
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Emission Reduction Opportunities 

The District evaluated Rule 4901 for potential opportunities to reduce emissions. 

Potential opportunities evaluated include an analysis of benefits from reducing the 

curtailment level, allowing cleaner wood burning devices under certain circumstances to 

encourage consumers to switch to these clean devices from uncontrolled fireplaces, the 

possibility of extending the wood burning season, and the possibility of amending the 

portion of the rule pertaining to the quantity of units allowed in new developments. 

These evaluations resulted in the District committing to amend Rule 4901 through a 

public rule-amending process (see Chapters 5 and 10 for these commitments). The 

analyses are as follows: 

Curtailment Level 

A potential opportunity for further emissions reductions is to lower the curtailment level, 

which would reduce emissions by increasing the number of “No Burn” days. Lowering 

the curtailment level below the current level would reduce the build-up of emissions 

during the long stagnation periods experienced in the Valley during the winter season, 

and would help avoid exceedances of the PM2.5 standard. The table below shows the 

average number of days wood burning could be prohibited if the curtailment level was 

reduced below the current level of 30 μg/m3, based on 2009-2012 air quality forecasts. 

The actual number of “No Burn” days that would occur under the lower curtailment level 

would likely be lower when actually implemented, since additional emissions reductions 

will phase in and improve PM2.5 air quality before the lower “No Burn” level would take 

effect. As discussed in Chapter 4, this reduction in emissions during the peak PM2.5 

winter would significantly reduce PM2.5 concentrations in Kern County, and greatly 

assist in attaining the 24-hour PM2.5 standard. 

Table D-12 Average Number of Days Forecast Above Curtailment Thresholds* 

Current 

Threshold 

Contingency 

Threshold 

County >=30 μg/m3 >=25 μg/m3 >=20 μg/m3 

San Joaquin 18 30 47

Stanislaus 36 62 74

Merced 26 43 63

Madera 37 56 73

Fresno 53 75 85

Kings 41 60 73

Tulare 40 59 71

Kern 47 66 78

Kern (Greater Frazier Park Area) 0 2 3

 *Based on the 2009-10, 2010-11, and 2011-12 wood-burning seasons. 

Wood burning curtailments under Rule 4901 have been shown to significantly reduce 

PM2.5 concentrations on “No Burn” days, as demonstrated in the District’s annual “End 

of the Season Wood Burning Reports.” Currently, Valley-wide curtailment of wood 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-121 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

burning during winter is estimated to reduce 16 tons per day of PM2.5 emissions. 

Prohibitions are declared by county or forecast area and apply to areas with natural gas 

service, allowing the rule to target the most densely-populated urban areas that are 

most likely to experienced localized effects of wood burning in the neighborhood. 

Although a “No Burn” day can increase a resident’s natural gas costs, natural gas can 

more efficiently heat the whole home; some homes could also offset increased natural 

gas costs by spending less on wood. Compared to other District rules, curtailing 

burning under Rule 4901 is the most cost effective rule for reducing PM2.5 

concentrations. 

Wood Burning Devices 

Rule 4901 limits the installation of new wood burning devices, and limits the use of 

wood burning devices on “No Burn” days in areas that have natural gas service. When 

and where residents are allowed to burn and choose to do so, they are encouraged to 

burn as cleanly as possible. For example, dry, seasoned wood and manufactured logs 

burn cleaner than unseasoned wood. 

Upgrading a home’s wood burning device also reduces air pollutant emissions on days 

when wood burning is allowed. By operating more efficiently, these devices can lower 

the overall home heating cost. District Rule 4901 neither prohibits nor requires wood 

burning device upgrades. However, the District encourages such upgrades through its 

public outreach and through its Burn Cleaner Program, which provides funding to Valley 

residents to upgrade their current wood-burning devices and open fireplaces to natural 

or propane gas devices, to certified wood stoves or inserts, or to pellet devices. The 

District’s webpage36 has more information on program eligibility and qualified devices. 

There are several types of wood burning devices and device inserts available. Wood 

stoves, especially newer models, are generally safe and efficient devices for home 

heating. There are two types of wood stoves: catalytic and non-catalytic. EPA’s Phase 

II certified wood stoves produce only 2 to 7 grams of smoke per hour, compared to 15 to 

30 grams of smoke per hour from older, uncertified devices. 

Pellet stoves are similar in appearance to wood stoves, but burn compressed pellets 

made of ground, dried wood and other biomass wastes. Pellet stoves are generally 

more expensive than wood stoves and require electricity for operation; however, they 

are typically more efficient than wood stoves due to the better fuel-to-air ratio in the 

combustion chamber. EPA also certifies pellet stoves. 

Wood burning fireplaces include traditional masonry fireplaces built into brick or stone, 

constructed in the home, and “low mass” fireplaces that are pre-fabricated prior to 

installation. Most fireplaces are not used as a primary source of heat, but serve as a 

secondary heating source or for ambiance. Fireplaces generate much more emissions 

than wood stoves or pellet stoves, but fireplace inserts are available to reduce 

 

36 www.valleyair.org/Grant_Programs/GrantPrograms.htm#WoodStoveChangeOut
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-122 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

emissions. EPA does not certify fireplaces or fireplace inserts, but does have a 

voluntary program for devices that meet qualifications to be considered cleaner burning 

than typical fireplaces and fireplace inserts. Phase I qualified units are approximately 

57% cleaner than older fireplace models, while Phase II qualified units are 

approximately 70% cleaner. While these devices reduce emissions relative to 

uncontrolled fireplaces, their emissions are still relatively higher than certified wood 

stoves and pellet stoves. 

Gas stoves and gas fireplaces burn natural gas or propane, emit very little air pollution, 

and require little maintenance. Gas devices are not subject to the requirements of Rule 

4901, so they can be used on “No Burn” days. For more information about the various 

types of wood burning devices available, see EPA’s Burn Wise program webpages37

. 

The District will consider allowing the use of cleaner EPA-certified wood burning 

devices, particularly during new potential curtailment days aimed at reducing the buildup 

of PM2.5 emissions. EPA-certified devices have been designed and demonstrated to 

reduce PM2.5 emissions by 70% or greater in comparison to uncertified woodstoves, 

and by 95% in comparison to wood-burning fireplaces. Pellet stoves have 

demonstrated even greater reductions in PM2.5 emissions, with an 89% reduction in 

comparison to uncertified woodstoves and a 98% reduction from wood-burning 

fireplaces. Figure D-1 illustrates the average PM2.5 emissions based on various heat 

sources. 

 

37 www.epa.gov/burnwise 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-123 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Figure D-1 Average PM2.5 Emissions based on Device38

Many Valley residents have upgraded their homes with these newer devices, including 

through programs such as the District’s Burn Cleaner Program and federal tax 

incentives. Given their much lower relative emissions, allowed use of these devices 

during a lower curtailment level could still achieve the goal of significantly reducing the 

overall emissions that ultimately lead to violations of the standard. This potential 

allowance and the appropriate level of acceptable clean certified devices will be 

examined through the public rule amendment process. Enforcing this added flexibility 

would be difficult given the challenge in distinguishing wood smoke emissions from 

various wood burning devices, and the District would explore various options during the 

rule development process for ensuring that this issue is addressed. Along with this 

potential allowance, the District will continue to provide incentives to encourage the 

replacement of existing older devices with newer clean devices. 

Wood Burning Season 

An additional opportunity for further reducing emissions from this source includes 

lengthening the wood burning curtailment season, given the relatively high levels of 

PM2.5 emissions often observed during the months of October and March. The 

District’s current Rule 4901 wood burning curtailment season runs from the beginning of 

November until the end of February. Expanding District Rule 4901’s curtailment season 

to include October and/or March would potentially increase the number of curtailment 

days in each wood burning season, particularly in October, based on recent air quality 

data. However, measured Valley concentrations of levoglucosan, a primary indicator for 

 

38EPA. Consumers – Energy Efficiency and Wood-Burning Stoves and Fireplaces. (2012, November 14). Retrieved 

from http://www.epa.gov/burnwise/energyefficiency.html.
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-124 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

wood burning, are not nearly as high in October or March as found to be during the 

current curtailment season of November through February. Therefore, while total 

PM2.5 concentrations are often relatively high during the months of October and March, 

there may be limited potential benefit in extending the season to these months if the 

amount of wood burning and related contribution to the total PM2.5 concentrations is 

limited in scale. Extending the wood burning season to include curtailments in October 

and/or March and the associated potential air quality benefits resulting from that 

extension will be considered during the public rule amending process for Rule 4901. 

New Residential Developments 

The District considered further limiting the installation of wood burning fireplaces and 

heaters in new residential developments by strengthening Section 5.3 of Rule 4901. 

South Coast Rule 445 prohibits the installation of wood burning devices in any 

development that has natural gas service. However, since most of the Valley’s new 

developments are already subject to restrictions based on their housing densities, the 

emissions reduction potential is minimal. 

Risk-based Strategy Analysis 

Wood smoke contains PM2.5, carbon monoxide, formaldehyde, sulfur dioxide, irritant 

gases, and known and suspected carcinogens, such as polycyclic aromatic 

hydrocarbons (PAH). The toxic air pollutants in wood smoke can cause human health 

impacts such as coughs, headaches, and eye and throat irritation. Studies show that 

prolonged inhalation of wood smoke contributes to chronic interstitial lung disease, 

pulmonary arterial hypertension, and cor pulmonale, which can eventually lead to heart 

failure, in adults39. Wood smoke has also been linked to detrimental mutagenic and 

systemic effects such as oxidative stress and coagulation, which can ultimately result in 

cell damage and possibly lead to cancer40, 41, 42. Children with the highest exposure to 

wood smoke show a significant decrease in lung function43. Studies also found that 

wood smoke is twelve times more carcinogenic than an equal concentration of cigarette 

smoke44. Efforts to reduce wood smoke target some of the most harmful species of 

PM2.5. 

 

39 Sandoval, J.; Slas, J.; Martinez-Guerra, M.L.; Gomez, A.; Martinez, C.; Portales, A.; Palomar, A.; Villegas, M.; and 

Barrios, R. Pulmonary Arterial Hypertension and Cor Pulmonale Associated with Chronic Domestic Woodsmoke 

Inhalation. (1993) Chest 103:12-20. 

40 Danielsen, P.H.; Bräuner, E.V.; Barregard, L.; Sällsten, G.; Wallin, M.; Olinski, R.; Rozalski, R.; Møller, P.; Loft, S. 

Oxidatively damaged DNA and its repair after experimental exposure to wood smoke in healthy humans. (2008) 

Mutat Res. 642(1-2):37-42. 

41 Barregard, L.; Allsten, G.S.; Gustafson, P.; Johansson, L.; Johannesson, S.; Basu, S.; Stigendal, L. Experimental 

Exposure to Wood-Smoke Particles in Healthy Humans: Effects on Markers of Inflammation, Coagulation, and Lipid 

Peroxidation (2006) Inhalation Toxicology 18:845–853. 

42 Sapkota, A.; Gajalakshmi, V.; Jetly, D.H.; Roychowdhury, S.; Dikshit, R.P.; Brennan, P.; Hashibe, M.; Boffetta, P. 

Indoor air pollution from solid fuels and risk of hypopharyngeal/laryngeal and lung cancers: a multicentric case-control 

study from India. (2008) Int J Epidemiol. 37(2):321-8. 

43 Heumann, M.; Foster, L.R.; Johnson, L; Kelly, L. Woodsmoke Air Pollution and Changes in Pulmonary Function 

Among Elementary School Children (1991) Air & Waste Management Association 84th Annual Meeting & Exhibition, 

Vancouver, British Columbia. 

44 Lewtas, J.; Zweidinger, R.B.; Cupitt, L.; Mutagenicity, Tumorigenicity and Estimation of Cancer Risk from Ambient 

Aerosol and Source Emissions from Woodsmoke and Motor Vehicles. (1991) Air and Waste Management 

Association 84th Annual Meeting & Exhibition, Vancouver, British Columbia. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-125 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

People can be exposed to wood smoke when they use their wood burning 

devices. Additionally, people can be exposed to wood smoke when people in their 

neighborhoods use their wood burning devices; windows and doors cannot keep the 

particles in wood smoke out of homes. A recent ARB-funded study of residential wood 

smoke impacts on indoor air quality was conducted in Cambria, California and 

published in 2011. Using aethalometers designed to monitor carbon black as the 

definitive chemical signature of wood smoke, the study found nocturnal outdoor 

concentrations in Cambria neighborhoods that were 2 to 10 times higher than the 

cleanest part of the city. Most significantly, over the course of the winter season, indoor 

concentrations of carbon black in non-burning homes were found to be 74% as high as 

concentrations measured just outside the same homes. This combination of processes 

results in a very high intake fraction (the portion of the total emissions that actually end 

up being inhaled) for neighborhood wood combustion when compared to other sources 

of PM that are less proximate. 

The studies referenced above demonstrate the importance of reducing wood burning 

emissions to improve public health. Rule 4901 prohibits wood burning by county or 

forecast area on days when that area is forecast to exceed 30 μg/m3 (the level of EPA’s 

2006 health-based PM2.5 standard of 35 μg/m3, plus a margin of safety). Thus, District 

Rule 4901 and its corresponding Check Before You Burn Program reduce PM2.5 when 

and where those reductions are most needed: in impacted urbanized areas when the 

local weather is forecast to hamper PM dispersion. 

Given the time, location, and type of PM2.5 emissions reductions associated with 

District wood burning prohibitions, Rule 4901 is a key component of the District’s Riskbased Strategy. In 2008, the Central Valley Health Policy Institute found that District 

wood burning curtailments on high pollution days reduced annual exposure by about 

13% in Bakersfield and Fresno, resulting in 30 to 70 avoided cases of annual premature 

mortality. Strengthening Rule 4901 could allow for even greater health benefits. 

The emissions from this source category contribute 15.6% of average winter PM2.5 

emitted from stationary and area sources in the 2012 emission inventory making 

residential wood burning one of the Valley’s largest source of directly-emitted PM2.5. 

Also, emissions associated with residential wood burning are confined to the time of 

year when the Valley experiences its PM2.5 exceedance days. Reducing emissions 

from this source category further is a key strategy for the Valley to attain the PM2.5 

national ambient air quality standards. Photochemical modeling conducted for this plan 

shows that further reducing residential wood burning emissions would contribute to 

improved PM2.5 air quality in the Valley. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4901. 

Regulatory Action

There is potential to reduce residential wood combustion PM2.5 emissions by lowering 

the threshold at which a “No Burn” day is called for each county. As discussed above, 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-126 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

the recommendation is to lower the curtailment threshold to 20 μg/m3. While 

significantly below the federal standard of 35 μg/m3, establishing the curtailment 

threshold at this level will reduce the buildup of emissions during the long stagnation 

periods characteristic to the Valley. Table D-12 details the impact that lowering the 

threshold will have on the number of “No Burn” days in each county for the current 

November – February wood burning season under Rule 4901. 

With this lower wood burning curtailment threshold, intended to reduce buildup during 

stagnation events, the District will consider allowing the use of cleaner EPA-certified 

wood burning devices during these buildup periods. Given their much lower relative 

emissions, allowed use of these devices during certain curtailment levels could still 

achieve the goal of significantly reducing the overall emissions that ultimately lead to 

violations of the standard. 

Expanding the applicability of Rule 4901 curtailments to include October and/or March 

will also be considered when Rule 4901 is next amended. This could potentially 

increase the number of “No Burn” days, particularly in October. At this time, the District 

does not propose to change any of the existing rule exemptions. However, exemptions 

could be re-evaluated during the rule amendment process. 

Contingency 

With the District’s 2008 adoption of a contingency measure that would lower the wood 

burning curtailment level to 20 μg/m3 in 2014, the District committed to evaluate the 

appropriateness of a substitute contingency measure starting in 2012. In conjunction 

with the District’s current recommendation to formally lower the curtailment level to 20 

μg/m3, the District proposes a new contingency level of 15 μg/m3, to be implemented if 

EPA finds that the Valley fails to attain the 2006 PM2.5 NAAQS by 2019. In addition, 

the attainment year contingency-trigger would achieve an additional 1.5 tons per day of 

PM2.5, as an average day during the wood burning season (November - February). 

This would serve as additional contingency reductions in 2020. 

Table D-13 Potential Emissions Reductions

 2007 2012 2014 2015 2016 2017 2018 2019 

PM2.5 Tons per day – winter season 

Kern and Kings 

Counties (Attainment 

Need) 

0 0 0 0 0.1 0.2 0.2 0.2 

Other Valley Counties 0 0 0 0 0.7 1.3 1.3 1.3 

Valley-wide Total 0 0 0 0 0.8 1.5 1.5 1.5 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-127 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Table D-14 Estimated Change in Number of No Burn Days 

County 

“No Burn” Days at 

Current Threshold 

>=30 μg/m3 

“No Burn” Days at 

Lower Threshold 

>=20 μg/m3 

“No Burn” Days at 

Contingency 

Threshold >=15 

μg/m3 

San Joaquin 18 47 71

Stanislaus 36 74 93

Merced 26 63 85

Madera 37 73 96

Fresno 53 85 104

Kings 41 73 96

Tulare 40 71 92

Kern 47 78 100

Incentive Action 

No new incentive actions are recommended for wood burning fireplaces and wood 

burning heaters. The District expects to continue its Burn Cleaner Program to change 

out older wood burning devices. 

Technology Advancement Action 

Several manufacturers are developing Phase 2 qualified fireplace inserts and fireplaces 

that emit less PM2.5 than their uncontrolled fireplace counterparts. However, Phase II 

certified wood stoves, pellet stoves, and natural gas heating emit less PM2.5 than even 

the cleanest Phase 2 qualified fireplaces and fireplace inserts. The District does not 

anticipate participating in any technology advancement actions related to wood burning 

fireplaces at this time. 

Policy Initiatives 

The District will evaluate potential strategies for implementing the lower curtailment level 

during the public rule development process. 

Education and Outreach 

The District’s comprehensive, multimedia “Check Before You Burn” outreach utilizes 

billboards, radio ads, brochures, social media, strong media partnerships and more to 

ensure the public is informed about wood burning curtailments. The District is 

committed to continuing this strong public outreach effort to educate the public, help 

ensure the success of the District’s Rule 4901, and reduce these emissions in the 

Valley. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-128 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.5.3 Rule 4902 Residential Water Heaters 

Source Category 

Rule 4902 applies to manufacturers, distributors, retailers, and installers of Public 

Utilities Commission (PUC) quality natural gas-fired residential water heaters with heat 

input rates less than or equal to 75,000 Btu/hr. It is a point-of-sale type of rule that limits 

NOx emissions from residential water heaters. 

Rule 4902 was adopted on July 17, 1993 to control NOx emissions from natural gasfired water heaters. The original rule enforced a NOx emissions limit of 40 nanograms 

of NOx per Joule of heat output (ng/J). Since its adoption, the rule has been amended 

once. The March 2009 amendments strengthened the rule by enforcing a limit of 10 

ng/J for new or replacement water heaters and a limit of 14 ng/J for instantaneous water 

heaters. EPA finalized approval for Rule 4902 on May 5, 2010. Rule 4902 is not 

subject to RACT because it is not a Control Techniques Guidelines (CTG) category and 

it is applicable to sources that are too small to exceed the major source threshold. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.20 0.20 0.20 0.20 0.21 0.21 0.21 0.21

NOx 2.44 2.16 2.13 2.11 2.10 2.08 2.06 2.05

SOx 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02

Winter Average - Tons per day

PM2.5 0.28 0.27 0.27 0.27 0.28 0.28 0.29 0.29

NOx 3.30 2.91 2.87 2.85 2.82 2.80 2.78 2.76

SOx 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02

Regulatory Evaluation 

How does District Rule 4902 compare with federal rules and regulations? 

There is currently no federal guidance given for this source category under the federal 

CTG, Alternative Control Techniques (ACT), New Source Performance Standards 

(NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAP), and 

Maximum Achievable Control Technology (MACT) requirements. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-129 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

How does District Rule 4902 compare to rules in other air districts? 

District analysis compares Rule 4902 to the following analogous rules in other air 

districts: SCAQMD Rule 1121 (Control of Nitrogen Oxides from Residential Type, 

Natural Gas-Fired Water Heaters), SMAQMD Rule 414 (Water Heaters, Boilers and 

Process Heaters Rated Less than 1,000,000 BTU Per Hour), BAAQMD Regulation 9 

Rule 6 (Nitrogen Oxides Emissions from Natural Gas-Fired Boilers and Water Heaters), 

and VCAPCD Rule 74.11 (Natural Gas-Fired Water Heaters) and determined that Rule 

4902 is at least as stringent as those rules. 

Emission Reduction Opportunities 

As stated above, the most recent amendment of Rule 4902 strengthened the emission 

limit and as a result, NOx emissions have been controlled by approximately 88% for this 

source category. Units subject to Rule 4902 are fired on PUC quality natural gas, and 

are inherently low-emitters of SOx and PM2.5 emissions. Given the significant efforts 

and investments already made to reduce emissions from this source category, there are 

little remaining opportunities for obtaining additional emissions reductions. For the sake 

of thoroughness, the possibility of further reducing emissions from natural-gas fired 

water heaters is evaluated in the following discussion. 

The potential opportunity evaluated is the possibility of achieving additional emission 

reductions from this category by taking advantage of lower emitting water heating 

technology. Rule 4902 is a point of sale rule, and nearly all water heaters sold in the 

District are conventional storage water heaters that operate on natural gas. The 

potential opportunity would be to replace natural gas and propane water heaters with 

units that run on electricity. A comparison of three water heaters that utilize the different 

fuel types with an emissions reduction and cost effectiveness analysis for these units is 

summarized below. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-130 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Table D-15 Emissions Reductions and Cost Effectiveness of Water Heaters by 

Fuel Type

Fuel Type 

Low NOx 

Propane Electricity 

Natural Gas 

Capacity1 50 gallons 50 gallons 50 gallons

Shipping Weight1 180 lbs 151 lbs 109 lbs

Energy Factor1 0.62 0.59 0.91

Purchase Price1 $902.00 $899.00 $473.25 

Estimated Life 

Expectancy2 13 years 13 years 13 years

Lifetime Energy Use2 3,133 therms 2,867 gallons of 

LP 62,439 kWh

Lifetime Energy Costs3 $3,568 $7,176 $9,834 

Lifetime NOx Emissions4 30.60 lbs 48.09 lbs 0.00 lbs

Annual NOx Emissions 2.35 lbs 3.70 lbs 0.00 lbs

Comparing Natural Gas and Propane to Electricity 

N/A 

Annualized capital cost5 $76.99 $76.99

Annual Operating Cost 

Savings Compared to 

Electric 

$482.00 $204.46

Cost per pound NOx $237.87 $76.07

Cost per ton NOx $475,736 $152,135 

1

 Unit specifications and prices acquired from Grainger Industrial Supply as of August 7, 2012 

2

 Data from US Department of Energy – Energy Cost Calculator for Electric and Gas Water Heaters 

http://www1.eere.energy.gov/femp/technologies/eep_waterheaters_calc.html 

3

 Cost data based on the of the average cost of units of energy in 2010 according to the US Energy Information Administration. 

http://www.eia.gov/ 

4

 Emissions factors derived from Appendix EA-1 of US Department of Energy’s Energy Assessment for Proposed Energy 

Conservation Standards for Residential Clothes Washers 

5

 The annualized capital equipment cost is calculated by multiplying the installed equipment cost by the capital recovery factor of 

0.1627. 

The operating cost for electric water heaters is higher than for propane and natural gas 

units, due to the higher cost of electricity over propane and natural gas. However, the 

initial purchase price is considerably lower for electric units. Converting to an electric 

water heater also may require modifications to the residence and have associated 

costs, though electric water heaters are amongst the safest units available. Electric 

units also weigh considerably less, due to the lack of safety equipment needed on a gas 

fueled water heater. While the lifetime cost of an electric water heater is higher than 

that of propane and natural gas, the emissions benefits may make converting to electric 

water heating a viable control strategy. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-131 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Risk-based Strategy Analysis 

The emissions from units subject to Rule 4902 contribute 6.0% of average winter NOx 

emitted from stationary and area sources in the 2012 emission inventory. As illustrated 

in the emission inventory table above, the emissions from this source category are more 

prominent during winter months. However, these units are primarily fired on PUCquality natural gas, which is generally considered a clean burning fuel with low SOx and 

PM emissions. Overall, Rule 4902 has significantly reduced NOx and SOx emissions 

from these units and has assisted in reducing PM2.5 concentrations through reductions 

of this key precursor. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 4902. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 4902. 

Incentive Action 

The District does not currently fund any incentive programs specific to residential water 

heating, and there are no recommendations for new incentive programs for these 

sources at this time. 

Technology Advancement Action 

There are no recommendations for technology advancement actions at this time. 

Through its Technology Advancement Program, the District will continue to seek 

potential feasible and low-cost technologies that may provide for additional emission 

reduction opportunities in this category. 

Policy Initiatives 

The District does not currently have any policy initiatives specific to this rule. There are 

no recommendations for new policy initiatives specific to these units. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. As this is a point of sale rule, this outreach would be applicable to retailers 

and manufacturers of residential water heaters. The District will continue to work 

closely with affected sources to ensure successful compliance. No new education and 

outreach efforts are recommended for these sources at this time. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-132 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.5.4 Rule 4905 Natural Gas-Fired, Fan-Type, Residential Central 

Furnaces 

Source Category

Rule 4905 is a point of sale rule that applies to any person who sells, offers for sale, 

installs or solicits the installation of natural-gas-fired, fan-type residential central 

furnaces, for use within the Valley with a rated heat input capacity of less than 175,000 

Btu/hour, and for combination heating and cooling units with a rated cooling capacity of 

less than 65,000 Btu/hour. 

 

The rule was adopted on October 20, 2005 to establish NOx limits for residential central 

furnaces supplied, sold, or installed in the Valley. The rule set a NOx emission limit of 

0.093 pounds per million Btu of heat output (lb/MMBtu). EPA finalized approval for 

Rule 4905 on May 30, 2007. Rule 4905 is not subject to RACT requirements because it 

is not a Control Techniques Guidelines (CTG) category and it is applicable to sources 

that are too small to exceed the major source threshold. 

Emission Inventory

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.20 0.19 0.20 0.20 0.20 0.21 0.21 0.21

NOx 2.49 2.40 2.45 2.48 2.51 2.54 2.58 2.61

SOx 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02

Winter Average - Tons per day

PM2.5 0.36 0.35 0.36 0.36 0.36 0.37 0.37 0.38

NOx 4.47 4.31 4.40 4.45 4.51 4.56 4.62 4.68

SOx 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03

Regulatory Evaluation 

How does District Rule 4905 compare with federal rules and regulations?

There are no applicable CTG, Alternative Control Techniques (ACT), New Source 

Performance Standards (NSPS), National Emission Standards for Hazardous Air 

Pollutants (NESHAP), or Maximum Achievable Control Technology (MACT) guidelines 

for this source category. 

How does District Rule 4905 compare to rules in other air districts?

Rule 4905 when compared to other California air districts’ rules for similar sources is 

found to be at least as stringent as the other rules. Specifically, Rule 4905 was 

compared to the following rules: SMAQMD Rule 414 (Water Heaters, Boilers and 

Process Heaters Rated Less Than 1,000,000 BTU Per Hour), BAAQMD Regulation 9 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-133 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Rule 4 (Nitrogen Oxides from Fan Type Residential Central Furnaces), and VCAPCD 

Rule 74.22 (Natural Gas-Fired, Fan-Type Central Furnaces). 

SCAQMD Rule 1111 (Reduction of NOx Emissions from Natural Gas-Fired, Fan-Type 

Central Furnaces) limits NOx emissions of all furnaces to 0.0325 lb/MMBtu by October 

1, 2018, whereas the Rule 4905 NOx limit is 0.093 lb/MMBtu. In addition, SCAQMD 

Rule 1111 applies to both commercial and residential units, whereas District Rule 4905 

only applies to residential units. The District has already committed to amending Rule 

4905 in 2014. 

Emission Reduction Opportunities 

The District committed to amending Rule 4905 in the 2008 PM2.5 Plan. This 

amendment is scheduled for 2014, and will lower NOx emission limits for new natural 

gas-fired, fan-type residential central furnaces as appropriate for the Valley based on 

NOx limits within SCAQMD Rule 1111. However, it has still not been determined if 

manufacturers will be able to meet the limits in SCAQMD Rule 1111. In 2010, 

SCAQMD released a Request for Proposal (RFP) for the development of prototype 

ultra-low NOx natural gas-fired fan-type central furnaces. Four different projects were 

selected with different burner and emission control technologies for funding and are 

ongoing. The District will work closely with South Coast staff throughout the technology 

development project. When Rule 4905 is amended, NOx emission limits will be based 

on the results of those studies and the technology that is expected to be available. 

Commercial Furnaces 

As previously stated, SCAQMD Rule 1111 currently regulates small residential and 

commercial furnaces less than 175,000 Btu/hr, whereas District Rule 4905 regulates 

residential furnaces of the same size, but not commercial furnaces. The technology of 

commercial furnaces does not differ from residential central furnaces. 

As a part of their on-going research efforts, SCAQMD plans on conducting a new 

technical assessment of the technology available to offset emissions from commercial 

central furnaces greater than 175,000 Btu/hr by 2014. SCAQMD plans on following up 

the assessment with a rule amendment that incorporates a new NOx limit for 

commercial units greater than 175,000 Btu/hr, which are currently unregulated, by 2016. 

The District has committed to amending Rule 4905 in 2014 to lower NOx limits; during 

that rule-amending project the possibility of extending the applicability of this rule to 

include commercial units based on technological feasibility and cost effectiveness will 

also be evaluated. The District will work closely with SCAQMD to discuss the findings 

from their technical assessments of low-NOx technologies for commercial furnaces. 

Risk-based Strategy Analysis

The emissions from units subject to Rule 4905 contribute 8.9% of average winter NOx 

emitted from stationary and area sources in the 2012 emission inventory. As illustrated 

in the emission inventory table above, the emissions from this source category are 

primarily a winter issue. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-134 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Control Measure Commitments

The following is a summary of recommended commitments for Rule 4905. 

Regulatory Action 

The recommendation is to amend the rule in 2014 as committed to in the District 2008 

PM2.5 Plan, and as a part of that process examine the possibility of extending the 

applicability of rule requirements to include natural gas-fired, fan-type, commercial 

central furnaces. 

Incentive Action 

Rule 4905 is currently under commitment to be amended to make the rule more 

stringent, and no new technologies were identified to further reduce emissions beyond 

those technologies that will be evaluated during the 2014 rule amending project. No 

new incentive actions are recommended for these natural gas-fired, fan-type, residential 

central furnaces. 

Technology Advancement Action 

As discussed above, the SCAQMD is currently testing new technologies to reduce 

emissions from these sources and the District intends to use the findings from that 

testing to make determinations as to the appropriate amendments for the rule. This 

effort, aside, there is no recommendation for a new technology advancement project for 

this source category. Through its Technology Advancement Program, the District will 

continue to seek potential feasible and low-cost technologies that may provide for 

additional emission reduction opportunities in this category. 

Policy Initiatives 

The District is not currently supporting any policy initiatives specific to natural gas-fired, 

fan-type, residential central furnaces, and there are no recommendations for new policy 

initiatives for these sources. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. This is a point of sale rule; District outreach is primarily applicable to retailers 

of these natural gas-fired, fan-type, residential central furnaces. No new education and 

outreach efforts are recommended for these retailers at this time. The District will 

continue to work closely with affected sources to ensure successful compliance. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-135 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.6 FUGITIVE PARTICULATE MATTER 

District Regulation VIII is comprised of eight rules that regulate fugitive dust emissions. 

Regulation VIII applies only to outdoor anthropogenic (human-caused) fugitive dust 

sources; primary PM10 sources that result in fugitive dust emissions such as 

construction, demolition, excavation, extraction or other earthmoving activities; handling, 

transport, and storage of bulk materials; landfill operations; carryout and trackout; open 

areas with disturbed soil; unpaved roads; unpaved vehicle/equipment traffic areas (such 

as parking, shipping, receiving, transfer, and service areas), and off-field agricultural 

sources. Regulation VIII does not apply to PM10 precursor sources or sources of 

smoke. Regulation VIII prohibitory standards are performance based whereby the 

operators are allowed to determine the control technique sufficient to limit visible dust 

emissions to 20 percent opacity and, in certain instances, to implement requirements for 

a stabilized surface. 

Regulation VIII was critical in the District’s attainment of the National Ambient Air 

Quality Standard for PM10. However, a variety of studies have been conducted which 

may indicate that the PM2.5 fraction of the PM emissions from this source category may 

not be as significant as the PM coarse fraction. A better quantification of the PM2.5 

fraction is required to develop a more accurate emissions inventory for the various 

activities in this category and to indicate the level of significance of those PM2.5 

emissions. At this time, PM2.5 emission control factors are not well defined and it is not 

known if controls for PM10 are effective for producing PM2.5 emissions reductions for 

this category. 

In the Risk-based Strategy chapter of this plan, modeling results show that the geologic 

fraction of PM2.5 found in the San Joaquin Valley makes a relatively small contribution 

to overall PM2.5 mass (see Figure 2.1). In addition, studies have shown that geologic 

dust, by itself, has relatively low toxicity. For more information on the impacts of 

geologic PM2.5 refer to Chapter 2. 

Regulation VIII Rules do not regulate the vehicles that create dust because the District 

does not have the jurisdiction to regulate mobile sources. Refer to Chapter 6 (Incentive 

Programs) and Appendix C (Mobile Source Control Strategies) for details on how the 

District addresses mobile sources. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-136 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Existing Control Strategies 

Due to the degree of difficulty and enormity of the challenge that the Valley faces in 

meeting the National Ambient Air Quality Standards (NAAQS), the District recognizes 

that prohibitory rules alone are not enough to reduce emissions to meet attainment 

requirements and protect public health. The District’s longstanding, progressive 

strategy for reducing emissions is a multifaceted effort that includes incentive programs 

and policy initiatives in addition to prohibitory rules. The following discussion 

summarizes both the existing District efforts to reduce emissions from this source 

category, and evaluations for potential opportunities for further emissions reductions. 

Incentive Programs 

Incentive programs are an integral part of the emission reduction efforts of the District, 

especially where the District lacks direct jurisdiction in establishing emission control 

requirements. Because the District has regulatory authority and currently regulates 

these control measure source categories, the opportunities for incentive programs are 

minimal. In fact, there are not currently any incentive programs specific to the reduction 

of fugitive PM from sources subject to the Regulation VIII rules. The District does 

however implement incentive programs for off-road vehicles; refer to Chapter 6 for 

details on those programs. 

Policy Initiatives 

Similar to the Incentive Programs, the District’s policies and Legislative Platform are 

important components to the District’s strategy to attain federal ambient air quality 

standards. The District utilizes policies and the legislative platform to bring attention to 

major issues that have a direct impact on the Valley’s air quality. Water shortages have 

an adverse impact on air quality in the Valley in a number of ways. Taking agricultural 

land out of production has led to the exposure of bare land, which can cause soil 

erosion and result in wind-blown dust. Furthermore, one of the key dust control 

measures that the Valley relies upon to control fugitive dust is wet suppression, which 

also requires water. With this in mind, the District supports measures to provide reliable 

water supplies to the Valley. 

Rules and Regulations 

The following table identifies the District Regulatory VIII rules, each of which will be 

evaluated to examine potential opportunities for additional emissions reductions. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-137 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Table D-16 Current Regulation VIII Rules 

Rule

Last 

Amended/ 

Adopted

Rule 8011 General Requirements 08/19/2004 

Rule 8021 Construction, Demolition, Excavation, 

Extraction, and Other Earthmoving Activities 08/19/2004 

Rule 8031 Bulk Materials 08/19/2004 

Rule 8041 Carryout and Trackout 08/19/2004 

Rule 8051 Open Areas 08/19/2004 

Rule 8061 Paved and Unpaved Roads 08/19/2004 

Rule 8071 Unpaved Vehicle/ Equipment Traffic Areas 08/19/2004 

Rule 8081 Agricultural Sources 08/19/2004 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-138 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.6.1 Rule 8011 General Requirements 

Source Category 

The provisions of Rule 8011 are applicable to specified outdoor fugitive dust sources. 

The definitions, exemptions, requirements, administrative requirements, recordkeeping 

requirements, and test methods set forth in this rule are applicable to all rules under 

District Regulation VIII (Fugitive PM10 Prohibitions). The Regulation VIII series was 

adopted in November 2001, and subsequently amended in 2004. The rules were 

developed pursuant to EPA guidelines for serious PM10 nonattainment areas. In 2004, 

the District adopted amendments to Regulation VIII to upgrade existing Reasonably 

Available Control Measure (RACM) level rules to meet the more stringent Best Available 

Control Measure (BACM) level required in serious PM10 nonattainment areas. 

Emission Inventory 

The emission inventory for this rule is not quantified because it is a supplementary rule 

to the other seven Regulation VIII Rules. Although this rule applies to all sources that 

have the potential to emit particulate matter there are no control requirements 

established within this rule. Emissions and emission reductions are addressed in the 

other seven Regulation VIII Rules. Emissions from Regulation VIII Rules can be found 

in Appendix B, and summarized in the other seven Regulation VIII rule discussions in 

this appendix. 

Regulatory Evaluation 

How does District Rule 8011 compare with federal rules and regulations? 

Rule 8011 when compared to EPA rules, regulations, and guidelines that apply to 

fugitive dust is found to meet or exceed these standards. Federal requirements are 

located in General Preamble for Title I of the Clean Air Act Amendments of 1990 

Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and 

Technical Information Document for Best Available Control Measures (EPA-450/2-92-

004). 

How does District Rule 8011 compare to rules in other air districts? 

Rule 8011 was compared to fugitive dust regulations at other air districts and where 

comparable, is at least as stringent, if not more stringent, than other districts’ rules. 

Comparisons to other air district rules, included SCAQMD Rule 1156 (Further 

Reductions of Particulate Emissions from Cement Manufacturing Facilities), SCAQMD 

Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations), 

SMAQMD Rule 403 (Fugitive Dust), VCAPCD Rule 55 (Fugitive Dust), and Clark 

County Department of Air Quality (CCDAQ) Section 41 (Fugitive Dust). BAAQMD does 

not have a comparable rule. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-139 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Emission Reduction Opportunities 

This rule is administrative in nature, and is intended to be a supplementary rule to the 

other District Regulation VIII rules. Opportunities for emission reductions would be 

found with each of the other Regulation VIII rules and would not be identified as a 

possibility for this rule. As such, there are no emission reduction opportunities for Rule 

8011. 

Risk-based Strategy Analysis 

As discussed above, the emissions from this source category are accounted for with the 

other Regulation VIII rules. This is a general requirement rule meant to supplement and 

support the other Regulation VIII rules. The emissions associated with the Regulation 

VIII rules are geological; as discussed in Chapter 2, research indicates that the geologic 

fraction of PM2.5 in the Valley makes a relatively small contribution to overall PM2.5 

mass in peak winter months, and by itself has a relatively low toxicity. The emissions 

associated with sources subject to each of the Regulation VIII rules are identified and 

discussed in each rule control measure source category discussion. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 8011. 

Regulatory Action 

This rule is an administrative and supplemental rule to other Regulation VIII rules. The 

District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 8011. 

Incentive Action 

There are no recommendations for incentive actions for this rule because the rule is 

administrative in nature and if any incentive actions were to be recommended, they 

would need to be directed at the other Regulation VIII rules. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 

Policy Initiatives 

As discussed previously, one of the key dust control measures that residents and 

operators in the Valley rely upon to control fugitive dust is wet suppression. Being 

mindful of this, the District currently supports legislative measures to provide reliable 

water supplies to the Valley. While there are no recommendations for new policy 

initiatives, the recommendation is to continue supporting legislative activities that aim to 

provide reliable water supplies to the Valley. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-140 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. The District does not have recommendations for new education and outreach 

efforts for these sources. The District will continue to work closely with affected sources 

to ensure successful compliance. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-141 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.6.2 Rule 8021 Construction, Demolition, Excavation, Extraction, 

and Other Earthmoving Activities 

Source Category

Rule 8021 applies to construction or demolition related disturbances of soil, including 

land clearing, grubbing, scraping, excavation, extraction, land leveling, grading, cut and 

fill operations, travel on the site, travel access roads to and from the site, and demolition 

activities. The rule also applies to construction of new landfill disposal sites or 

modifications to existing landfill disposal sites prior to commencement of landfilling 

activities. 

In 2004, the District adopted amendments to Regulation VIII to upgrade existing RACM 

level rules to meet the more stringent BACM level required in serious PM10 

nonattainment areas. Rule 8021 was amended to add dust suppression requirements, 

and to require submittal of Dust Control Plans on residential construction sites 10.0 

acres or more in size and on non-residential construction sites 5.0 acres or more in size. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 1.19 1.11 1.12 1.13 1.14 1.15 1.16 1.17

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day

PM2.5 1.09 1.01 1.03 1.04 1.05 1.06 1.06 1.07

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Regulatory Evaluation 

How does District Rule 8021 compare with federal rules and regulations? 

Rule 8021, when compared to EPA rules, regulations, and guidelines that apply to 

fugitive dust, is found to meet or exceed these standards. Federal requirements are 

located in General Preamble for Title I of the Clean Air Act Amendments of 1990 

Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and 

Technical Information Document for Best Available Control Measures (EPA-450/2-92-

004). 

How does District Rule 8021 compare to rules in other air districts? 

Rule 8021 was compared to fugitive dust regulations at other air districts and where 

comparable, is at least as stringent, if not more stringent, than other districts’ rules. 

Comparisons to other air district rules included SCAQMD Rule 1156 (Further 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-142 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Reductions of Particulate Emissions from Cement Manufacturing Facilities), SCAQMD 

Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations), 

SMAQMD Rule 403 (Fugitive Dust), VCAPCD Rule 55 (Fugitive Dust), and Clark 

County Department of Air Quality (CCDAQ) Section 94 (Permitting and Dust Control for 

Construction Activities). BAAQMD does not have a comparable rule. 

Emission Reduction Opportunities 

District analysis identified one potential opportunity to further reduce emissions from this 

source category; to require signs to be posted at certain size work sites, asking the 

public to contact the District if the work site is producing significant dust emissions. 

While, this potential opportunity would increase the awareness of the workers and the 

public, there is no conclusion that it would result in reduced emissions. If emissions are 

reduced, it is not likely to result in quantifiable emission reductions. 

Risk-based Strategy Analysis 

The emissions from this source category contribute to 1.8% of average winter PM2.5 

emitted from stationary and area sources in the 2012 emission inventory. The 

particulate matter emissions are geological and the inventory is relatively small and 

consistent throughout the year, with no elevated emission levels in winter months. As 

discussed in Chapter 2, research indicates that the geologic fraction of PM2.5 in the 

Valley makes a relatively small contribution to overall PM2.5 mass in peak winter 

months, and by itself has a relatively low toxicity. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 8021. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 8021. 

Incentive Action 

The District does not currently have an incentive program specific to construction or 

demolition related disturbances of soil. There are no recommendations for new 

incentive actions at this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-143 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Policy Initiatives 

As discussed previously, one of the key dust control measures that residents and 

operators in the Valley rely upon to control fugitive dust is wet suppression. Being 

mindful of this, the District currently supports legislative measures to provide reliable 

water supplies to the Valley. While there are no recommendations for new policy 

initiatives, the recommendation is to continue supporting legislative activities that aim to 

provide reliable water supplies to the Valley. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for new education and outreach efforts for 

these sources. The District will continue to work closely with affected sources to ensure 

successful compliance. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-144 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.6.3 Rule 8031 Bulk Materials 

Source Category 

Rule 8031 applies to the outside storage and handling of any unpackaged material, 

which emits or has the potential to emit dust when stored or handled. Rule 8031 

requires bulk handling and storage facilities to restrict dust from material transfer, and 

reduce emissions from transport material and storage piles that emit dust. Facilities 

subject to Rule 8031 are required use control measures to ensure that visible dust 

emissions are limited to 20% opacity or less. These control measures can include 

application of water or other dust stabilizers, covering of bulk materials, construction of 

wind barriers, covering of haul trucks, etc. 

In 2004, the District adopted amendments to Regulation VIII to upgrade existing RACM 

level rules to meet the more stringent BACM level required in serious PM10 

nonattainment areas. Rule 8031 was amended to require construction and 

maintenance of wind barriers when handling bulk materials. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day

PM2.5 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Regulatory Evaluation 

How does District Rule 8031 compare with federal rules and regulations? 

Rule 8031, when compared to EPA rules, regulations, and guidelines that apply to 

fugitive dust, is found to meet or exceed these standards. Federal requirements are 

located in General Preamble for Title I of the Clean Air Act Amendments of 1990 

Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and 

Technical Information Document for Best Available Control Measures (EPA-450/2-92-

004). 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-145 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

How does District Rule 8031 compare to rules in other air districts? 

Rule 8031 was compared to fugitive dust regulations at other air districts and where 

comparable, is at least as stringent, if not more stringent, than other districts’ rules. 

Comparisons to other air district rules included SCAQMD Rule 1156 (Further 

Reductions of Particulate Emissions from Cement Manufacturing Facilities), SCAQMD 

Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations), 

SMAQMD Rule 403 (Fugitive Dust), VCAPCD Rule 55 (Fugitive Dust), and Clark 

County Department of Air Quality (CCDAQ) Section 41 (Fugitive Dust). BAAQMD does 

not have a comparable rule. 

Emission Reduction Opportunities 

Rule 8031 currently employs the best dust mitigation techniques; there are no additional 

potential opportunities for further reductions of emissions from this source category. 

Rule 8031’s requirement of limiting opacity to 20% is as or more stringent than any 

other District’s rule and compliance with the standard requires significant mitigation 

efforts from sites that store bulk materials. 

Risk-based Strategy Analysis 

The PM2.5 emissions from this source category contribute to 0.04% of average winter 

PM2.5 emitted from stationary and area sources in the 2012 emission inventory. The 

particulate matter emissions are geological and the inventory is relatively small and 

consistent throughout the year, with no elevated emission levels in winter months. As 

discussed in Chapter 2, research indicates that the geologic fraction of PM2.5 in the 

Valley makes a relatively small contribution to overall PM2.5 mass in peak winter 

months, and by itself has a relatively low toxicity. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 8031. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 8031. 

Incentive Action 

The District does not currently fund incentive programs specific to the outside storage 

and handling of bulk materials. There are no recommendations for new incentive 

actions at this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-146 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Policy Initiatives 

As discussed previously, one of the key dust control measures that residents and 

operators in the Valley rely upon to control fugitive dust is wet suppression. Being 

mindful of this, the District currently supports legislative measures to provide reliable 

water supplies to the Valley. While there are no recommendations for new policy 

initiatives the recommendation is to continue supporting legislative activities that aim to 

provide reliable water supplies to the Valley. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for new education and outreach efforts for 

these sources. The District will continue to work closely with affected sources to ensure 

successful compliance. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-147 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.6.4 Rule 8041 Carryout and Trackout 

Source Category 

Rule 8041 applies to the prevention and cleanup of mud and dirt whenever it is 

deposited (carryout and trackout) onto public paved roads from activities subject to the 

requirements of Rules 8021, 8031, 8061, and 8071. The rule contains requirements for: 

removing carryout and trackout at the end of each workday; thresholds for any site with 

150 daily vehicle trips; addressing carryout and trackout in Dust Control Plans; 

removing carryout and trackout in urban areas; paved interior roads; and prevention of 

carryout and trackout. 

In 2004, the District adopted amendments to Regulation VIII to upgrade existing RACM 

level rules to meet the more stringent BACM level required in serious PM10 

nonattainment areas. Rule 8041 was amended to require a threshold for vehicles with 

three or more axles to takes actions for carryout/trackout. Amendments included a 

threshold for projects located in rural areas, a provision requiring actions within half an 

hour if specified measures are insufficient to prevent carryout/trackout, and 

specifications for dust collectors, gravel pads, and paved surfaces. 

Emission Inventory 

The emission inventory for this rule is not quantifiable independent from paved and 

unpaved roads. These emissions occur on paved and unpaved roads and therefore are 

documented as a part of the inventory for Rule 8061 (Paved and Unpaved Roads). 

Refer to the control measure write up for Rule 8061 for this combined inventory. 

Regulatory Evaluation 

How does District Rule 8041 compare with federal rules and regulations? 

Rule 8041, when compared to EPA rules, regulations, and guidelines that apply to 

fugitive dust, is found to meet or exceed these standards. Federal requirements are 

located in General Preamble for Title I of the Clean Air Act Amendments of 1990 

Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and 

Technical Information Document for Best Available Control Measures (EPA-450/2-92-

004). 

How does District Rule 8041 compare to rules in other air districts? 

Rule 8041 was compared to fugitive dust regulations at other air districts and where 

comparable, is at least as stringent, if not more stringent, than other districts’ rules. 

Comparisons to other air district rules included SCAQMD Rule 1156 (Further 

Reductions of Particulate Emissions from Cement Manufacturing Facilities), SCAQMD 

Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations), 

SMAQMD Rule 403 (Fugitive Dust), VCAPCD Rule 55 (Fugitive Dust), and Clark 

County Department of Air Quality (CCDAQ) Section 94 (Permitting and Dust Control for 

Construction Activities). BAAQMD does not have a comparable rule. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-148 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Emission Reduction Opportunities 

Two potential opportunities to reduce emissions were identified, evaluated, and 

determined to not be feasible. The first potential emission reduction opportunity would 

be to reduce the threshold for daily trips per worksite that requires a carryout and 

trackout prevention system (currently 150 trips). Reducing this threshold would require 

smaller worksites to install costly trackout prevention equipment like wheel washers, 

metal grates, and gravel pads. At these smaller worksites the emission reductions that 

would be achieved would be minimal and not cost effective because of the small size of 

the sites. The second potential opportunity would be to shorten the distance from the 

nearest unpaved exit point of a site at which trackout must be immediately cleaned 

(currently 50 feet). Lowering this threshold would significantly increase the use of street 

sweepers and their associated emissions, which are more toxic to human health (see 

Chapter 2). Therefore this opportunity has been determined to not be feasible. 

Risk-based Strategy Analysis 

The emissions from this source category are documented as a part of the emissions 

inventory for Rule 8061 (Paved and Unpaved Roads). The PM2.5 emissions from these 

two source categories combined contribute to 11.2% of the average winter PM2.5 

emitted from stationary and area sources in the 2012 emission inventory. The 

particulate matter emissions are geological and the inventory is relatively small and 

consistent throughout the year, with no elevated emission levels in winter months. As 

discussed in Chapter 2, research indicates that the geologic fraction of PM2.5 in the 

Valley makes a relatively small contribution to overall PM2.5 mass in peak winter 

months, and by itself has a relatively low toxicity. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 8041. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 8041. 

Incentive Action 

The District does not currently fund incentive programs specific to this source category; 

there are no recommendations for new incentive actions at this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-149 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Policy Initiatives 

As discussed previously, one of the key dust control measures that residents and 

operators in the Valley rely upon to control fugitive dust is wet suppression. Being 

mindful of this, the District currently supports legislative measures to provide reliable 

water supplies to the Valley. While there are no recommendations for new policy 

initiatives the recommendation is to continue supporting legislative activities that aim to 

provide reliable water supplies to the Valley. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for new education and outreach efforts for 

these sources. The District will continue to work closely with affected sources to ensure 

successful compliance. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-150 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.6.5 Rule 8051 Open Areas 

Source Category 

Rule 8051 applies to any open area 0.5 acres or more within urban areas, or 3.0 acres 

or more within rural areas that contains at least 1,000 square feet of disturbed surface 

area. The rule has requirements for limiting visible dust emissions (VDE) to 20% 

opacity, to comply with the conditions of a stabilized surface, and to install barriers to 

prevent unauthorized vehicles from accessing the stabilized areas. 

In 2004, the District adopted amendments to Regulation VIII that upgraded existing 

RACM level rules to meet the more stringent BACM level required in serious PM10 

nonattainment areas. Rule 8051 was amended to add applicability thresholds for rural 

and urban areas. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.41 0.34 0.34 0.34 0.34 0.34 0.34 0.34

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day 

PM2.5 0.26 0.21 0.21 0.21 0.21 0.21 0.21 0.21

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Regulatory Evaluation 

How does District Rule 8051 compare with federal rules and regulations? 

Rule 8051, when compared to EPA rules, regulations, and guidelines that apply to 

fugitive dust, is found to meet or exceed these standards. Federal requirements are 

located in General Preamble for Title I of the Clean Air Act Amendments of 1990 

Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and 

Technical Information Document for Best Available Control Measures (EPA-450/2-92-

004). 

How does District Rule 8051 compare to rules in other air districts? 

Rule 8051 was compared to fugitive dust regulations at other air districts and where 

comparable, is at least as stringent, if not more stringent, than other districts’ rules. 

Comparisons to other air district rules included SCAQMD Rule 1156 (Further 

Reductions of Particulate Emissions from Cement Manufacturing Facilities), SCAQMD 

Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations), 

SMAQMD Rule 403 (Fugitive Dust), VCAPCD Rule 55 (Fugitive Dust), and Clark 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-151 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

County Department of Air Quality (CCDAQ) Section 90 (Permitting and Dust Control for 

Construction Activities). BAAQMD does not have a comparable rule. 

Emission Reduction Opportunities 

The District’s analysis did not identify any potential opportunities to further reduce 

emissions from this source category beyond those emissions that are already being 

reduced by rule requirements. As a part of due diligence efforts in seeking addition 

emission reduction opportunities, the following two potential opportunities have been 

identified to improve rule clarity. Language could be added to the rule to clarify that it 

applies to off-road recreational vehicle use areas. Also, the rule provides an exemption 

for weed abatement activity utilizing mowing and/or cutting. Adding language to specify 

that weed abatement by tilling is not exempt would also add clarity to the rule. 

Risk-based Strategy Analysis 

The emissions from this source category contribute 0.4% of average winter PM2.5 

emitted from stationary and area sources in the 2012 emission inventory. The 

particulate matter emissions are geological and the inventory is relatively small and 

consistent throughout the year, with no elevated emission levels in winter months. As 

discussed in Chapter 2, research indicates that the geologic fraction of PM2.5 in the 

Valley makes a relatively small contribution to overall PM2.5 mass in peak winter 

months, and by itself has a relatively low toxicity. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 8051. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls that would result in reduced emissions. Therefore, there are 

no recommendations for additional regulatory actions for Rule 8051. 

Incentive Action 

The District does not currently fund any incentive programs specific to this source 

category; there are no recommendations for new incentive actions at this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-152 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Policy Initiatives 

As discussed previously, one of the key dust control measures that residents and 

operators in the Valley rely upon to control fugitive dust is wet suppression. Being 

mindful of this, the District currently supports legislative measures to provide reliable 

water supplies to the Valley. While there are no recommendations for new policy 

initiatives the recommendation is to continue supporting legislative activities that aim to 

provide reliable water supplies to the Valley. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. No new education and outreach efforts are recommended for these sources 

at this time. The District will continue to work closely with affected sources to ensure 

successful compliance. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-153 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.6.6 Rule 8061 Paved and Unpaved Roads 

Source Category 

Rule 8061 establishes standards for the construction of new and modified paved roads 

in accordance with published guidelines by the American Association of State Highway 

and Transportation Officials for road construction and applies to any paved, unpaved, or 

modified public or private road, street highway, freeway, alley way, access drive, access 

easement, or driveway. The rule also allows alternative means of achieving the same 

level of dust reduction. Rule 8061 also establishes thresholds that when exceeded 

require that roads are treated to reduce visible dust emissions. 

In 2004, the District adopted amendments to Regulation VIII to upgrade existing RACM 

level rules to meet the more stringent BACM level required in serious PM10 

nonattainment areas. Rule 8061 was amended to replace the existing 75 maximum 

daily vehicle trip threshold with a 26 annual average daily vehicle trips (AADT) threshold 

on unpaved roads, and require all new unpaved roads within urban areas be paved. 

Emission Inventory 

This inventory accounts for emissions occurring on paved and unpaved roads and 

includes the inventory from carryout and trackout (Rule 8041) activities onto these 

roads. 

Paved Roads 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 5.57 5.18 5.18 5.18 5.18 5.18 5.18 5.18

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day 

PM2.5 4.80 4.46 4.46 4.46 4.46 4.46 4.46 4.46

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-154 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Unpaved Roads

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 2.02 1.96 1.98 1.99 2.01 2.02 2.04 2.05

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day

PM2.5 1.82 1.77 1.79 1.80 1.81 1.82 1.84 1.85

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Regulatory Evaluation 

How does District Rule 8061 compare with federal rules and regulations? 

Rule 8061, when compared to EPA rules, regulations, and guidelines that apply to 

fugitive dust, is found to meet or exceed these standards. Federal requirements are 

located in General Preamble for Title I of the Clean Air Act Amendments of 1990 

Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and 

Technical Information Document for Best Available Control Measures (EPA-450/2-92-

004). 

How does District Rule 8061 compare to rules in other air districts? 

Rule 8061 was compared to fugitive dust regulations at other air districts and where 

comparable, is at least as stringent, if not more stringent, than other districts’ rules. 

Comparisons to other air district rules included SCAQMD Rule 1156 (Further 

Reductions of Particulate Emissions from Cement Manufacturing Facilities), SCAQMD 

Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations), 

SMAQMD Rule 403 (Fugitive Dust), VCAPCD Rule 55 (Fugitive Dust), Clark County 

Department of Air Quality (CCDAQ) Section 91 (Fugitive Dust from Unpaved Roads, 

Unpaved Alleys, and Unpaved Easement Roads), and CCDAQ Section 93 (Fugitive 

Dust from Paved Roads and Street Sweeping Equipment). BAAQMD does not have a 

comparable rule. 

Emission Reduction Opportunities 

The following potential opportunity to reduce emissions from paved and unpaved roads 

was identified and determined to be not feasible. Section 5.2.1 of the rule requires dust 

control measures for any unpaved road segments with 26 or more annual average daily 

trips. A potential opportunity to reduce emissions would be to lower this threshold. This 

would require more owners/operators to implement at least one control measure to 

reduce fugitive emissions. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-155 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Analysis of the emission inventory indicates that the majority of the particulate 

emissions attributable to unpaved roads are generated from unpaved roads already 

subject to the mitigation requirements of Rule 8061. Therefore, the remaining portion of 

emissions associated with unpaved roads (less than 26 AADT) does not provide an 

opportunity for additional reductions. 

Additionally, emissions from unpaved roads are lowest in the winter months, when the 

District’s PM2.5 24-hour exceedances occur. District staff believes the winter average 

PM2.5 emission inventory is overestimated for the following reasons: 

• ARB methodology assumes that rainfall of at least 0.01 inch on any day mitigates 

unpaved road dust for 24 hours 

• 71% of the days with precipitation occur during the winter months. 

• Many US Forest and Park Roads are inaccessible during winter months due to 

increased amounts of rain and snow, yet emissions from these roads make up a 

larger percentage of the total unpaved road emissions in winter (42.8%) than in 

the annual average (40.7%) 

For these reasons, lowering the trip threshold is not a viable emission reduction 

opportunity. 

Risk-based Strategy Analysis 

The emissions inventory from this source category includes the inventory for emissions 

from sources subject to the Rule 8041 (Carryout and Trackout) control measure source 

category. The emissions from these two source categories combined contribute to 

11.2% of average winter PM2.5 emitted from stationary and area sources in the 2012 

emission inventory. The particulate matter emissions are geological and the inventory 

is relatively small and consistent throughout the year, with no elevated emission levels 

in winter months. As discussed in Chapter 2, research indicates that the geologic 

fraction of PM2.5 in the Valley makes a relatively small contribution to overall PM2.5 

mass in peak winter months, and by itself has a relatively low toxicity. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 8061. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 8061. The key potential opportunity identified to reduce 

emissions for this rule is to lower the trip threshold that requires dust control measures 

on public unpaved roads. Staff reviewed this source category and determined that 

lowering this threshold would not result in measureable emission reductions. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-156 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Incentive Action 

The District does not currently fund an incentive program specific to paved and unpaved 

roads; there are no recommendations for new incentive actions specific to this rule at 

this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 

Policy Initiatives 

As discussed previously, one of the key dust control measures that residents and 

operators in the Valley rely upon to control fugitive dust is wet suppression. Being 

mindful of this, the District currently supports legislative measures to provide reliable 

water supplies to the Valley. While there are no recommendations for new policy 

initiatives the recommendation is to continue supporting legislative activities that aim to 

provide reliable water supplies to the Valley. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for new education and outreach efforts for 

these sources. The District will continue to work closely with affected sources to ensure 

successful compliance. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-157 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.6.7 Rule 8071 Unpaved Vehicle/ Equipment Traffic Areas 

Source Category 

Rule 8071 is applicable to unpaved vehicle/equipment areas, parking, fueling and 

service areas, and shipping, receiving, and transfer areas. The rule contains 

requirements for when vehicle traffic reaches or exceeds specified thresholds, 

limitations on visible dust emissions (VDE), compliance requirements with the 

conditions of a stabilized surface, and lists control techniques, which could be 

implemented to limit VDE and to comply with the conditions of a stabilized surface. 

In 2004, the District adopted amendments to Regulation VIII to upgrade existing RACM 

level rules to meet the more stringent BACM level required in serious PM10 

nonattainment areas. Rule 8071 was amended to remove the 1.0 acre or larger 

threshold; change the vehicle threshold from 75 vehicle daily trips to 50 annual average 

daily trips; add a single day peak threshold of 150 VDT or require control for sources 

that exceed the 150 VDT threshold limit on at least 30 days per year; and add a 

requirement whenever 25 or more three-axle vehicle trips will occur on an unpaved 

vehicle/equipment traffic area. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 1.01 0.99 0.99 0.99 0.99 0.99 0.99 0.99

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day

PM2.5 1.03 1.01 1.01 1.01 1.01 1.01 1.01 1.01

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Regulatory Evaluation 

How does District Rule 8071 compare with federal rules and regulations? 

Rule 8071, when compared to EPA rules, regulations, and guidelines that apply to 

fugitive dust, is found to meet or exceed these standards. Federal requirements are 

located in General Preamble for Title I of the Clean Air Act Amendments of 1990 

Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and 

Technical Information Document for Best Available Control Measures (EPA-450/2-92-

004). 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-158 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

How does District Rule 8071 compare to rules in other air districts? 

Rule 8071 was compared to fugitive dust regulations at other air districts and where 

comparable, is at least as stringent, if not more stringent, than other districts’ rules. 

Comparisons to other air district rules included SCAQMD Rule 1156 (Further 

Reductions of Particulate Emissions from Cement Manufacturing Facilities), SCAQMD 

Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations), 

SMAQMD Rule 403 (Fugitive Dust), VCAPCD Rule 55 (Fugitive Dust), and Clark 

County Department of Air Quality (CCDAQ) Section 92 (Fugitive Dust from Unpaved 

Parking Lots and Storage Areas). BAAQMD does not have a comparable rule. 

Emission Reduction Opportunities 

Section 5.2.1 of current rule language requires dust control measures for any unpaved 

traffic area with 50 or more annual average daily trips. Analysis of lowering this 

threshold to determine if it is a feasible option to reduce emissions determined that this 

is not a cost effective opportunity. Lowering the trip threshold of Rule 8071 would result 

in direct PM emission reductions, but would also result in the requirement that owners 

and/or operators implement a dust control measure. The most common control 

measures are watering and covering with gravel. Local cost estimates indicate that 

installing a 2 inch gravel base with another 2 inches of top gravel would cost 

approximately $1.90 per square foot, or around $83,000 per acre. Based on the small 

size of the emissions from this source category, and the estimated mitigation costs, 

requiring control measures for areas with such minimal activity is not a cost effective 

option. 

Risk-based Strategy Analysis 

The emissions from this source category contribute to 1.8% of average winter PM2.5 

emitted from stationary and area sources in the 2012 emission inventory. The 

particulate matter emissions are geological and the inventory is relatively small and 

consistent throughout the year, with no elevated emission levels in winter months. As 

discussed in Chapter 2, research indicates that the geologic fraction of PM2.5 in the 

Valley makes a relatively small contribution to overall PM2.5 mass in peak winter 

months, and by itself has a relatively low toxicity. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 8071. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 8071. 

Incentive Action 

There are no recommendations for new incentive programs specific to this source 

category at this time. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-159 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 

Policy Initiatives 

As discussed previously, one of the key dust control measures that residents and 

operators in the Valley rely upon to control fugitive dust is wet suppression. Being 

mindful of this, the District currently supports legislative measures to provide reliable 

water supplies to the Valley. While there are no recommendations for new policy 

initiatives the recommendation is to continue supporting legislative activities that aim to 

provide reliable water supplies to the Valley. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for new education and outreach efforts for 

these sources. The District will continue to work closely with affected sources to ensure 

successful compliance. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-160 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.6.8 Rule 8081 Agricultural Sources 

Source Category 

Rule 8081 applies to “off-field” agricultural sources including, but not limited to, unpaved 

roads, unpaved vehicle/equipment traffic areas, and bulk materials. The rule contains 

requirements to limit visible dust emissions (VDE) and/or to comply with the conditions 

of a stabilized surface, and lists control techniques which could be implemented to limit 

VDE and to comply with the conditions of a stabilized surface. 

In 2004, the District adopted amendments to Regulation VIII to upgrade existing RACM 

level rules to meet the more stringent BACM level required in serious PM10 

nonattainment areas. The amendments added an exemption to the rule for 

vehicle/equipment traffic areas if they are less than one acre in size and more than one 

mile from an urban area; expanded rule applicability by updating the vehicle threshold 

from 75 vehicle daily trips to 50 annual average vehicle trips; and added a requirement 

specific to whenever 26 or more three-axle vehicle trips will occur on an unpaved 

vehicle/equipment traffic area. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 1.27 1.23 1.22 1.21 1.21 1.20 1.20 1.19

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day

PM2.5 1.62 1.56 1.55 1.54 1.54 1.53 1.53 1.52

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Regulatory Evaluation 

How does District Rule 8081 compare with federal rules and regulations? 

Rule 8081, when compared to EPA rules, regulations, and guidelines that apply to 

fugitive dust, is found to meet or exceed these standards. Federal requirements are 

located in General Preamble for Title I of the Clean Air Act Amendments of 1990 

Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and 

Technical Information Document for Best Available Control Measures (EPA-450/2-92-

004). 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-161 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

How does District Rule 8081 compare to rules in other air districts? 

Rule 8081, when compared to EPA rules, regulations, and guidelines that apply to 

fugitive dust, is found to meet or exceed these standards. Federal requirements are 

located in General Preamble for Title I of the Clean Air Act Amendments of 1990 

Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and 

Technical Information Document for Best Available Control Measures (EPA-450/2-92-

004). 

Emission Reduction Opportunities 

The District’s analysis did not identify any potential opportunities to further reduce 

emissions from this source category. However, a potential opportunity to improve 

enforceability of this for this source category has been identified. Section 5.4 of the rule 

references California Vehicle Code section 23112-23113 for prevention of carryout and 

trackout. This section could be removed and replaced with specific language from the 

vehicle code, however, as previously stated, this amendment would not result in 

emissions reductions. 

Risk-based Strategy Analysis 

The emissions from this source category contribute to 2.8% of average winter PM2.5 

emitted from stationary and area sources in the 2012 emission inventory. The 

particulate matter emissions are geological and the inventory is relatively small and 

consistent throughout the year, with no elevated emission levels in winter months. As 

discussed in Chapter 2, research indicates that the geologic fraction of PM2.5 in the 

Valley makes a relatively small contribution to overall PM2.5 mass in peak winter 

months, and by itself has a relatively low toxicity. 

Control Measure Commitments 

The following is a summary of recommended commitments for Rule 8081. 

Regulatory Action 

The District’s analysis did not identify any additional technologically feasible and cost 

effective potential controls. Therefore, there are no recommendations for additional 

regulatory actions for Rule 8081. 

Incentive Action 

There are no recommendations for incentive actions to further reduce directly emitted 

particulate matter from agricultural sources subject to Rule 8081 at this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-162 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Policy Initiatives 

As discussed previously, one of the key dust control measures that residents and 

operators in the Valley rely upon to control fugitive dust is wet suppression. Being 

mindful of this, the District currently supports legislative measures to provide reliable 

water supplies to the Valley. While there are no recommendations for new policy 

initiatives, the recommendation is to continue supporting legislative activities that aim to 

provide reliable water supplies to the Valley. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. No new education and outreach efforts are recommended for these sources 

at this time. The District will continue to work closely with affected sources to ensure 

successful compliance. 

 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-163 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.7 ADDITIONAL SOURCE CATEGORIES 

The Valley’s ongoing air quality attainment challenges require the District to look 

beyond the successes of its stringent rules and innovative incentive programs for further 

emissions reductions. The following potential control measure source categories and 

programs represent the District’s continuing efforts to consider and evaluate new and 

existing sources for potential emissions reductions. 

Through its incentives program and its policy and legislative platform, the District is able 

to positively affect emissions reductions from non-regulated sources and sources that 

are outside of its jurisdiction. These efforts include educational programs and public 

outreach that encourage fuel and energy savings, funding for cleaner-running vehicles 

and engines, and the support of legislation that impacts air quality in the Valley. 

For some of the source categories listed below, the District has made initial efforts 

through incentive and outreach programs to reduce emissions. This analysis will look 

beyond such efforts at refinements and new technology to potentially obtain additional 

emissions reductions for each of the source categories. 

Table D-17 Additional Source Categories 

Source Categories

SC 001 Lawn and Garden Equipment

SC 002 Energy Efficiency

SC 003 Fireworks

SC 004 Sand and Gravel Operations

SC 005 Asphalt/Concrete Operations

SC 006 Almond Hulling/Shelling Operations

SC 007 Pistachio Hulling/ Shelling Operations

SC 008 Ag Material Screening/Shaking Operations

SC 009 Tub Grinding Operations

SC 010 Abrasive Blasting

Existing Control Strategies 

Due to the degree of difficulty and enormity of the challenge that the Valley faces in 

meeting the National Ambient Air Quality Standards (NAAQS), the District recognizes 

that prohibitory rules alone are not enough to reduce emissions to meet attainment 

requirements and protect public health. The District’s longstanding, progressive 

strategy for reducing emissions is a multifaceted effort that includes incentive programs 

and policy initiatives in addition to prohibitory rules. The following discussion 

summarizes existing District efforts to reduce emissions from sources under this 

category. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-164 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Incentive Programs 

Incentive programs are an integral part of the emission reduction efforts of the District, 

especially where the District lacks direct jurisdiction in establishing emission control 

requirements. As a part of the District’s continuing efforts to reduce emissions from 

sources through the use of incentive programs, the District has already implemented a 

successful incentive program aimed at replacing lawn care equipment with less polluting 

equipment and is in the process of launching a new program to test new technologies in 

the lawn and garden source category to determine if it is a viable alternative. 

The District encourages the replacement of polluting gas powered lawn mowers with 

electric lawn mowers through The Clean Green Yard Machine grant program which has 

provided $1,472,977 in grant money toward the replacement of 8,600 gas-powered 

lawn mowers in the Valley. 

Other air districts also have incentive programs for lawn and garden equipment. The 

corresponding programs are generally similar to the District’s residential lawn and 

garden replacement program, using rebates or hosting events to replace lawn mowers. 

SCAQMD has a similar program incentivizing electric lawn mowers, but they have also 

extended the program to apply to leaf blowers. Currently, the SCAQMD 2-stroke gas 

leaf blowers are being replaced with lower emitting 4-stroke equipment. 

The availability of zero-emitting or battery powered lawn equipment has been 

challenging, especially in the commercial sector due to the need for a longer battery life 

and durability to allow for more frequent and prolonged equipment use. Local operators 

have previously expressed concerns about the cost and reliability of cordless electric 

equipment, and how this equipment might affect productivity and competition with other 

operators. In May 2012, the District solicited proposals from interested equipment 

manufacturers and vendors to partner with the District and implement the Cordless 

Zero-Emission Commercial Lawn and Garden Equipment Demonstration Program 

(using Assembly Bill 118 funding from ARB). The District finalized a contract with the 

selected equipment manufacturers and vendors and released a Request For 

Applications in August. The demonstration program has generated significant interest 

and support from the commercial lawn and garden applicators, which include 

businesses that provide landscaping services and organizations that have their own 

maintenance team. District staff is currently working with 61 participants to complete 

the contract phase and order the cordless zero-emission commercial lawn and garden 

equipment for the Demonstration Program. Participants will begin using the equipment 

and provide feedback on the performance and durability of the cordless zero-emission 

commercial lawn and garden equipment. Based on suggestions from local lawn and 

garden operators, as a part of the demonstration program, the District will provide 

training for operators to learn how to use cordless electric equipment properly and 

efficiently. Incorporating cordless electric lawn equipment will provide emission 

reductions and should be evaluated further as equipment becomes more readily 

available to operators. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-165 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

The District launched an incentive program in early 2012 for alternatives to 

professionally-managed pyrotechnic fireworks displays. The program committed to 

provide up to 50% of the cost of a laser-light based display to replace pyrotechnic 

fireworks displays at existing, annual July 4th events. The program will potentially be 

restructured to provide more outreach and a better incentive for replacing pyrotechnic 

fireworks in future years. 

This past year, the District provided funding in support of several pilot programs 

examining the potential benefits of providing energy efficiency tools to Valley 

manufacturing facilities and other businesses. Early results from this program indicate 

significant potential opportunities for generating emission reductions from the 

manufacturing and industrial sectors through the promotion of “lean manufacturing” and 

other practices. 

At this time, there are no incentive programs that directly impact the other source 

categories listed in the table above, but the District continues to seek out opportunities 

for other incentive programs to reduce emissions in the Valley. 

Policy Initiatives 

Similar to the Incentive Programs, the District’s policies and Legislative Platform are 

important components to the District’s strategy to attain federal ambient air quality 

standards. The District uses this platform to bring attention to major issues that impact 

air quality in the Valley, including energy efficiency and clean-energy alternatives and 

legislation that limits the District’s ability to regulate the installation and use of woodburning devices in residences. 

The District promotes energy efficiency and clean-energy alternatives as an additional 

means of emissions reductions in areas with well-established, strong regulatory 

measures on stationary sources, such as in the Valley. These extra efforts will help the 

District attain air quality standards as expeditiously as possible. As such, the District 

supports policies and initiatives that encourage renewable energy and energy efficiency 

including the following: 

• Develop additional biomass capacity using agricultural waste materials 

• Expand net metering and feed-in tariffs for the utilization of solar and other 

renewable energy sources 

• Promote energy efficiency for energy end-users that will result in lower pollutant 

emissions and a more stable electric distribution system 

• Encourage and incentivize low-emission technologies that use waste gas as an 

alternative to waste-gas venting or flaring. 

California Senate Bill (SB) 1468 would allow the sale of fireworks for the period 

immediately before New Year’s Eve. Historically, the use of fireworks has been limited 

to the summer season (late June through early July); however, the proposed legislation 

now extends the use of fireworks to winter months, the period of time when the Valley 

experiences stagnation events that trap particulate matter for extended periods of time. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-166 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Particulate matter is the main pollutant of concern during the winter months, and the 

District uses the Check-Before-You-Burn program to reduce particulate matter 

emissions during winter months. If fireworks are allowed in conjunction with the New 

Year’s Eve celebration, and the usage coincides with a stagnation event, Valley 

residents will likely be exposed to elevated and unhealthy particulate matter levels, and 

will likely result in additional fireplace curtailments. Therefore, given the potential for 

extreme adverse impact to public health, the District Governing Board has approved a 

policy in opposition to SB 1468. 

Rules, Regulations, and Incentives 

While rules and regulations are the cornerstone of the District’s efforts in obtaining 

emissions reductions, incentive programs have proven to be a critical component in 

meeting the Valley’s attainment goals. The source categories listed in Table D-17 are 

evaluated in light of their potential to further reduce emissions and achieve the 

attainment of federal air quality standards as expeditiously as possible. 
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D.7.1 SC 001 Lawn and Garden Equipment 

Source Category 

This source category includes the commercial and residential lawn and garden sectors. 

The commercial sector includes larger businesses that employ licensed contractors, 

public agencies and organizations that maintain their own properties or provide 

landscape services, and small businesses serving residential properties. The 

residential sector of lawn and garden equipment includes equipment purchased by the 

public for personal use. A survey conducted in 2003 by the California Air Resources 

Board (ARB) estimated that there are approximately 13 million pieces of lawn and 

garden equipment statewide: 12% in the commercial sector, and 88% in the residential 

sector. Although there are more pieces of equipment used by the residential sector, the 

survey showed that the commercial sector accounts for 68% of annual use of all lawn 

care equipment. 

Lawn and garden equipment includes the following: chainsaws, chippers, commercial 

turf equipment, front mowers, lawn and garden tractors, lawn mowers, leaf blowers and 

vacuums, rear-engine riding mowers, shredders, snow blowers, tillers, trimmers, 

edgers, brush cutters, wood splitters, and other lawn and garden equipment. 

Handheld lawn and garden tools (such as leaf blowers) typically use two-stroke 

engines, and most larger machines (such as lawn and garden tractors) use four-stroke 

engines. Lawn mowers are available with either type of engine. Two-stroke engines 

rely on oil mixed with the gasoline to lubricate the engine components. Much of this oil 

is not completely combusted by the engine thus creating high exhaust emissions. The 

major pollutants from a two-stroke engine, for example, are oil-based particulates, 

PM2.5, NOx, and a mixture of hydrocarbons, which combine with other gases in the 

atmosphere to form ozone, carbon monoxide, and other toxic air contaminants. Overall, 

four-stroke engines emit significantly lower emissions than their two-stroke 

counterparts, with significantly lower levels of hydrocarbons and particulate matter. 

Lawn care equipment, particularly leaf blowers, can also cause a significant amount of 

fugitive dust depending on the work practices employed such as blowing on bare dirt or 

very dusty paved surfaces. These types of activities would increase fugitive emissions 

including PM, toxic air contaminants (TAC) and ultrafine particles (UFP) resulting in a 

negative health impact on those in proximity to the activity. 

Emission Inventory 

The emissions inventory for lawn care includes exhaust and evaporative emissions from 

lawn care equipment. Exhaust emissions from lawn care engines (consisting of both 

unburned fuel and products of incomplete combustion), while high compared to on-road 

mobile sources on a per engine basis, are a relatively small part of the overall NOx and 

directly emitted PM2.5 emission inventory. However, these emissions can be highly 

concentrated geographically as well as within certain hours of the day. 
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Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.12 0.11 0.11 0.11 0.11 0.11 0.11 0.11

NOx 1.02 0.89 0.88 0.88 0.87 0.87 0.87 0.87

SOx 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.001

Winter Average - Tons per day

PM2.5 0.11 0.10 0.10 0.10 0.10 0.10 0.10 0.10

NOx 0.98 0.85 0.84 0.83 0.83 0.82 0.82 0.82

SOx 0.001 0.001 0.001 0.001 0.001 0.001 0.001 0.001

Efforts to improve the emission inventory 

Based on the activity levels reported by ARB in their 2003 emissions inventory 

methodology for lawn care, it is expected that residential activity levels for lawn care 

equipment in the Valley have been underestimated. ARB is currently planning on 

conducting a survey of California residents to update and improve the inventory. 

Concurrently, the District will be conducting additional research to quantify Valleyspecific lawn care activity levels to improve the emissions inventory. 

Regulatory Evaluation 

The District does not currently have any prohibitory rules specifically addressing lawn 

care emissions, though the Indirect Source Review (ISR) rule does account for lawn 

care emissions in the model that calculates emissions increases from new 

developments. Providing electric lawn equipment and incorporating convenient electric 

charging stations and outlets on the property are currently recognized on-site mitigation 

measures for meeting ISR requirements. The list of on-site mitigation measures could 

be expanded to include additional landscape measures such as zero or low-water 

landscaping. However, the emission reduction benefits would have to be quantified. 

The District’s innovative strategies to reduce emissions from the lawn care source 

category, as discussed previously, include funding the residential Clean Green Yard 

Machine residential lawn mower incentive program which replaces conventional 

mowers with electric lawn mowers, and increased outreach efforts to the community. 

Additionally, in March of 2012 the District hosted a conference on lawn care, 

landscaping, and air quality to discuss emerging low-emission technologies. 

How would District SC 001 compare with federal rules and regulations? 

EPA’s small non-road spark-ignition engine rule applies to engines rated below 25 

horsepower, including lawn care equipment. The EPA regulation requires exhaust 

emission standards by 2011 and 2012 depending on the class of the engine. New 

evaporative emission standards for both handheld and non-handheld equipment include 

requirements to control fuel tank permeation, fuel line permeation, and diffusion 

emissions. 
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ARB also has a rule addressing spark-ignition small off-road engines (SORE) less than 

25 horsepower. It was originally adopted in 1990 and established tiered exhaust and 

evaporative emission standards. The rule requires manufacturers to meet these 

standards and obtain certification for the engines from ARB and EPA. The SORE rule 

is an attrition rule, which relies on natural turnover of lawn mowers for reductions to 

occur. While the rule establishes lower emissions, it does not push zero emissions 

technology. ARB recently amended the SORE rule in December 2011 to make it more 

consistent with EPA’s test procedures. 

There are no applicable federal standards and guidelines, such as New Source 

Performance Standards (NSPS), National Emission Standards for Hazardous Air 

Pollutants (NESHAP), and Maximum Achievable Control Technology (MACT) 

requirements, for this category. Additionally, there are no Control Techniques 

Guidelines (CTG), Alternative Control Technology (ACT), or Best Available Control 

Technology (BACT) guidelines requiring additional technologically feasible controls. 

How would District SC 001 compare to rules in other air districts? 

SCAQMD adopted Rule 1623 (Credits for Clean Lawn and Garden Equipment) in 1996, 

but it was not approved by EPA and it is currently not being implemented. There 

doesn’t appear to be any other rules currently in place at other air districts. 

Emission Reduction Opportunities 

ARB and EPA have regulatory authority over engine standards. As described above, 

the ARB and EPA rules rely on natural turnover and do not push zero emissions 

technology; therefore, there are still opportunities to reduce emissions by closing the 

emissions gap and accelerating the use of zero emissions technology. While the 

District cannot establish new engine standards, it could regulate the use of lawn care 

and garden equipment. Given the Valley’s air quality challenges and the potential 

benefits, the District may explore in-use regulatory options as a long-term strategy. The 

District’s analysis of potential opportunities to reduce emissions includes evaluations of 

emerging technologies, potential control strategies such as an in-use rule or best 

management practices, episodic controls, and zoning. While these evaluations do not 

result in recommendations for regulatory action, further study is recommended for the 

evaluation of the emission inventory and of the results from current and future District 

technology demonstration activities. 
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Emerging Technologies 

There has been recent improvement in the availability and applications of zero 

emissions lawn care technology. Manufacturers are producing more electric lawn care 

equipment options and are developing ways to allow for this equipment to be used in 

the commercial sector, such as carrying additional battery packs. Examples of more 

recent advances in new electric options include the following: 

• Lawn mowers 

o Riding mowers 

o Robotic mowers 

o Self-propelled walk behind mowers 

o Cordless electric lawn mowers 

• Battery powered leaf blowers 

• Electric sweepers and backpack vacuums 

• Battery powered chainsaws 

• Electric line trimmers/edgers 

• Electric hedge trimmers 

• Stronger batteries and battery chargers 

Though zero-emitting or battery operated lawn equipment has significantly improved in 

recent years, the viability of cordless electric technology has not been proven in the 

commercial sector. This is largely due to the need for a longer battery life and durability 

to allow for more frequent and prolonged equipment use. On March 21, 2012, the 

District hosted a conference on lawn care, landscaping, and air quality. The conference 

highlighted challenges operators face when using lower emitting equipment and 

commercial viability. Local operators expressed concerns about the cost and reliability 

of cordless electric equipment, and how this equipment might affect productivity and 

competition with other operators. 

The District is actively pursuing demonstrations of new opportunities through its 

Technology Advancement Program, including the recent launch of the Cordless ZeroEmission Commercial Lawn and Garden Equipment Demonstration Program. The 

program is funded with State Air Quality Improvement Program and District program 

funds and would provide eligible cordless zero-emission commercial lawn and garden 

equipment to commercial landscape professionals who conduct business within the 

boundaries of the San Joaquin Valley. The District plans to continue to work with 

commercial operators to address the concerns with commercial viability through the 

implementation of this program. Technologies capable of reducing emissions in the 

Valley are being demonstrated, and if successful these demonstrations may provide an 

opportunity for the District to develop incentive programs to promote these technologies. 
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Potential Strategies to Reduce Emissions 

In evaluating potential control strategies, the District’s analysis identified a number of 

potential regulatory and outreach opportunities. However, there are no recommended 

regulatory actions at this time due to the need to revise the emissions inventory and 

complete the technology demonstration project. The District will continue its evaluation 

of which of the following regulatory approaches are feasible from a regulatory 

standpoint as well as from a public health standpoint. 

In-Use Rule 

One potential control strategy would be to require the use of the cleanest available 

equipment by prohibiting the use of gas combustion equipment. This could be achieved 

through a point-of-sale rule implementing a tiered approach or by phasing in restrictions 

as lower or zero-emissions technology becomes more available in the future. This type 

of control measure could potentially eliminate the portion of emissions resulting from the 

combustion of fuel. There might also be a need to bifurcate this type of regulation due 

to the varying availability of low or zero-emitting equipment in the residential sector 

versus commercial sector. 

Best Management Practices 

Another potential control strategy would be to require operators to implement Best 

Management Practices (BMPs) using a menu approach for the use of lawn and garden 

equipment in the commercial sector. Some examples of potential BMPs include: 

• Restrictions near schools and other heavily populated areas 

• Courtesy practices, e.g. don’t point at people or open windows, don’t blow 

material onto public roads, sidewalks, or neighboring properties 

• Particulate prevention practices (no leaf blower use on bare dirt surfaces or very 

dusty paved surfaces, etc.) 

This BMP option would focus on providing education on safety and more efficient use of 

equipment. Enforcing this type of rule could be challenging due to the large number of 

operators, variation in size of businesses, and the wide spread distribution of operator 

activities. Operators could be required to complete a certification course so that they 

can be educated on proper work practices. The District could also require operators to 

show a certificate of completion to purchase gas equipment after a certain date, to 

ensure contractors operating gas equipment are using the most effective work practices 

to protect public health and decrease emissions. 

Episodic Control 

Episodic control provides another potential control strategy where use of gas equipment 

could be limited or prohibited during high-pollution days. There has also been 

precedence set throughout California with numerous cities and counties adopting 

ordinances banning or prohibiting the use of leaf blowers on specified days, times, 

distances from residential areas, or noise levels. The District could create a model 

ordinance for cities and counties to adopt throughout the Valley to limit or prohibit the 

use of gas equipment and/or leaf blowers. One example was found where the city of 

Menlo Park prohibited the use of gas equipment on Spare the Air days in the Bay Area 
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Air Quality Management District (BAAQMD). This could be an option for future 

regulatory control in the Valley to reduce emissions, especially on high pollution days. 

Table D-18 City Bans of Leaf Blowers 

Cities Ban Type

Dana Point 

San Diego 

Decibel and hours of operations restrictions 

Foster City 

Los Angeles 

Palo Alto 

Restrictions on distance from residential unit and hours 

allowed to operate 

Sacramento 

Sunnyvale 

Restrictions on decibels, hours of operations, and distance 

from residential areas 

Berkeley 

Beverly Hills 

Claremont 

Lawndale 

Los Altos 

Santa Barbara 

Bans gas blowers 

Burlingame Restrict commercial use to one day per week dependent on 

determined city districts; Residential restricted by days and 

hours of operation 

Menlo Park Prohibited on Sundays, observed federal holidays and on 

"Spare the Air" days as declared by the BAAQMD 

Laguna Beach 

Santa Monica 

Bans all blowers 

Zoning 

Another potential opportunity to reduce emissions could be through the promotion of 

“zones,” where gas equipment would be prohibited or limited in designated zones, such 

as those close to schools, parks, etc. This approach, known as “greenzoning,” is 

currently being pioneered in Los Angeles County. Greenzoning could potentially be 

included as a part of the Healthy Air Living outreach program to individual businesses, 

schools, cities, and counties. A related option could be limiting gas powered equipment 

use in certain zones to designated days of the week, similar to days allowed to water 

residential yards. This approach was recently adopted by Burlingame for leaf blower 

use only. Cleaner electric equipment would have an advantage by still being able to be 

operated on the days or areas that gas powered equipment is limited. This strategy 

would also be a win-win by reducing noise nuisances in neighborhoods and near 

schools. The District could provide model ordinances to cities and counties to adopt to 

assist them in implementing this type of measure. 
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Risk-based Strategy Analysis 

The emissions from this source category contribute 1.7% of average winter NOx emitted 

from stationary and area sources in the 2012 emission inventory. Lawn care emissions 

can have a potential health impact due to its widespread use in densely populated 

urban areas. The use of equipment and resultant emissions are typically more 

concentrated in areas of schools, parks, and commercial districts where lawn and 

garden upkeep require more frequent equipment use for a longer duration. 

Lawn care emissions include criteria pollutants and their precursors, toxic air 

contaminants from engine emissions and fugitive sources, and PM 0.1 (ultrafine 

particles, or UFP) from engine emissions and work practices. As noted in Chapter 2 of 

this plan, PM 0.1 is a special concern for public health. In 2010, the District entered into 

a contract with UCSF-Fresno to conduct a pilot characterization of PM 0.1 and PM2.5 

associated with emission plumes from vehicular traffic, lawn care equipment, and wood 

combustion in the Fresno/Clovis metro area. The pilot study found very high PM 0.1 

emission concentrations from lawn care engines, indicating a higher than assumed risk 

to individuals near the engine exhaust plumes and a considerably higher risk to workers 

breathing these particles at the epicenter of the plumes. The District will be building 

upon this pilot study to provide exposure modeling and risk assessment. The extended 

project will measure PM2.5 generated by conventional lawn care equipment and 

speciate collected PM2.5 samples. The resultant mass and chemical species 

assessment will provide a much more solid assessment of the risk facing lawn care 

workers. It will also help establish a firmer empirical basis for estimating the 

contribution of small lawn care engines to ambient concentrations of PM2.5. 

Health effects resulting from exhaust emissions, fugitive dust, and noise generated by 

lawn equipment range from mild to serious, depending on exposure and the sensitivity 

of the individual exposed. In particular, lawn and landscape operators are exposed to 

potentially hazardous concentrations of carbon monoxide (CO), PM2.5, and ultrafine 

particles intermittently throughout their work day. Noise exposures may be high enough 

that operators are at increased risk of developing hearing loss. While exposures to CO, 

PM, and noise may not have immediate, acute effects, the potential health impacts are 

potentially greater for chronic effects. 

Describing the impacts on the public at large is more difficult than for workers because 

exposures, and reactions to those exposures, are much more variable. Exposure could 

occur from being in the vicinity or downwind of an operator of, for example, residents 

whose lawns are being serviced, persons in commercial buildings whose landscapes 

are being maintained or serviced, and persons within a few blocks of the source. In 

addition, some sensitive individuals may experience extreme physical reactions, mostly 

respiratory symptoms such as bronchial spasms, from exposure to bioaerosols found in 

fugitive dust emissions, which include pollen fragments, mold spores, and endotoxins. 

Lawn care emissions are also concentrated in areas where Valley residents live, work, 

and go to school. This proximity leads to a potentially high intake fraction from this 

equipment, defined as that fraction of engine emissions that are actually inhaled by 
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individuals. The timing, proximity, and potency of emissions from lawn care equipment 

can thus pose a significant health risk to operators and the public. 

Noise from lawn care equipment, especially leaf blowers, has the potential of causing 

hearing loss and other adverse health impacts. While the majority of the public is likely 

exposed to noise as bystanders, given the widespread use and the increasing density of 

cities and towns, there is presently no way of knowing for certain how many are actually 

exposed, because of the lack of studies. Regulating the use of lawn care equipment 

could prove to be a win-win from an emissions standpoint as well as for noise concerns. 

Control Measure Commitments 

The following is a summary of recommended commitments for SC 001. 

Regulatory Action 

There are no recommendations for regulatory action at this time. Further study of this 

source category through the noted emissions inventory review and control technology 

demonstration projects to determine if a regulatory approach is appropriate is 

recommended. 

Incentive Action 

There are no recommendations for new incentive programs at this time. The 

recommendation is to continue to run the Clean Green Yard Machine residential lawn 

mower incentive program as well as evaluate the commercial lawn care equipment 

technologies capable of reducing emissions in the Valley as they are being 

demonstrated as a part of the Cordless Zero-Emission Commercial Lawn and Garden 

Equipment Demonstration Program. The program participants will use the equipment in 

real world settings to verify equipment durability and performance, battery capacity, and 

battery charge time. In addition, the participants would be responsible for providing 

monthly data and feedback to the District. At the conclusion of the program, the District 

and the technology demonstrators would work together to complete a final report and 

submit the findings to ARB. Based on these findings and feedback from program 

participants, the District commits to developing more incentive program options for 

commercial operators to assist in deploying zero emissions lawn and garden 

technologies. 
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Technology Advancement Action 

There are no recommendations for new technology advancement programs at this time. 

The recommendation is to continue the current technology advancement program for 

cordless zero-emission technologies. In May 2012, the District solicited proposals from 

interested equipment manufacturers and vendors to partner with the District and 

implement the Cordless Zero-Emission Commercial Lawn and Garden Equipment 

Demonstration Program. The District finalized a contract with the selected equipment 

manufacturers and vendors and released a Request For Applications in August. The 

demonstration program has generated significant interest and support from the 

commercial lawn and garden applicators, which include businesses that provide 

landscaping services and organizations that have their own maintenance team. District 

staff is currently working with 61 participants to complete the contract phase and order 

the cordless zero-emission commercial lawn and garden equipment for the 

Demonstration Program. Participants will begin using the equipment and provide 

feedback on the performance and durability of the cordless zero-emission commercial 

lawn and garden equipment. 

Policy Initiatives 

The District is not currently supporting any policy initiatives specific to lawn care 

equipment, and there are no recommendations for new policy initiatives for these 

sources. 

Education and Outreach 

The District currently provides education and outreach regarding the use of lawn care 

equipment through the Healthy Air Living program. The District also has a robust 

education and outreach program for regulated sources through the Small Business 

Assistance program, Permit Stakeholder Meetings, Compliance Assistance Bulletins, 

and public notices for public workshops and public hearings. There are no 

recommendations for new education and outreach programs beyond those that the 

District currently supports, as discussed above. 
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D.7.2 SC 002 Energy Efficiency 

Source Category 

This category does not include specific emissions inventory sources in the Valley, but, 

rather, the opportunity to reduce emissions from all Valley sectors through the 

promotion of energy efficiency and conservation measures. Generally, emissions 

reductions could be obtained from reductions in electrical power generation or fuel 

through the implementation of such measures. Potential areas of focus include 

residential and commercial buildings, manufacturing and industrial facilities, agricultural 

operations, and oil/gas production and processing facilities. 

Emission Reduction Opportunities 

Energy use is not a regulated activity; however, emissions from the generation of 

electricity are regulated at the power plant. Overall, electricity generation in California is 

relatively clean when compared to emission factors (criteria pollutants and greenhouse 

gases (GHG)) from other states. California has been on the forefront of developing 

renewable energy sources, and has implemented regulations to ensure cleaner nonrenewable energy. Whereas coal-fired electricity generation provides a significant 

percentage of electricity in other parts of the country, especially the eastern states, 

California relies more heavily on natural gas-fired power plants, which have lower 

emission rates for criteria pollutants and GHGs. 

California imports 31% of its electricity from surrounding states (2009 data from 

California Energy Commission (CEC)). The state’s four major utility companies use this 

electricity, as well as resources from around the state to supply continuous, reliable 

electricity to its customers. The inter-related nature of California’s electricity 

transmission leads to a complex relationship between local energy efficiency programs 

and emissions reductions. Energy dispatch for needed demand is time and market 

dependent; the closest plant does not necessarily supply energy to the closest demand. 

In some cases, peak energy demand is met for areas outside the Valley, including Los 

Angeles and San Diego, with marginal (peaker) power plants within the Valley. 

Likewise, Valley demand may be met with electricity from marginal power plants outside 

the Valley. To complicate matters, which marginal plant is used can depend on the time 

of day, the minute-by-minute energy market, or other highly variable factors. 

In 2010, the CEC commissioned an evaluation of energy usage and potential reductions 

from energy efficiency and renewable energy measures. Using sophisticated dispatch 

modeling, Synapse Energy Economics Inc. (Synapse) was able to estimate NOx 

emissions reductions for renewable energy and energy efficiency projects within 

California and within each of the four major utility companies.45 In preliminary model 

runs, Synapse showed that approximately 45 pounds of NOx could be reduced for each 

gigawatt of displaced base load electricity. Likewise, 76 pounds of NOx could be 

 

45 California Energy Commission. (2011, May). Emission Reductions from Renewable Energy and Energy Efficiency 

in California Air Quality Management Districts: Final Project Report (Draft). Synapse Energy Economics, Inc. for CEC 

Public Interest Energy Research (PIER) Program. CEC-XXX-XXX-XXX. 
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reduced for each gigawatt of displaced peak load electricity displaced by targeted 

energy efficiency efforts during peak demand hours. 

Recently, EPA released a roadmap manual46 to assist state, tribal, and local air 

agencies with quantifying and including emissions reductions from energy efficiency and 

renewable energy in State Implementation Plans (SIPs). The document focuses on 

emission benefits from energy policies and programs in the electric power sector. The 

District will focus its future efforts in realizing NOx emissions reductions for potential SIP 

credit during the upcoming ozone attainment planning process. The complex nature of 

electricity transmission and dispatch, combined with import and export of electricity in 

and out of the District and California, will require sophisticated energy modeling to 

pinpoint emissions reductions attributable to potential energy efficiency and renewable 

energy control measures. 

The District’s involvement in energy efficiency and renewable energy is guided by its 

Regional Energy Efficiency Strategy (REES), which was adopted in January 2010.47

 

This policy document identifies the District’s commitment to fostering energy efficiency 

and clean energy alternatives as opportunities for emissions reductions. The District 

has initiated several projects that exemplify this policy guidance. 

Risk-based Strategy Analysis 

The emission inventory for this source category is not quantified as discussed above. 

Control Measure Commitments 

The following is a summary of recommended commitments for SC 002.

Regulatory Action 

The District’s analysis did not identify any technologically feasible and cost effective 

potential controls. Therefore, there are no recommendations for regulatory actions. 

Incentive Action 

The District currently has incentive programs aimed at reduced energy use in the 

Valley. To date, the projects include the following: 

• The administration of approximately $4 million in federal and state Energy 

Efficiency and Conservation Block Grant funds made available to 37 small 

jurisdictions in the Valley. The majority of the funding was used to retrofit 

municipal facilities with lighting and other cost effective energy efficiency retrofits; 

• The funding of an innovative pilot program to assess the potential to operate 

more efficiently, thus saving money and using less energy; and 

 

46 U.S. Environmental Protection Agency: Incorporating Energy Efficiency/Renewable Energy in State and Tribal 

Implementation Plans. (2012). Retrieved July 10, 2012 from http://www.epa.gov/airquality/eere/ 

47 San Joaquin Valley Air Pollution Control District. (2010). Approval of the District’s Regional Energy Efficiency 

Strategy. Memorandum to the SJVAPCD Governing Board. Public Hearing, January 21, 2010. 

http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2010/January/Agenda_Item_7_Jan_21_2010.

pdf
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• The funding of an outreach program showing governmental and service 

organizations the benefits of “going green.” This program started in Stockton 

through the Stockton Chamber of Commerce, and with the District’s help has 

expanded to the central and southern San Joaquin Valley. 

While there are no recommendations for new incentive programs at this time, the 

recommendation is to continue supporting existing incentive programs. 

Technology Advancement Action 

The District’s Technology Advancement Program responds to the long-term need for 

the zero- and near-zero-emission transport of goods and people by informing near-term 

strategies to overcome the Valley’s significant challenges. Two of the three focus areas 

for FY 2012–2013 are renewable energy and waste solutions, which take into account 

energy efficiency. The recommendation is to continue to pursue technology 

advancement programs that may result in further reducing emissions in the Valley. 

Policy Initiatives 

Consistent with the District’s 2012 Legislative Platform, the recommendation is to 

continue to work with stakeholders and state agencies to expand net metering and feedin tariffs for use of solar and other renewable energy sources, promote energy efficiency 

programs for energy end users that will result in lower emissions and a more stable 

electrical distribution system, and develop measures that incentivize and encourage 

low-emission technologies for use of waste gas as an alternative to waste-gas venting 

or flaring. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. Many of the previously-identified actions and commitments rely heavily on the 

existing District outreach and communication efforts and will continue with those efforts. 
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D.7.3 SC 003 Fireworks 

Source Category 

This category consists of fireworks sold and/or used in the Valley. This includes 

consumer fireworks for home displays as well as professional products for use by 

licensed operators in public displays. 

Emission Inventory 

The emission inventory for this category has not been quantified. 

Regulatory Evaluation 

How would District SC 003 compare with federal or state rules and regulations? 

State fireworks law is contained in the California Health and Safety Code, Section 

12500 – 12759, and regulations are encoded as Title 19, California Code of 

Regulations, Chapter 6. The Health and Safety Code section 12505 requires the 

designation of “dangerous” for fireworks containing certain chemicals (such as arsenic 

sulfide), effectively prohibiting their use in consumer (i.e. “safe and sane”) fireworks. 

The Office of the State Fire Marshall (SFM) is the California agency with authority to 

classify fireworks in the state, including the classification of consumer fireworks. 

Pyrotechnic operators who discharge fireworks in public displays must apply to the SFM 

for the necessary license, and report in advance of and after completion of displays. 

The SFM also collects and disposes of seized illegal fireworks. 

No federal guidance has been identified for this source category under the federal 

Alternative Control Techniques (ACT), New Source Performance Standards (NSPS), 

National Emission Standards for Hazardous Air Pollutants (NESHAP), Maximum 

Achievable Control Technology (MACT), and Control Techniques Guidelines (CTG). 

How would District SC 003 compare to rules in other air districts? 

SCAQMD Rule 219 (Equipment not Requiring a Written Permit Pursuant to Regulation 

II) exempts pyrotechnic equipment, special effects or fireworks paraphernalia equipment 

used for entertainment purposes from permit requirements. Additionally, fireworks and 

fireworks displays and pyrotechnics used for creation of special effects at theme parks 

are excluded from the open burning requirements of SCAQMD Rule 444 (Open 

Burning), and prohibitory Rule 401 (Visible Emissions) and Rule 402 (Nuisance) do not 

exempt fireworks displays. 

No references to the use of fireworks or pyrotechnics for entertainment purposes were 

identified for the BAAQMD or the SMAQMD. 
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Emission Reduction Opportunities 

Fireworks usage in the Valley is limited to occasional displays at a small number of 

entertainment venues (minor league sporting events, for example) and Independence 

Day/July 4th. On July 4th, with wide-spread consumer fireworks use, the Valley’s air 

monitors typically show peak PM2.5 concentrations for several hours on the evening of 

July 4th and into July 5th. These hourly PM2.5 concentrations are much higher than 

normal PM2.5 concentrations during the summer, although 24-hour average PM2.5 

concentrations on July 4th and 5th do not always go above the level of EPA’s standard. 

In addition, exceedances of the National Ambient Air Quality Standards (NAAQS) due to 

fireworks qualify as an exceptional event under federal regulations and, with proper 

documentation and EPA concurrence, do not count against an area’s attainment 

status.48 However, the clear relationship between fireworks activity and ambient PM2.5 

levels; the location of emissions in populated areas; and the fact that the PM2.5 species 

associated with fireworks are health-impacting metals and carbons all demonstrate the 

value of reducing emissions from fireworks as part of the District’s Risk-based Strategy. 

Fireworks emissions are reduced by limiting the use of fireworks. For several years, the 

District has utilized public education to inform residents of the risks associated with 

firework emissions, and the dangers to sensitive populations. Enhancements to future 

outreach efforts may include partnering with other state and local agencies’ outreach 

efforts. 

Despite the strong public affinity for July 4th fireworks, many parts of the country are 

moving away from pyrotechnic fireworks displays and towards laser light-based shows – 

particularly in regions with severe drought conditions and extreme fire danger. 

According to the International Laser Display Association, laser-light-based shows are 

gaining steadily in popularity as more and more communities are moving in this 

direction. Several companies in California and throughout the country are engaged in 

the business of incorporating laser-light based shows into 4th of July celebrations. 

In spring 2012, the District offered an incentive program to provide up to 50% of the cost 

of a municipal laser-light based display for existing annual 4th of July displays where the 

grantee is willing to commit to 100% elimination of pyrotechnic fireworks at the event. 

Due to the timing, the District was not able to fund any shows for 2012. The District is 

interested in reviewing and again providing the program in 2013. 

Some fireworks are lower-emitting than others. Disneyland Theme Park started using a 

patented air launch pyrotechnics system in 2004 to reduce noise and pollution. Use of 

such a system appears to be limited, and is likely most effective in situations where 

fireworks displays are frequent enough to justify the cost and permanent installation. 

 

48 Treatment of Air Quality Monitoring Data Influenced by Exceptional Events, 40 C.F.R. § 50.14 (b)(2), (2011). 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

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Risk-based Strategy Analysis 

The emissions from this source category have not been quantified. Fireworks displays 

and their associated emissions are occasional and occur primarily in the summer time. 

Reducing these emissions will not significantly accelerate attainment because 

exceedances of the PM2.5 NAAQS occur during winter months. 

However, the PM2.5 species associated with fireworks are primarily metals, which, as 

noted in Chapter 2, are relatively high in toxicity and health-impacting. During a 

professional display PM2.5 levels can be sustained above 1,000 μg/m3.49 Particulate 

matter from ground-level fireworks includes aerosolized metals used as fuel and 

coloration, and may cause exposures exceeding occupational exposure guidelines for 

Barium, Strontium, Copper, and Lead.50 Consumer fireworks emissions occur in 

populated areas. Although these emissions are not long-term, these emissions can be 

very high for a period of several hours. For these reasons, reducing emissions from 

fireworks and educating the public about the health impacts of fireworks is consistent 

with the District’s Risk-based Strategy. 

Control Measure Commitments 

The following is a summary of recommended commitments for fireworks. 

Regulatory Action 

Fireworks use is infrequent and isolated to the summer months, and since there is a 

very strong public affinity for fireworks displays, there are no recommendations for 

regulatory action at this time. 

Incentive Action 

As discussed above, the District launched an incentive program for municipal laser-light 

shows to replace fireworks displays in 2012, but due to timing issues, was not able to 

fund any shows. Recommendations for incentive action are to continue this effort with 

continued research to make any needed program improvements, and making the 

program available again in future years. Another recommendation would be to seek 

partners earlier in the year, and consider sponsoring shows combining a small amount 

of fireworks with an otherwise predominantly laser driven show. 

Technology Advancement Action 

There are no recommendations for technology advancement actions at this time 

because the technologies discussed already exist and are in use in some areas. 

Through its Technology Advancement Program, the District will continue to seek 

potential feasible and low-cost technologies that may provide for additional emission 

reduction opportunities in this category. 

 

49 Joly, A., Smargiassi, A. Kosatsky, T., Fournier, M., Dabek-zlotorzynska, E., Celo, V., Mathieu, D., Sevranckx, R., 

D’amours, R., Malo, A., and Brook, J. (2910) Characterization of particulate exposure during fireworks displays. 

Atmospheric Environment, 44, 4325-4329. doi:10.1016/j.atmosenv.2009.12.010 

50 Croteau, G., Dills, R., Beaudreau, M., and Davis M. (2010) Emission factors and exposures from ground-level 

pyrotechnics. Atmospheric Environment, 44, 3295-3303. doi:10.106/j.atmosenv.2010.05.048
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Policy Initiatives 

On August 16, 2012, the District Governing Board voted to adopt a position in 

opposition of California Senate Bill (SB) 1468 (Calderon), which would have allowed for 

the sale of safe and sane fireworks during the period of December 6th to January 2nd for 

two years, as a pilot for considering whether such an expanded use of fireworks should 

continue. This legislation would have thus expanded the use of fireworks to winter 

months when the Valley experiences stagnant conditions that trap particulates for 

extended periods of time. Given the potential for extreme adverse impact to public 

health, the District opposed SB 1468. Ultimately, the bill is not being enacted, likely for 

financial reasons associated with the data collection and analysis associated with the 

bill. 

No additional policy initiatives are proposed at this time. The recommendation is to take 

a policy stance opposing any expansion of fireworks use in the Valley, particularly if 

such expansion were to affect the winter months when there are already high particulate 

levels. 

Education and Outreach 

The District currently has a robust education and outreach program, as discussed 

above, to encourage residents to avoid or reduce consumer fireworks use. The 

recommendation is to continue current education and outreach activities and possibly 

seek to partner with local police and fire departments in this messaging, since these 

entities also encourage residents to avoid or limit fireworks use (especially illegal 

fireworks use). Another recommendation is to generate interest in the District’s 

municipal incentive program by sponsoring a technology demonstration of lasers at a 

pre-July 4th public event, such as a minor league sporting event, and invite staff and 

public representatives from Valley municipalities who might consider laser light shows 

for their local July 4th celebrations. Such a demonstration could showcase the laser 

technology before July 4th to improve public acceptance of reducing fireworks. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

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D.7.4 SC 004 Sand and Gravel Operations 

Source Category 

Particulate matter emissions from sand and gravel operations occur as excavated 

aggregate material is conveyed, screened, crushed, and stored. This source category 

is not subject to RACT because this is not a volatile organic compound (VOC) rule and 

is not a Control Techniques Guidelines (CTG) rule. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.077 0.077 0.081 0.083 0.086 0.089 0.092 0.093

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day

PM2.5 0.074 0.074 0.078 0.080 0.083 0.086 0.088 0.089

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Regulatory Evaluation 

How would SC 004 compare with federal rules and regulations? 

“EPA promulgated its New Source Performance Standard (NSPS), 40 CFR Part 60, 

established under Section 111 of the Clean Air Act on December 16, 1975 (40 FR 

58416) as means to regulate stationary sources of particulate matter (PM) emissions. 

Subpart OOO of the NSPS standard covers nonmetallic mineral processing, which 

includes regulations for emissions from operating equipment that was manufactured, 

modified or reconstructed after August 31, 1983. NSPS Subpart OOO was further 

revised on April 28, 2009. Processing equipment regulated under Subpart OOO 

affecting the crushed stone, sand and gravel industry includes crushers, grinding mills, 

screens, bucket elevators, bagging operations, storage bins, enclosed truck and railcars 

and transfer points on belt conveyors.”51 There are no other federal guidelines, including 

CTG, Maximum Achievable Control Technology (MACT), and National Emission 

Standards for Hazardous Air Pollutants (NESHAP), that apply to the control of 

particulate matter from sand and gravel operations. 

 

51 National Stone, Sand and Gravel Association: New Source Performance Standards, Subpart OOO. (2012). 

Retrieved April 4, 2012 from http://www.nssga.org/environment/nsps.cfm 
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D-184 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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How would SC 004 compare to rules in other air districts? 

SCAQMD Rule 1157 (PM10 Emission Reductions from Aggregate and Related 

Operations) identifies requirements for general performance standards; loading, 

unloading, and transferring; conveyor; crushing equipment; screening equipment; 

storage piles; internal roads; and track-out. Such operations are also covered by 

SCAQMD Rule 403 (Fugitive Dust), which also identifies Best Available Control 

Measures (BACM) applicable to all construction activity sources. Other than new source 

review rules, specific rules were not identified in BAAQMD, SMAQMD, and VCAPCD. 

As described below, the District has regulated these sources under District Rules 8011, 

2201, and 4101 for many years, including requiring Best Available Control Technology 

(BACT) for new and modified facilities. 

Emission Reduction Opportunities 

Generally, sand and aggregate materials are wet or moist when handled and emissions 

are often negligible. For processes where water is not an appropriate method for 

minimizing emissions, baghouse and filter technology and achieved-in-practice controls 

are generally sufficient to limit visible dust emissions to less than 20 percent opacity as 

required by District Rule 8011 (General Requirements for Regulation VIII) and District 

Rule 4101 (Visible Emissions). 

While other districts have specific rules for aggregate and related operations (SCAQMD 

Rule 1157), the ultimate limits for dust emissions is the same as opacity and visible 

emissions standards used for District operations. SCAQMD provides guidance for 

specific activities (e.g. loading, conveying, crushing, screening, and storage), but the 

emissions limits are the same as the District’s limits. The District reviews any new or 

modified stationary source under Rule 2201 (New and Modified Stationary Source 

Review), which in most cases will trigger Best Available Control Technology (BACT) 

requirements, thus requiring operators to apply the best controls to reduce emissions 

during operational activities including crushing, screening, and conveying. 

Risk-based Strategy Analysis 

The emissions from this source category contribute 0.1% of average winter PM2.5 

emitted from stationary and area sources in the 2012 emission inventory. As illustrated 

in the emission inventory table above, the emission inventory is relatively small and 

consistent throughout the year, with no elevated emission levels in winter months. 

Additionally, the emissions are geologic in nature, and, as described in Chapter 2, do 

not contribute significantly during the peak winter season, and are of low relative 

toxicity. 

Control Measure Commitments 

The following is a summary of recommended commitments for SC 004. 

Regulatory Action 

The District’s analysis did not identify any technologically feasible and cost effective 

potential controls. Therefore, there are no recommendations for regulatory actions. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

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Incentive Action 

There are no incentive action recommendations for this sand and gravel operations. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 

Policy Initiatives 

The District is not currently supporting any policy initiatives specific to sand and gravel 

operations and there are no recommendations for new policy initiatives for this source at 

this time. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for new education and outreach efforts for 

these sources. 
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D.7.5 SC 005 Asphalt/Concrete Operations 

Source Category 

This source category includes emissions from asphalt and concrete production 

operations. Cement concrete production includes cement manufacturing and concrete 

production. There are only a few cement plants in California, but none within the Valley. 

However, many operations contribute to potential emissions associated with concrete 

production, which include the blending of cement powder, water, sand, and coarse 

aggregate. Similarly, there are operations producing asphalt concrete, which is 

primarily used for paving parking lots and on-road surfaces and is made by hot-mixing 

asphalt with size-graded aggregate in drums or batches. If a cement production plant 

were to be built within the Valley, it would be reviewed and evaluated under District Rule 

2201 (New and Modified Stationary Source Review) and would trigger Best Available 

Control Technology (BACT) requirements for equipment and processes associated with 

the production of cement. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 1.01 1.01 1.07 1.11 1.14 1.18 1.22 1.24

NOx 0.19 0.16 0.17 0.17 0.18 0.18 0.19 0.19

SOx 0.30 0.30 0.32 0.33 0.34 0.35 0.36 0.36

Winter Average - Tons per day

PM2.5 1.00 1.00 1.06 1.10 1.13 1.17 1.20 1.23

NOx 0.16 0.14 0.15 0.15 0.16 0.16 0.17 0.17

SOx 0.29 0.29 0.31 0.32 0.32 0.33 0.34 0.35

Regulatory Evaluation 

How would SC 005 compare with federal rules and regulations? 

Because many of the same processes are implemented at sand and gravel operations 

(crushing, grinding, conveying, mixing of aggregate), EPA’s New Source Performance 

Standard (NSPS), 40 CFR Part 60 Subpart OOO, Standards of Performance for 

Nonmetallic Mineral Processing Plants, is also applicable to asphalt and concrete 

operations. NSPS Subpart I, Standards of Performance for Hot Mix Asphalt Facilities, 

and NSPS Subpart UU, Standards of Performance for Asphalt Processing and Asphalt 

Roofing Manufacturing, are also applicable to asphalt operations. 

Asphalt processing is also subject to National Emission Standards for Hazardous Air 

Pollutants (NESHAPs), 40 CFR Part 63 Subpart LLLLL, Asphalt Processing and Asphalt 

Roofing Manufacturing (major sources), and Subpart AAAAAAA, Asphalt Processing 

and Asphalt Roofing Manufacturing (area sources). 
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How would SC 005 compare to rules in other air districts? 

SCAQMD Rule 1157 (PM10 Emission Reductions from Aggregate and Related 

Operations) identifies requirements for general performance standards; loading, 

unloading, and transferring; conveyor; crushing equipment; screening equipment; 

storage piles; internal roads; and track-out. Such operations are also covered by 

SCAQMD Rule 403 (Fugitive Dust) which also identifies Best Available Control 

Measures (BACM) applicable to all construction activity sources. SCAQMD provides 

only guidance for minimizing emissions during these activities, but, ultimately, the 

emissions limits are the same as those being achieved under District rules. Similar 

rules were not identified in BAAQMD, SMAQMD, and VCAPCD.

Emission Reduction Opportunities 

Emissions from concrete production operations and asphalt concrete operations are 

minimized by achieved-in-practice controls meeting the opacity requirements of District 

Rule 4101 (Visible Emissions) and Rule 2201 (New and Modified Stationary Source 

Review). For concrete production operations, this technology includes baghouses for 

screens, crushers, and concrete weight batchers; bin vent filters for concrete and fly ash 

silos; and water spray for other emissions points. For asphalt operations, achieved-inpractice controls include oil mist collectors and “blue smoke” control with electrostatic 

precipitators or filter packs. Dryers used for drying aggregate in the asphalt production 

process are regulated under District Rule 4309 (Dryers, Dehydrators, and Ovens), 

which limits NOx and CO to 4.3 and 42 ppmv, respectively, for gaseous-fuel fired units. 

Specific to asphalt operations, warm-mix asphalt technologies show promise in reducing 

emissions associated with the production of asphalt for paving projects when compared 

to hot-mix asphalt. Both mechanical (foaming) and additive (chemical and organic) 

technologies “allow the producers of asphalt pavement material to lower the 

temperatures at which the material is mixed and placed on the road.”52 Lower 

temperatures—50 to 100 degrees Fahrenheit below what is necessary for hot-mix 

asphalt—result in lower fuel consumption, decreased production of greenhouse gases, 

lower criteria pollutant emissions, and lower fugitive VOC emissions during application. 

The amount of emissions reductions is dependent on the additive or process used53, but 

one additive manufacturer claims reductions of 30% (VOC), greater than 30% (PM), and 

greater than 50% (NOx) in emissions measured at the plant stack.54 The same 

manufacturer also claims more than 45% reduction in CO2 emissions. 

Warm-mix asphalt, while widely used in Europe, is relatively new in the United States. 

There have been many demonstration projects throughout the U.S. and California, and 

 

52 National Asphalt Pavement Association, Warm Mix Asphalt Technical Working Group: Warm Mix Asphalt Takes 

Off. (2012). http://warmmixasphalt.com/ 

53 Jones, D., Wu, R., Tsai, B, Barros, C.B., Peterson, J., (2011). Key Results from a Comprehensive Accelerated 

Loading, Laboratory, and Field Testing Study on Warm-Mix Asphalt in California. Proceedings, 2nd International 

Warm-Mix Conference, St. Louis, Missouri, October 11–13. 

http://www.asphaltpavement.org/big_files/11mwmx/Papers/WM19_Jones.pdf 

54 MeadWestvaco Corporation [MWV]: Evotherm® Warm Mix Asphalt (2012). 

http://www.meadwestvaco.com/SpecialtyChemicals/AsphaltAdditives/MWV002106 
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there is ongoing research to evaluate long-term durability, to verify emissions 

reductions, and to develop best practices for the use of warm-mix asphalt. The 

California Department of Transportation (Caltrans), in conjunction with the University of 

California, Davis, has been investigating implementation issues specific to the use of 

warm-mix asphalt in California. Caltrans already uses warm-mix asphalt for projects 

requiring nighttime work or application in cooler temperatures. Caltrans has also issued 

a contractor-permissive specification that allows the use of warm-mix asphalt for paving 

projects as conditions and requirements allow. Despite the general acceptance of 

warm-mix asphalt technologies by Caltrans, use by local jurisdictions has not been wellreceived; cost and unfamiliarity with the technology remain as barriers to technology 

penetration. 

Of the emissions inventory for this category, approximately 50% of the PM2.5 

emissions, 80% of the NOx emissions, and virtually all of the SO2 emissions are 

attributable to asphalt concrete production. As of August 2012, there are 22 permitted 

asphalt production plants in the Valley. While the inventory from these existing plants 

represents a small portion of the overall inventory, the co-benefits of using warm-mix 

asphalt (reduced fuel use, reduced worker exposure to on-site emissions, improved 

compaction, and the ability to extend the paving season and pave in cooler 

temperatures) may make its use cost effective. 

Risk-based Strategy Analysis 

The emissions from this source category contribute 3.5% of average winter SOx, and 

1.8% of average winter PM2.5 emitted from stationary and area sources in the 2012 

emission inventory. As illustrated in the emission inventory table above, the emissions 

from this source category consist of a relatively small portion of the Valley inventory and 

do not have elevated emission levels in winter months. Additionally, the emissions are 

geologic in nature, and, as described in Chapter 2, do not contribute significantly during 

the peak winter season, and are of low relative toxicity. 

Control Measure Commitments 

The following is a summary of recommended commitments for SC 005. 

Regulatory Action 

There are no recommendations for regulatory actions for asphalt and concrete 

operations. Further study to evaluate the potential of using warm-mix asphalt instead of 

hot-mix asphalt in the Valley is recommended. 

Incentive Action 

There are no recommendations for incentive actions for asphalt and concrete 

operations at this time. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-189 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Technology Advancement Action 

There are no recommendations for new technology advancement actions at this time. 

Through its Technology Advancement Program, the District will continue to seek 

potential feasible and low-cost technologies that may provide for additional emission 

reduction opportunities in this category. 

Policy Initiatives 

The District is not currently supporting any policy initiatives specific to asphalt and 

concrete operations. There are no recommendations for new policy initiatives specific 

to asphalt and concrete operations. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for new education and outreach efforts for 

these sources. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-190 Appendix D: Stationary and Area Source Control Strategy Evaluation 

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D.7.6 SC 006 Almond Hulling/Shelling Operations 

Source Category 

This control measure source category would apply to almond hulling and shelling 

operations. Almonds are harvested from orchards and transported to almond 

processing facilities, where the almonds are hulled and shelled leaving the nut, or meat. 

Orchard debris, soil, and pebbles represent 10- 25% of the field weight of material 

brought to the almond processing facility. Clean almond meats are obtained as about 

20% of the field weight. Processes for removing the debris and almond hulls and shells 

are potential sources of air emissions. The Valley harvests 86% of the almonds 

produced in California. Production has roughly doubled in the last decade, with the 

2010/2011 crop year reaching 1.4 billion pounds.55 

Emission Inventory 

The emission inventory for this control measure source category includes the emissions 

from the SC 007 (Pistachio Hulling/Shelling Operations) source category for pistachio 

hulling and shelling operations. 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.075 0.081 0.084 0.086 0.087 0.089 0.091 0.093

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day

PM2.5 0.049 0.052 0.054 0.056 0.057 0.057 0.059 0.060

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Regulatory Evaluation 

How would SC 006 compare with federal rules and regulations? 

There are no specific federal guidelines applying to almond hulling/shelling operations in 

terms of Control Techniques Guidelines (CTG), Alternative Control Techniques (ACT), 

New Source Performance Standards (NSPS), National Emission Standards for 

Hazardous Air Pollutants (NESHAP), Best Available Control Technology (BACT), and 

Maximum Achievable Control Technology (MACT) for this category. 

 

55 The Tioga Group. (2012). SJV Nut Industry Profile Preliminary Draft. 

http://www.sjvcogs.org/pdfs/2012/Nut%20Industry%20030612.pdf 
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How would SC 006 compare to rules in other air districts? 

No rules or Best Available Control Technology (BACT) guidelines were identified in 

other California air districts for this source category. Air districts researched included 

SCAQMD, BAAQMD, VCAPCD, and SMAQMD. 

Emission Reduction Opportunities 

Evaluation of emission reduction opportunities for almond hulling and shelling 

operations included a review of on-going research efforts, and the technologicial 

feasibility and cost effectiveness of Poly Tetra Fluoro Ethylene bags. 

On-Going Research Efforts 

Research is currently being conducted by Texas A&M University in partnership with 

almond harvesting equipment manufacturers, almond farmers, United States 

Department of Agriculture-Natural Resources Conservation Service (USDA-NRCS), and 

the District to compare “low dust” almond harvesters and an exhaust abatement device 

to conventional harvesters in the harvesting of almonds at a Valley farm. No differences 

were detected in the particle size distribution (PSD) characteristics of PM emitted from 

each harvester, with the exception of the exhaust abatement device, where large 

particles were efficiently captured by the cyclone. Emissions of total suspended 

particulates (TSP) and PM10 trended lower for all new harvesters and were significantly 

lower for most harvesters. There were significant reductions of PM2.5 ranging from 61-

69% observed from the harvesters and a 95% reduction in PM2.5 from the Clean Air 

Concept cyclone. The results of these tests imply that new harvest technologies are 

able to reduce PM emissions without affecting product quality. 

Poly Tetra Fluoro Ethylene Bags 

District BACT guidelines for almond hullers and shellers require the use of a baghouse, 

which controls PM by moving the contaminated flow of air through bag type filters. The 

technology has been achieved in practice in the District. Standard polyester bags are 

the most commonly used type of bag for baghouses in the almond hulling/shelling 

industry. A layer of dust (dust cake) collects on the upstream side of these bags and 

filtering efficiency increases as the layer grows; however, they are not designed to 

provide high PM2.5 control. On the other hand, membrane type bags treated with Poly 

Tetra Fluoro Ethylene (PTFE) contain extremely small pores and filtering occurs on the 

bag surface instead of in a dust cake. These types of filters are capable of controlling 

99.9%56 of PM2.5 emissions, whereas baghouses with polyester bags control PM2.5 

emissions by 95%-99%57

. 

The costs of using baghouses with PTFE bags rather than standard polyester bags 

were calculated. The pressure drop across polyester and PTFE bags is about the same 

 

56 Baghouse: PTFE Filters. (2012). Retrieved March 15, 2012 from http://www.baghouse.com/products/dust-collectorfilters/baghouse-filter/ptfe-filters/ as supported by EPA Air Pollution Control Technology Center, Verified 

Technologies. (2012). 

57 Roberts, C. (2009). Information on Air Pollution Control Technology for Woody Biomass Boilers. Northeast States 

for Coordinated Air Use Management and the EPA Office of Air Quality Planning and Standards.
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so there should not be a significant increase in electrical costs by using one bag over 

another. Additionally, existing baghouses would not require modifications to 

accommodate PTFE bags so the increased cost lies solely in the cost of the bags. A 

PTFE bag typically costs $23, whereas a polyester bag costs $12. The lifetime of both 

bags is approximately 2 years. The following cost differential was calculated, with 

knowledge that some facilities in the Valley have up to 2-3 baghouses, each with 500 

bags. District permits also require facilities to have replacement bags accounting for 

10% of the total number of bags; therefore 550 bags will be used for the following 

calculations. 

Additional Costs for using PTFE bags 

550 bags x ($23/ PTFE bag - $12/ polyester bag) / 2 years = $3,025/ year (per 

baghouse) 

3 baghouses x $3,025/ year = $9,075/ year (for 3 baghouses) 

Potential PM2.5 Emission Reductions from using PTFE bags 

The control efficiency for PM2.5 for polyester bags is assumed to be equivalent to the 

control efficiency for PM10. 

(99.9% control efficiency from PTFE bags – 99% control efficiency of polyester bags) 

= 0.9% additional control efficiency 

2012 emission inventory is 0.081 tons/day 

(0.081 tons/day PM2.5) x (0.9% additional control from using PTFE bags) 

= 0.000729 tons/day reduced

(0.000729 tons/day reduced from using PTFE bags) x (365 days/year) 

=0.266 tons/year reduced 

Potential Cost Effectiveness of using PTFE bags 

101 baghouses in the Valley 

(101 baghouses) x (PTFE bag costs $3,025/ year) = $305,525/year

($305,525/year) / (0.266 tons/year reduced) = $1,148,590/ton 

The cost effectiveness of replacing polyester bags was also calculated at the lower end 

of the emission control efficiency scale (95%) with the PTFE bags to determine what a 

more conservative cost effectiveness analysis would reveal; the cost effectiveness from 

95% polyester bags to 99.9% PTFE bags is $210,898/ton PM2.5 reduced. 

Although the initial annual capital cost may seem relatively low; in terms of cost 

effectiveness, PTFE bags are not a cost effective alternative to standard bags. The 
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additional control efficiency gains are in the fractions of tons of incremental emissions 

reductions. Additionally, as mentioned above, the emission inventory used in these 

calculations (0.081 tons/day PM2.5) includes the emissions of both almond hulling and 

pistachio hulling, meaning the actual inventory is smaller, and making the actual cost 

effectiveness even higher than calculated. 

The cyclone is another technology in common use at Valley facilities for PM control in 

almond hulling/shelling; however, like baghouses with polyester bags, the technology 

primarily provides PM10 control. Additionally, cyclones typically achieve 80-85% control 

efficiency. Approximately 37 facilities in the Valley use cyclones to control PM 

emissions. Therefore, if these facilities were required to replace cyclones with 

baghouses, the cost effectiveness would be as follows: 

Potential PM2.5 Emission Reductions for replacing cyclones with Baghouses with 

PTFE

The PM2.5 control efficiency for cyclones is assumed to be equivalent to the control 

efficiency for PM10 

(99.9% control efficiency of baghouse – 85% control efficiency of cyclone) 

= 14.9% additional control efficiency 

2012 emission inventory is 0.081 tons/day 

(0.081 tons/day PM2.5) x (14.9% control with use of baghouse) 

= 0.012 tons/day reduced

(0.012 tons/day reduced) x (365 days/year) 

= 4.38 tons/year reduced 

Potential Cost Effectiveness 

37 facilities to install baghouses at a minimum of $150,000 each 

With a 10 year amortization factor and 10% interest, the annualized cost for a $150,000 

baghouse would be: 

(0.1627) x ($150,000) = $24,405/year

(37 facilities) x (capital cost of baghouse $24,405/year) = $902,985/year 

($902,985/year) / (4.38 tons/year reduced) = $206,161/ton 

Replacing the existing cyclones with baghouses with PTFE bags would cost 

$206,161/ton, which does not include additional costs of installation, electrical system 

upgrades, ductwork, demolition or disposal of the cyclone. Therefore, replacing 

cyclones with baghouses is not a cost effective control option. As previously stated, the 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-194 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

emission inventory used in these calculations (0.081 tons/day PM2.5) includes the 

emissions of both almond hulling and pistachio hulling, meaning the actual inventory is 

smaller, and making the actual cost effectiveness even higher than stated. 

At this time, the District’s analysis indicates that there are no feasible opportunities for 

additional emission reduction regulatory strategies for this source category. 

Risk-based Strategy Analysis 

The PM2.5 emissions from this source category include the emissions from pistachio 

hulling and shelling operations (refer to SC 007). The emissions from these two source 

categories combined contribute 0.1% of average winter PM2.5 emitted from stationary 

and area sources in the 2012 emission inventory. As illustrated in the emission 

inventory table above, the emissions from this source category are relatively small 

throughout the year, with peak emissions occurring in summer months. Additionally, the 

emissions are geologic in nature, and, as described in Chapter 2, do not contribute 

significantly during the peak winter season, and are of low relative toxicity. 

Control Measure Commitments 

The following is a summary of recommended commitments for SC 006. 

Regulatory Action 

The District’s analysis did not identify any technologically feasible and cost effective 

potential controls. Therefore, there are no recommendations for regulatory actions. 

Incentive Action 

The District does not currently fund any incentive programs specific to almond hulling 

operations; there are no recommendations for new incentive programs for almond 

hulling activities at this time. One potential opportunity was identified to reduce 

emissions, which was found to be not cost effective for current practices. The District 

could potentially fund the replacement of existing particulate matter control devices with 

baghouses that use the PTFE bags; however, an incentive program would be unlikely 

due to the high cost effectiveness and low emissions reductions. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 

Policy Initiatives 

The District is not currently supporting any policy initiatives specific to almond hulling 

operations and there are no recommendations for new policy initiatives for these 

sources. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-195 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for new education and outreach efforts for 

these sources. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-196 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.7.7 SC 007 Pistachio Hulling/Shelling Operations 

Source Category 

This control measure source category would apply to pistachio hulling and shelling 

operations within the Valley. Pistachio hulling operations are permitted together under 

the same permit with the pistachio receiving and pre-cleaning portions of the operation. 

These operations use 1D-3D cyclones to control PM emissions from the pre-cleaning 

portion of the process, which is the Best Available Control Technology (BACT) 

standard. Typically pistachio processing equipment, located after the pre-cleaning 

section and prior to the pistachio dryers, is of a wet-process design; PM emissions from 

this portion of the operation are assumed to be negligible. California produces 98.5% of 

U.S. pistachios and production has expanded greatly in the last decade. Pistachio 

acreage doubled between 1997 and 2010, and production looks like it will continue to 

increase in the near future.58 In the interest of identifying every possible strategy to 

reduce PM2.5 emissions, pistachio hulling and shelling operations were evaluated for 

potential opportunities to reduce emissions, see the discussion below. 

Emission Inventory 

The emission inventory for this category is included as a part of the emission inventory 

for the control measure source category for almond hulling. Refer to the emission 

inventory table presented in SC 006 for this combined inventory. 

Regulatory Evaluation 

How would SC 007 compare with federal rules and regulations? 

There are no specific federal guidelines applying to pistachio hulling/shelling operations 

in terms of New Source Performance Standards (NSPS), Control Techniques 

Guidelines (CTG), Alternative Control Technology (ACT), Maximum Achievable Control 

Technology (MACT) and National Emission Standards for Hazardous Air Pollutants 

(NESHAP). Additionally, there are currently no EPA BACT determinations for pistachio 

hulling and shelling operations. 

How would SC 007 compare to rules in other air districts? 

This source category was compared to other air districts in California including 

SCAQMD, BAAQMD, SMAQMD, and VCAPCD; no rules were identified in other air 

districts regarding pistachio hulling and shelling operations. 

 

58 The Tioga Group. (2012). SJV Nut Industry Profile Preliminary Draft. 

http://www.sjvcogs.org/pdfs/2012/Nut%20Industry%20030612.pdf 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-197 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Emission Reduction Opportunities 

Pistachio shelling operations are served by a baghouse, which is the industry standard 

for shelling operations. While there is no specific BACT guideline for shelling 

operations, baghouses are typically attributed to a PM2.5 control efficiency of 95-99%. 

As discussed above in SC 006 (Almond Hulling/Shelling Operations), Poly Tetra Fluoro 

Ethylene (PTFE) bags have the potential to provide additional PM2.5 control when used 

in baghouses but are not cost effective due to the already high control efficiency of 

existing practices. Refer to SC 006 (Almond Hulling/Shelling Operations) for the cost 

effectiveness analysis. 

Unlike almonds which are shaken on the ground and vacuumed off the soil during 

harvesting, pistachios are caught with a canvas catcher before they hit the ground, 

which allows for a very small amount of dust and debris in addition to the pistachios. 

Much of the PM emissions associated with the processing of pistachios occur during the 

pre-cleaning stage, which is controlled by cyclones. The hulling stage is a wet process 

as the nuts are floated on water; PM emissions from this portion of the operation are 

assumed to be negligible. At this time, the District’s analysis indicates that there are no

feasible opportunities for additional emission reduction regulatory strategies for this 

source category. 

Risk-based Strategy Analysis 

The PM2.5 emissions from this source category include the emissions from almond 

hulling and shelling operations (refer to SC 006). The emissions from these two 

sources combined contribute 0.1% of average winter PM2.5 emitted from stationary and 

area sources in the 2012 emission inventory. The emissions from this source category 

are relatively small throughout the year, with peak emissions occurring in summer 

months. Additionally, the emissions are geologic in nature, and, as described in 

Chapter 2, do not contribute significantly during the peak winter season, and are of low 

relative toxicity. 

Control Measure Commitments 

The following is a summary of recommended commitments for SC 007. 

Regulatory Action 

The District’s analysis did not identify any technologically feasible and cost effective 

potential controls. Therefore, there are no recommendations for regulatory actions. 

Incentive Action 

The District does not currently fund any incentive programs specific to pistachio hulling 

operations; there is no recommendation for a new incentive program specific to 

pistachio hulling activities. One potential opportunity to reduce emissions was 

identified, but was found to be not cost effective for current practices (refer to the 

potential opportunities analysis for almond hulling for the cost effectiveness analysis). 

The District could potentially fund the replacement of existing PM control devices with 

baghouses that use the PTFE bags; however, an incentive program would be unlikely 

due to the high cost effectiveness and low emissions reductions. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-198 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 

Policy Initiatives 

The District is not currently supporting any policy initiatives specific to pistachio hulling 

operations and there are no recommendations for new policy initiatives for these 

sources. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for new education and outreach efforts for 

these sources. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-199 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.7.8 SC 008 Agricultural Material Screening/Shaking 

Operations 

Source Category 

This control measure source category would be applicable to the handling and 

processing of agricultural materials in biomass, composting, and other agricultural 

material handling facilities. 

Emission Inventory 

The emission inventory for this category is accounted for in other control measure 

source categories. Refer to Appendix B for the emission inventory. 

Regulatory Evaluation 

How would SC 008 compare with federal rules and regulations? 

There are no applicable federal standards and guidelines, such as Control Techniques 

Guidelines (CTG), Alternative Control Techniques (ACT), New Source Performance 

Standards (NSPS), National Emission Standards for Hazardous Air Pollutants 

(NESHAP), and Maximum Achievable Control Technology (MACT) for this source 

category. EPA Best Available Control Technology (BACT) requirements were also 

evaluated for potential opportunities; however no standards were listed for this category. 

How would SC 008 compare to rules in other air districts? 

SCAQMD Rule 1131.1 (Chipping and Grinding Activities) is the only rule in California 

identified to be applicable to agricultural material screening and shaking operations. 

Rule 1133.1 contains provisions to ensure that greenwaste is chipped or ground and 

used within 48 hours to prevent inadvertent decomposition. Biomass facilities are 

exempt from most requirements if the material temperature is maintained below 122 

degrees Fahrenheit and the moisture content is less than 30%. Greenwaste kept with 

moisture content less than 30% is also exempt from these requirements. The limits of 

this rule are targeted at controlling volatile organic compound (VOC) emissions rather 

than NOx or PM2.5. District analysis did not identify similar rules, regulated categories, 

or BACT requirements at BAAQMD and SCAQMD. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-200 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Emission Reduction Opportunities 

District analysis of potential emission reduction opportunities includes an evaluation of 

feasibility of wet suppression systems and enclosing conveyors and transfer points. 

Wet Suppression System 

A wet suppression system can achieve between 40-65% control of PM2.559. In a wet 

suppression system, water is generally applied to all emissions units, transfer points, 

and raw material stockpiles to ensure that adequate moisture is provided to the 

operation to successfully reduce PM emissions. No emissions would be reduced by 

requiring a wet suppression system because this control is currently in use at all 

identified facilities in the Valley and would be required at any new facility triggering 

BACT under the New Source Review Rule 2201. 

Enclosed Conveyors and Transfer Points 

Enclosing conveyors and transfer points to limit the emissions of PM is a practice used 

in addition to water spray at seven facilities in the Valley. This control option would 

potentially reduce emissions at the drop or transfer points on the conveyors. However, 

in addition to the control efficiency of enclosed conveyors being unknown, conveyors 

are already operated so that they move very slowly to avoid entraining dust and limit 

visible emissions. Therefore, the potential to reduce emissions is minimal and reduced 

emissions would not be quantifiable. 

At this time, the District’s analysis indicates that there are no feasible opportunities for 

additional emission reduction regulatory strategies for this source category. 

Risk-based Strategy Analysis 

The emissions from this source category are accounted for in the emission inventory of 

other control measures. However, the emissions are geologic in nature, and, as 

described in Chapter 2, do not contribute significantly during the peak winter season, 

and are of low relative toxicity. 

Refer to Appendix B for the emission inventory. 

Control Measure Commitments 

The following is a summary of recommended commitments for SC 008. 

Regulatory Action 

The District’s analysis did not identify any technologically feasible and cost effective 

potential controls. Therefore, there are no recommendations for regulatory actions. 

 

59 Environmental Protection Agency [EPA]. (1995). Compilation of Air Pollutant Emission Factors, Table B.2-3.

Research Triangle Park, NC.
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-201 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Incentive Action 

The District does not currently fund any incentive programs specific to reducing PM 

emissions from agricultural material screening and shaking operations. There are no 

recommendations for new incentive actions to reduce PM emissions from this source 

category. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 

Policy Initiatives 

The District is not currently supporting any policy initiatives specific to the control of PM 

emissions from agricultural material screening and shaking operations, and there are no 

recommendations for new policy initiatives for PM control of these operations. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for new education and outreach efforts for 

these sources. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-202 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.7.9 SC 009 Tub Grinding 

Source Category 

This control measure source category would apply to operations using a tub grinder for 

agricultural material processing. Tub grinders are used to grind organic materials such 

as wood and agricultural materials for biomass fuel processing facilities, composting 

facilities, landscape material manufacturing (e.g. wood bark, mulch, etc.), or agricultural 

waste grinding (e.g. orchard removal, land clearing, etc.). These units are typically 

powered by diesel-fired internal combustion engines (ranging from 100 horse power 

(hp) to 1,600 hp) and mounted on wheels to be transportable, which allows the units to 

be towed to the jobsite where the piles of material are to be ground. In addition, these 

units may also be self-propelled and track-mounted; in this case the diesel engine 

powering the equipment is also used for motive power and is exempt from District 

permits since it is considered to be mobile equipment. The diesel engines powering the 

transportable units are subject to District Rule 4702 (Internal Combustion Engines) and 

Best Available Control Technology (BACT) Guideline 3.2.11. This control measure 

source category discussion addresses the particulate matter (PM) emissions from the 

loading, grinding, and conveying of the process materials. 

Emission Inventory 

Emissions generated by the engines of the tub grinders are accounted for as a part of 

the inventory for District Rule 4702 (Internal Combustion Engines). The fugitive 

particulate emissions from these units are accounted for as a part of the stationary and 

area inventory. See Appendix B. 

Regulatory Evaluation 

How would SC 009 compare with federal rules and regulations? 

There are no specific federal guidelines applying to wood chipping and stump grinding 

operations in terms of New Source Performance Standards (NSPS), National Emission 

Standards for Hazardous Air Pollutants (NESHAP), Maximum Achievable Control 

Technology (MACT), Control Techniques Guidelines (CTG) or Alternative Control 

Techniques (ACT) for this category. 

How would SC 009 compare to rules in other air districts? 

Upon comparing this source category to other California air districts’ rules, the only 

similar rule found was SCAQMD Rule 1131.1 (Chipping and Grinding Activities). Rule 

1133.1 contains provisions for biomass facilities to maintain the material temperature 

below 122 degrees Fahrenheit and the moisture content to less than 30%; however, 

these limits are targeted at controlling volatile organic compound (VOC) emissions 

rather than NOx or PM2.5. Portable chipping and grinding, agricultural chipping and 

grinding, land clearing chipping and grinding, wood waste chipping and grinding, and 

palm chipping and grinding activities are exempt from Rule 1133.1. Analysis 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-203 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

determined that no other air district regulates this source category. Air districts 

analyzed include BAAQMD, SMAQMD, and VCAPCD. 

Emission Reduction Opportunities 

No technologically feasible or alternative basic equipment are identified in the District’s 

Best Available Control Technology (BACT) guidelines. 

Currently, fugitive particulate emissions from transportable and self-propelled tub 

grinders are controlled with a water sprinkler system during loading, grinding, and 

unloading of the process materials to prevent visible emissions in excess of 5% opacity 

per Rule 2201 (New Source Review) and BACT guideline 6.4.2. Water sprinkler 

systems achieve between 40-65% control of PM2.560. It is standard practice to use 

water spray on this type of equipment to meet the visible emission requirements of Rule 

4101 (Visible Emissions); therefore, requiring water control for tub grinding operations 

would not result in additional emission reductions from this source category. A potential 

control option considered would be to require a baghouse to be installed onto the trailer 

of the equipment to capture fugitive PM emissions. Due to the large size of the 

additional equipment required to be installed onto the trailer and the limited space 

available, a baghouse is not technologically feasible for a transportable unit. 

Risk-based Strategy Analysis 

The emissions from this source category are accounted for in the emission inventory of 

other control measures. Refer to Appendix B for the emission inventory. The NOx 

emissions from this source category are from the engines used to power these units 

and are currently controlled by Rule 4702 (Internal Combustion Engines). Due to the 

nature of tub grinding activities, it is assumed that there are no elevated emission levels 

in the winter months. Additionally, the emissions are geologic in nature, and, as 

described in Chapter 2, do not contribute significantly during the peak winter season, 

and are of low relative toxicity. 

Control Measure Commitments 

The following is a summary of recommended commitments for SC 009. 

Regulatory Action 

The District’s analysis did not identify any technologically feasible and cost effective 

potential controls. Therefore, there are no recommendations for regulatory actions. 

 

60 Environmental Protection Agency [EPA]. (1995). Compilation of Air Pollutant Emission Factors, Table B.2-3.

Research Triangle Park, NC. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-204 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Incentive Action 

The District does not currently fund any incentive programs specific to reducing PM 

emissions from tub grinding operations. There are no incentive action 

recommendations to reduce PM emissions from tub grinders at this time. The District 

analysis did not identify new technologies that could potentially reduce emissions from 

this source category. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 

Policy Initiatives 

The District is not currently supporting any policy initiatives specific to the control of PM 

emissions from tub grinding operations and there are no recommendations for new 

policy initiatives for PM control of tub grinding operations. 

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for new education and outreach efforts for 

these sources. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-205 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.7.10 SC 010 Abrasive Blasting 

Source Category 

Abrasive blasting involves the cleaning or preparing of a surface by forcibly propelling a 

stream of abrasive material against such surface. Abrasive blasting can occur in a 

confined or an unconfined area, depending on the type of surface or application. 

Abrasive materials commonly used are walnut shells, various mineral or metal products, 

garnet, sand or aggregate, slag, steel grit abrasive, or steel shot. 

Emission Inventory 

Pollutant 2007 2012 2014 2015 2016 2017 2018 2019

Annual Average - Tons per day

PM2.5 0.22 0.22 0.24 0.24 0.25 0.26 0.26 0.27

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Winter Average - Tons per day

PM2.5 0.22 0.22 0.23 0.24 0.25 0.25 0.26 0.27

NOx 0 0 0 0 0 0 0 0

SOx 0 0 0 0 0 0 0 0

Regulatory Evaluation 

How would SC 010 compare with federal rules and regulations? 

EPA promulgated management practices, and monitoring, recordkeeping, and reporting 

requirements for dry abrasive blasting within 40 CFR 63, Subpart XXXXXX–National 

Emission Standards for Hazardous Air Pollutants Area Source Standards for Nine Metal 

Fabrication and Finishing Source Categories. 

Air pollution standards for abrasive blasting operations, or sandblasting, are set by 

statewide regulations, specifically California Code of Regulations, Title 17, Subchapter 

6, Sections 92000 through 92530 (Abrasive Blasting). Furthermore, California Health 

and Safety Code (CH&SC), Section 41904 stipulates that no air district regulation can 

be stricter than the state standard. The state standard limits visible emissions from 

sandblasting operations to 20% opacity if within a permanent structure or 40% if outside 

a permanent structure. 

How would SC 010 compare to rules in other air districts? 

No rule from another air district has requirements beyond what is already required in 

state standards. BAAQMD Regulation 12, Rule 4 (Sandblasting), SCAQMD Rule 1140 

(Abrasive Blasting), and VCAPCD Rule 74.1 (Abrasive Blasting) regulate abrasive 

blasting operations and activities, but all simply conform to the state standards. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-206 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Emission Reduction Opportunities 

Achieved-in-practice Best Available Control Technology (BACT) controls for 

sandblasting include baghouses, filters, or cartridge dust collectors. With such 

technologies, 99% control efficiency can be achieved. As emissions sources, 

sandblasting operations within the District are subject to District Rule 4102 (Nuisance) 

and the standards of 17 California Code of Regulations (CCR) Section 92200 (opacity) 

and 17 CCR Section 92500 (performance standards such as CARB-certified abrasives). 

Opportunities for further emissions reductions are limited because of the CH&SC 

stipulation that air districts cannot impose stricter rules on sandblasting operations. The 

District’s analysis has determined that there are no feasible opportunities for additional 

emission reductions for this source category. 

Risk-based Strategy Analysis 

The emissions from this source category contribute 0.4% of average winter PM2.5 

emitted from stationary and area sources in the 2012 emission inventory. As illustrated 

in the emission inventory table above, the emissions from this source category are 

consistently relatively small throughout the year, with no elevated emission levels in the 

winter months. 

Control Measure Commitments 

The following is a summary of the recommended commitments for SC 010. 

Regulatory Action 

The District’s analysis did not identify any technologically feasible and cost effective 

potential controls. Therefore, there are no recommendations for regulatory actions. 

Incentive Action 

The District does not currently have an incentive program specific to abrasive blasting 

operations. There is no recommendation for a new incentive program for abrasive 

blasting operations at this time. 

Technology Advancement Action 

There is no recommendation for a new technology advancement project for this source 

category. Through its Technology Advancement Program, the District will continue to 

seek potential feasible and low-cost technologies that may provide for additional 

emission reduction opportunities in this category. 

Policy Initiatives 

The District is not currently supporting any policy initiatives specific to abrasive blasting 

and there are no recommendations for new policy initiatives for these sources. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-207 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Education and Outreach 

The District currently provides a robust education and outreach program for regulated 

sources through the Small Business Assistance program, Permit Stakeholder Meetings, 

Compliance Assistance Bulletins, and public notices for public workshops and public 

hearings. There are no recommendations for new education and outreach efforts for 

these sources. 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-208 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

D.8 EMISSION INVENTORY CODES 

Table D-19 Emission Inventory Codes

Control Measure Emission Inventory Codes

Rule 4103 (Open Burning) 670-660-0262-9842; 670-660-0262-9856; 670-660-0262-9862; 

670-660-0262-9874; 670-660-0262-9884; 670-660-0262-9888; 

670-660-0262-9892; 670-662-0262-9866; 670-662-0262-9878; 

670-662-0262-9882; 670-668-0200-9858; 670-668-0200-9872; 

670-668-0200-9886; 670-995-0240-9848; 670-668-0200-9894 

Rule 4104 (Reduction of 

Animal Matter) 420-995-6004-0000 

Rule 4106 (Prescribed 

Burns) 

670-666-0200-0000; 670-667-0200-0000; 670-664-0200-0000; 

670-670-0200-0000 

Rule 4203 (Particulate Matter 

Emissions from the 

Incineration of Combustible 

Refuse)

010-005-0243-0000 

Rule 4204 (Cotton Gins) 420-418-6028-0000; 420-420-6028-0000 

Rule 4307 (Boilers, Steam 

Generators and Process 

Heaters 2 – 5 MMBtu/hr)

010-005-0110-0000; 010-005-0124-0000; 010-005-0130-0000; 

010-005-0300-0000; 010-005-1220-0000; 020-005-0110-0000; 

030-005-0110-0000; 030-005-0124-0000; 030-005-0130-0000; 

030-005-1220-0000; 030-005-1530-0000; 030-010-0110-0000; 

030-010-0130-0000; 030-010-1220-0000; 030-010-1600-0000; 

030-015-0110-0000; 030-015-0130-0000; 040-005-0110-0000; 

040-005-1530-0000; 040-010-0100-0000; 040-010-0110-0000; 

040-010-0120-0000; 040-010-0130-0000; 040-010-1000-0000; 

050-005-0110-0000; 050-005-0122-0000; 050-005-0124-0000; 

050-005-0130-0000; 050-005-0320-0000; 050-005-1100-0000; 

050-005-1220-0000; 050-005-1510-0000; 050-005-1520-0000; 

050-005-3220-0000; 050-010-0110-0000; 050-010-0120-0000; 

050-010-0320-0000; 050-010-1220-0000; 050-010-1500-0000; 

052-005-0110-0000; 052-005-0124-0000; 052-005-1220-0000; 

052-010-0110-0000; 052-010-0120-0000; 052-010-1224-0000; 

060-005-0110-0000; 060-005-0122-0000; 060-005-0124-0000; 

060-005-0130-0000; 060-005-0142-0000; 060-005-0144-0000; 

060-005-0320-0000; 060-005-1220-0000; 060-005-1510-0000; 

060-005-1520-0000; 060-010-0100-0000; 060-010-0110-0000; 

060-010-0120-0000; 060-010-0142-0000 

The EICs are the same for Rules 4306/4320, 4307, and 4308; 

the three rules share a combined emission inventory. Baseline 

emissions from the 2008 and 2009 rule amendments of these 

rules were used to determine the percentage of emissions for 

each rule. Those respective percentages are applied to the 

combined inventory to get the individual emission inventories.

Rule 4308 (Boilers, Steam 

Generators and Process 

Heaters 0.075 to less than 2.0 

MMBtu/hr)

The EICs are the same for Rules 4306/4320, 4307, and 4308; 

the three rules share a combined emission inventory. Baseline 

emissions from the 2008 and 2009 rule amendments of these 

rules were used to determine the percentage of emissions for 

each rule. Those respective percentages are applied to the 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-209 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Control Measure Emission Inventory Codes

combined inventory to get the individual emission 

inventories. See Rule 4307 for the EICs. 

Rule 4309 (Dryers) 430-422-7078-0000; 430-424-7006-0000; 430-995-7000-0000; 

499-995-0000-0000; 499-995-5630-0000 

Rule 4311 (Flares) 110-132-0130-0000; 110-132-0146-0000; 120-132-0136-0000; 

130-132-0110-0000; 130-132-0136-0000; 310-320-0010-0000; 

310-320-0110-0000; 310-320-0120-0000; 310-320-0130-0000; 

320-320-0010-0000; 320-320-0110-0000; 320-320-0120-0000; 

320-320-0130-0000 

Rule 4313 (Lime Kilns) Lime kilns are not included in the ARB emissions inventory. 

There are no lime kilns currently operating in the Valley. 

Rule 4320 (AERO for 

Boilers, Steam Generators, 

and Process Heaters >5 

MMBtu/hr) 

The EICs are the same for Rules 4306/4320, 4307, and 4308; 

the three rules share a combined emission inventory. Baseline 

emissions from the 2008 and 2009 rule amendments of these 

rules were used to determine the percentage of emissions for 

each rule. Those respective percentages are applied to the 

combined inventory to get the individual emission 

inventories. See Rule 4307 for the EICs. 

Rule 4352 (Solid Fuel Fired 

Boilers, Steam Generators, 

and Process Heaters) 

010-005-0214-0000; 010-005-0218-0000; 010-005-0220-0000; 

010-005-0240-0000; 010-005-0243-0000; 010-005-0254-0000; 

020-005-0218-0000; 020-005-0230-0000; 030-005-0214-0000; 

050-005-0214-0000; 050-005-0240-0000; 050-005-0254-0000; 

052-005-0240-0000; 060-005-0240-0000; 060-005-0264-0000 

Rule 4354 (Glass Melting 

Furnaces) 460-460-7037-0000; 460-460-7038-0000; 460-460-7039-0000 

Rule 4550 (Conservation 

Management Practices) 

620-614-5400-0000; 620-615-5400-0000;650-650-5400-0000; 

650-651-5400-0000 

Rule 4692 (Commercial 

Charbroiling) 690-680-6000-0000 

Rule 4702 (Internal 

Combustion Engines) 

010-040-0110-0000; 010-040-1200-0000; 020-040-0110-0000; 

020-040-1200-0000; 030-040-0110-0000; 030-040-0124-0000; 

030-040-1200-0000; 030-040-1210-0000; 040-040-0110-0000; 

050-040-0012-0000; 050-040-0110-0000; 050-040-0124-0000; 

050-040-1200-0000; 052-040-0110-0000; 052-040-1200-0000; 

052-042-0110-0000; 052-042-1200-0000; 052-042-1200-0010; 

052-042-1200-0011; 060-040-0110-0000; 060-040-0124-0000; 

060-040-0142-0000; 060-040-0146-0000; 060-040-1100-0000; 

060-040-1200-0000; 060-040-1210-0000; 060-995-1220-0000; 

099-040-1200-0000 

Rule 4703 (Stationary Gas 

Turbines) 

010-045-0110-0000; 010-045-1200-0000; 020-045-0110-0000; 

030-045-0110-0000; 040-045-0134-0000; 050-045-1200-0000; 

060-045-0110-0000; 060-045-1200-0000 

Rule 4802 (Sulfuric Acid 

Mist) 410-400-2058-0000 

Rule 4901 (Wood Burning 

Fireplaces and Wood Burning 

Heaters) 

610-600-0230-0000; 610-602-0230-0000 

Rule 4902 (Residential 610-608-0110-0000 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-210 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Control Measure Emission Inventory Codes

Water Heaters) 

Rule 4905 (Natural Gas – 

Fired, Fan Type Residential 

Central Furnace) 

610-606-0110-0000 

Rule 8011 (General 

Requirements) 

There is no specific emissions inventory associated with Rule 

8011. 

Rule 8021 (Construction, 

Demolition, Excavation, 

Extraction, and Other 

Earthmoving Activities) 

630-622-5400-0000; 630-624-5400-0000; 630-626-5400-0000; 

630-628-5400-0000; 630-634-5400-0000 

Rule 8031 (Bulk Materials) 430-436-7006-0000; 430-436-7078-0000; 430-995-7064-0000 

Rule 8041 (Carryout and 

Trackout) 

The EICs are included in Rule 8061 (Paved and Unpaved 

Roads). 

Rule 8051 (Open Areas) 650-652-5400-0000 

Rule 8061 (Paved and 

Unpaved Roads) 

640-635-5400-0000; 640-637-5400-0000; 640-639-5400-0000; 

640-641-5400-0000; 640-643-5400-0000; 645-638-5400-0000; 

645-640-5400-0000; 645-644-5400-0000; 645-648-5400-0000 

Rule 8071 (Unpaved Vehicle 

Traffic) 

645-645-5400-0000; 645-647-5400-0000. 

The ARB Emissions Inventory database does not contain 

emissions data on unpaved vehicle and equipment traffic 

areas. 

Rule 8081 (Ag Sources) 645-646-5400-0000 

SC 001 (Source Category: 

Lawn Care Equipment)

860-901-1100-1152; 860-901-1100-1153; 860-901-1100-1166; 

860-901-1100-1167; 860-901-1100-1168; 860-901-1100-1169; 

860-901-1100-1174; 860-901-1100-1175; 860-901-1100-1184; 

860-901-1100-1185; 860-901-1100-1332; 860-901-1100-1333; 

860-901-1100-1344; 860-901-1100-1345; 860-901-1100-1362; 

860-901-1100-1363; 860-901-1100-1374; 860-901-1100-1375; 

860-901-1100-2984; 860-901-1100-2985; 860-901-1100-2994; 

860-901-1100-2995; 860-901-1100-4044; 860-901-1100-4045; 

860-901-1100-4064; 860-901-1100-4065; 860-901-1100-4094; 

860-901-1100-4095; 860-901-1100-4102; 860-901-1100-4103; 

860-901-1100-4112; 860-901-1100-4113; 860-901-1100-4124; 

860-901-1100-4125; 860-901-1100-5672; 860-901-1100-5673; 

860-901-1100-5684; 860-901-1100-5685; 860-901-1100-5692; 

860-901-1100-5693; 860-901-1100-5704; 860-901-1100-5705; 

860-901-1100-5724; 860-901-1100-5725; 860-901-1100-7604; 

860-901-1100-7605; 860-901-1100-7614; 860-901-1100-7615; 

860-901-1100-8104; 860-901-1100-8105; 860-901-1100-8112; 

860-901-1100-8113; 860-901-1100-8344; 860-901-1100-8345; 

860-901-1100-8352; 860-901-1100-8353; 860-901-1100-8364; 

860-901-1100-8365; 860-901-1100-8372; 860-901-1100-8373; 

860-901-1100-8384; 860-901-1100-8385; 860-901-1100-9074; 

860-901-1100-9075; 860-901-1100-9542; 860-901-1100-9543; 

860-901-1100-9554; 860-901-1100-9555; 860-901-1100-9834; 

860-901-1100-9835; 860-902-1100-1152; 860-902-1100-1153; 

860-902-1100-1166; 860-902-1100-1167; 860-902-1100-1168; 

860-902-1100-1169; 860-902-1100-1174; 860-902-1100-1175; 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-211 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

Control Measure Emission Inventory Codes

860-902-1100-1184; 860-902-1100-1185; 860-902-1100-2984; 

860-902-1100-2985; 860-902-1100-2994; 860-902-1100-2995; 

860-902-1100-4044; 860-902-1100-4045; 860-902-1100-4064; 

SC 001 (Source Category: 

Lawn Care Equipment) 

860-902-1100-4065; 860-902-1100-4094; 860-902-1100-4095; 

860-902-1100-4102; 860-902-1100-4103; 860-902-1100-4112; 

860-902-1100-4113; 860-902-1100-4124; 860-902-1100-4125; 

860-902-1100-5672; 860-902-1100-5673; 860-902-1100-5684; 

860-902-1100-5685; 860-902-1100-5692; 860-902-1100-5693; 

860-902-1100-5704; 860-902-1100-5705; 860-902-1100-5724; 

860-902-1100-5725; 860-902-1100-7604; 860-902-1100-7605; 

860-902-1100-7614; 860-902-1100-7615; 860-902-1100-8104; 

860-902-1100-8105; 860-902-1100-8112; 860-902-1100-8113; 

860-902-1100-8344; 860-902-1100-8345; 860-902-1100-8352; 

860-902-1100-8353; 860-902-1100-8364; 860-902-1100-8365; 

860-902-1100-8372; 860-902-1100-8373; 860-902-1100-8384; 

860-902-1100-8385; 860-902-1100-9074; 860-902-1100-9075; 

860-902-1100-9542; 860-902-1100-9543; 860-902-1100-9554; 

860-902-1100-9555; 860-902-1100-9834; 860-902-1100-9835; 

860-903-1100-1394; 860-903-1100-1395; 860-903-1100-1404; 

860-903-1100-1405; 860-903-1100-4084; 860-903-1100-4085; 

860-903-1100-5744; 860-903-1100-5745; 860-903-1100-5754; 

860-903-1100-5755; 860-903-1210-1190; 860-903-1210-1200; 

860-903-1210-1210; 860-903-1210-1220; 860-903-1210-1230; 

860-903-1210-1240; 860-903-1210-1250; 860-903-1210-1350; 

860-903-1210-1380; 860-903-1210-4050; 860-903-1210-4070; 

860-903-1210-4130; 860-903-1210-4140; 860-903-1210-4150; 

860-903-1210-5710; 860-903-1210-5730; 860-903-1210-8390; 

860-903-1210-8400; 860-903-1210-8410 

SC 002 (Energy Efficiency) None 

SC 003 (Fireworks) None 

SC 004 (Sand and Gravel 

Operations) 

430-422-7078-0000; 430-426-0210-0000; 430-426-7078-0000; 

430-426-7092-0000 

SC 005 (Asphalt/Concrete 

Operations) 

430-424-7006-0000; 430-424-7050-0000; 430-429-7016-0000; 

430-430-7016-0000; 430-430-7018-0000; 430-436-7006-0000; 

430-995-7006-0000; 430-995-7012-0000; 430-995-7016-0000; 

430-995-7018-0000; 430-995-7050-0000; 430-995-7072-0000 

SC 006 (Almond 

Hulling/Shelling Operations) 420-418-6003-0000 

SC 007 (Pistachio 

Hulling/Shelling Operations) The EIC is included in SC 006 

SC 008 (Agricultural Material 

Screening/Shaking 

Operations) 

None 

SC 009 (Tub Grinding 

Operations) None 

SC 010 (Abrasive Blasting) 430-428-6084-0000; 430-428-7000-0000; 430-428-7036-0000; 

430-428-7078-0000; 430-428-7084-0000; 430-428-7088-0000; 

430-428-7090-0000 
San Joaquin Valley Unified Air Pollution Control District December 20, 2012

D-212 Appendix D: Stationary and Area Source Control Strategy Evaluation 

 2012 PM2.5 Plan

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