D-0 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan

2012 PM2.5 Plan

SJVUAPCD 

# Appendix D

Stationary and Area

Source Control Strategy EvaluationSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

Appendix D: Stationary and Area Source Control Str ategy Evaluation

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Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### Table of Contents

D.1 Combustion Devices ................................

................................................... ...... D-7

D.1.1 Rule 4203 Particulate Matter Emissions from the Inc ineration of

Combustible Refuse ................................ ............................................... D-1 0

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

to 5.0 MMBtu/hr ...................................

................................................... D-13

D.1.3 Rule 4308 Boilers, Steam Generators and Process Hea ters–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 B oilers, Steam Generators, and Process Heaters Greater than 5.0 MM Btu/hr ............... D-32

D.1.6 Rule 4352 Solid Fuel Fired Boilers, Steam Generator s, 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 B urning .............. 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-132San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan D.6 Fugitive Particulate Matter .......................

................................................... .. D-135

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

D.6.2 Rule 8021 Construction, Demolition, Excavation, Ext raction, and Other Earthmoving Activities ............................ .............................................. D-14 1

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-1 79

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 Oper ations ............... 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-208San Joaquin Valley Unified Air Pollution Control Di strict November 20, 2012

D-1 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Appendix D: Stationary and Area Source Control Stra tegy Evaluation

The San Joaquin Valley air basin (Valley) faces sig nificant challenges in meeting the National Ambient Air Quality Standards (NAAQS). Th e San Joaquin Valley Air Pollution Control District (District) has demonstrated leader ship in developing and implementing groundbreaking regulatory strategies to reduce emis sions. Tough and innovative rules, such as those for indirect source review, residenti al fireplaces, glass manufacturing, and agricultural burning, have set benchmarks for Calif ornia and the nation.

The District has adopted many regulatory control me asures 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) polic y, 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 reduc tions, and include both stationary

and area source control measures as well as Califor nia Air Resources Board (ARB) rules for mobile sources. The stationary and area source control measures that the District has already adopted and are contributing t o 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 re duce emissions from stationary and area sources that will achieve significant emission s reductions in the coming years, the District has invested significant effort in investi gating additional potential opportunities for reducing emissions and leaving “no stone unturn ed,” as outlined in the following Guiding Principles adopted by the District’s Govern ing Board:

• Use sound science as the plan’s foundation. This i ncludes efforts to assess public health impacts, predict future air quality, determine the extent of emissions reductions needed, and evaluate the avail ability, 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, pol icy initiatives, guidance documents, and outreach, including working with cit ies and counties to incorporate 2012 PM2.5 Plan principles into their g eneral 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.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-2 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Table D-1 District Stationary and Area Source Regul ations Contributing to

Continued PM2.5 Improvement

Adopted District Rules Emissions

Reduced 1

Rule 4103 Open Burning 0.12 tpd NOx 0.34 tpd PM2.5

Rule 4106 Prescribed Burning and Hazard Reduction Burning NQ 2

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 NQ 2

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 Heaters 3 2.40 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 ru le amendments. 2. Not quantified. 3. As an average for November – April; the reductio ns 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 in vestment 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 regulato ry strategies and considers other opportunities for timely, innovative, and cost effe ctive emissions reductions, including new incentive programs, policy initiatives, and enh anced education and outreach efforts. Also, where additional research is requir ed to determine if potential opportunities to further reduce emissions of partic ulate matter and particulate precursors may be feasible for the Valley, the Dist rict recommends further study. Further study commitments are another example of th e District’s commitment toSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-3 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan continuously pursue emission reduction opportunitie s, 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. T he 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 continu e to reduce emissions to meet more stringent air quality standards.

This appendix consists of a literature review and e valuation of emission reduction opportunities for a variety of stationary and area source categories. District staff in multiple departments with expertise in these variou s sectors contributed to this effort. The evaluations in this appendix are intended to ca pture relevant background information, examine emission reduction opportuniti es for technological and economic feasibility, make recommendations for appropriate D istrict 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 sour ce categories evaluated in this appendix are organized into the following groups: c ombustion 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 t o that category. Each individual control measure analyzed in this appendix has its own discu ssion and source category analysis.

Source Category Analysis Each control measure source category analysis inclu des regulatory evaluations including an assessment of Reasonably Available Con trol 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 D istrict.

Regulatory Evaluation As part of the regulatory evaluation, District rule s and source categories are compared to federal air quality regulations and standards, a nd 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 liter ature review of the following regulations and guidance do cuments:

o Control Techniques Guidelines (CTG)

o Alternative Control Techniques (ACT)

o National Emission Standards for Hazardous Air Poll utants (NESHAP)

o New Source Performance Standards (NSPS)

o Best Available Control Technology (BACT)San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-4 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 regulat ions adopted by California’s most progressive air distri cts. 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 (SCAQM D)

o Sacramento Metropolitan Air Quality Management Dis trict (SMAQMD)

o Bay Area Air Quality Management District (BAAQMD)

o Ventura County Air Pollution Control District (VCA PCD)

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

as “ the lowest emission limitation that a particular so urce is capable of meeting by the application of control technology that is re asonably 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 th at are subject to CTG documents issued by EPA and for “major sources” of VOCs and oxides of nitrogen (NOx), which are ozone precursors. Each c ontrol measure source category subject to RACT is evaluated to determine if each is at least as stringent as established RACT requirements. All so urce 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 ident ifies potential emission reduction opportunities for PM2.5 and its precursors, such as NOx and SOx. The potential emission reduction opportunities are then thoroughl y evaluated using the following key

factors:

• Technological Feasibility – The technological feasibility analysis determine s if a potential opportunity to reduce emissions will phys ically work for existing facilities and operators in the Valley. District analysis of technological feasibility includes a literature review of BACT guidelines; District pe rmits; environmental and technological studies; EPA and ARB guideline docume nts; and other air districts’ rules, regulations, and guidelines, to identify pot ential opportunities and determine the technological feasibility of any iden tified potential opportunities.

• Cost Effectiveness – The purpose of conducting a cost effectiveness a nalysis is to evaluate the economic reasonableness of a pollut ion 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 th e control technology or technique, divided by the emissions reductions achi eved, in tons per year.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-5 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

## ( ) ) / ( Reduction Emission )

/ ($ cost Compliance /$ ess Effectiven Cost

year ton year ton =

Additionally, a literature review of previous staff reports from District rules, staff reports and studies from other air districts, EPA t echnical guidance documents, and applicable study data from the scientific commu nity is conducted to determine if any technologically feasible opportuni ties that were previously not cost effective have changed to become cost effectiv e since the last amendment.

Risk-Based Strategy The District’s Risk-based Strategy (RBS) fits withi n and effectively supplements EPA’s current Clean Air Act (CAA) framework. Through the RBS, the District is maximizing public health improvements resulting from the Distr ict’s attainment strategies and related initiatives. The District is integrating t he RBS into various aspects of the 2012

PM2.5 Plan , including control measure review and strategy pri oritization. As described in Chapter 2 of this plan, the District uses a five -factor exposure assessment methodology to evaluate the PM2.5 attainment strate gy 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 pub lic 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 indicat ing that reductions of direct PM2.5 have a greater health benefit per ton than reductio ns 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 Plann ing and Standards: Implementation Guidance for the 2006 24- Hour Fine Particle (PM2.5) National Ambient Air Qua lity Standards (NAAQS). Retrieved from http://www.epa.gov/ttn/naaqs/pm/pdfs/20120302_imple ment_guidance_24- hr_pm2.5_naaqs.pdf
[2] Fann, N., Fulcher, C.M., & Hubbell, B.J. (2009). The Influence of Location, Source, and Emission Typ e 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: Incorpor ating 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.xSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-6 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Control Measure Commitment Recommendations District’s analysis of all applicable criteria disc ussed 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 Distri ct will determine which control strategies should be included in the plan. Commitm ents 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 redu ce emissions

• Incentive programs

• Technology advancement programs

• Policy initiatives

• Increased public outreach and education

Regulatory action commitments are summarized in Cha pter 5 (Regulatory Control Measures), and all commitments are summarized in Ch apter 9 (Progress Toward Attainment of the 2006 PM2.5 Standard).San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-7 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### 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 interna l or external combustion creates multiple pollutants, including oxides of nitrogen ( NOx), the primary PM2.5 precursor, volatile organic compounds (VOC), and oxides of sul fur (SOx). Establishing effective emission reduction strategies for combustion device s continues to be a key component of the San Joaquin Valley Air Pollution Control Dis trict’s (District) strategy to reduce emissions and achieve federal air quality standards

.

Combustion devices are utilized in numerous applica tions throughout the private and public sectors. The control measure source categor ies discussed affect several industries in the San Joaquin Valley air basin (Val ley) including, but not limited to: electrical utilities, cogeneration, oil and gas pro duction, 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 redu ce emissions to meet attainment requirements and protect public health. The Distri ct’s longstanding, progressive strategy for reducing emissions is a multifaceted e ffort that includes incentive programs and policy initiatives in addition to prohibitory r ules. The following discussion summarizes both the existing District efforts to re duce emissions from this source category, and evaluations for potential opportuniti es for further emissions reductions.

Incentive Programs Incentive programs are an integral part of the emis sion reduction efforts of the District, especially where the District lacks direct jurisdic tion in establishing emission control requirements. Since the emission units within the Combustion Devices category are typically located at stationary sources and have be en subject to several generations of regulations, the opportunities for incentive progra ms have been minimal. The District currently funds the following incentive programs th at 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 dat e, the program has distributed over $100 million in grant money and has funded the repl acement and/or purchase of 6,094 new engines and electric motors, reducing 47,059 to ns of NOx and 1,738 tons of particulate emissions. Similarly, the District par tnered with the Natural Resources Conservation Service (NRCS) Environmental Quality I ncentives Program (EQIP) toSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-8 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan replace 15 agricultural pump engines in the Valley. Between 2003 and 2011, NRCS also replaced an additional 547 diesel irrigation e ngines in the Valley. 1

Incentives have also been available for biomass fac ilities through state and Federal funded programs independent from the District. Fun ding or tax credits are available through some short-term programs such as the Existi ng 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 Asse mbly Bill 118 (Núñez Statutes of 2007, Chapter 750), which directs the CEC to develo p the Alternative and Renewable Fuel and Vehicle Technology Program , are available to identify and promote alternative biomass-based feedstocks, including agricultural wa ste, for the production of alternative

fuels.

Policy Initiatives The District’s policies and Legislative Platform ar e important components to the District’s strategy to attain federal ambient air q uality standards. The District utilizes policies and the legislative platform to bring atte ntion 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 rat es for power produced from biomass to enhance the economic feasibility of this alternativ e. 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 i n the field, has underlined the importance of biomass facilities in providing a mechanism to d ispose of this agricultural material.

The District also supports legislation that calls f or 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 prog rams. The District supports the continuation of air quality funding in the Farm Bil l to accelerate the replacement of agricultural equipment. Incentive funds have resul ted in the turnover of thousands of irrigation pumps thus far, generating significant e missions reductions for the Valley.

Rules and Regulations The following is a list of District rules that appl y 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 se veral generations of rule amendments. Each of the following rules will be ev aluated to examine potential opportunities for additional emissions reductions.

1 The District has also participated in the replacem ent of various mobile source combustion units (i.e. tractors) through other incentives programs. Please see Chap ter 6 for additional information.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-9 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 09/20/2007San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-10 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.1.1 Rule 4203 Particulate Matter Emissions from t he Incineration

of Combustible Refuse

Source Category Rule 4203 is applicable to incinerators or other eq uipment used to dispose of or process combustible refuse by incineration. The rule limit s 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 a nd subsequently amended for District rule number reorganization on December 17, 1992. There are currently 3 facilities in the Valley subject to Rule 4203. The se facilities currently implement Best Available Control Technology (BACT) requirements; t he facilities are required to mitigate the discharge of air pollutants to the max imum degree achievable. For this source category, examples of emission control techn ologies 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 ru les and regulations?

There are no specific federal guidelines for partic ulate matter concentration in terms of New Source Performance Standards (NSPS), Control Te chniques Guidelines (CTG), Alternative Control Technology (ACT), Maximum Achie vable Control Technology (MACT), and National Emission Standards for Hazardo us Air Pollutants (NESHAP).

EPA BACT standards require the use of a fabric filt er or baghouse. However, District BACT standards are just as stringent and require th e use of natural gas supplemental fuel with a baghouse.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-11 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan How does District Rule 4203 compare to rules in oth er air districts?

Rule 4203 was compared to similar rules at other ai r 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 Liq uid Wastes) and SMAQMD Rule 407 (Open Burn). BAAQMD and VCAPCD do not have com parable rules.

In addition to being one of the most stringent rule s 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 modi fied 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). Addit ionally, all new or modified units are evaluated under the District’s air toxics polic y, 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 th e maximum degree achievable using control technology like baghouses and lime scrubber s. No technologies beyond those

established as BACT were identified.

Risk-based Strategy Analysis The emissions from units subject to Rule 4203 contr ibute 2.3% of average winter NOx emitted from stationary and area sources in the 201 2 emission inventory. As illustrated in the emission inventory table above, the emission s 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 commitmen ts for Rule 4203.

Regulatory Action The District’s analysis did not identify any additi onal 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.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-12 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Technology Advancement Action There is no recommendation for a new technology adv ancement project for units subject to Rule 4203. Through its Technology Advan cement Program, the District will continue to seek potential feasible and low-cost te chnologies 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 combustibl e 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. No new education and outreach efforts ar e recommended for these sources

at this time. The District will continue to work c losely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-13 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.1.2 Rule 4307 Boilers, Steam Generators and Proce ss Heaters–

2.0 MMBtu/hr to 5.0 MMBtu/hr

Source Category This rule applies to any gaseous fuel or liquid fue l 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 p urpose of this rule is to limit emissions of NOx, carbon monoxide (CO), sulfur diox ide (SO2), and particulates from units subject to this rule. Based on District perm its 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 estab lish 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 me nu-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 be ing 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 cat egory.

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 0.08San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-14 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Regulatory Evaluation

How does District Rule 4307 compare with federal ru les and regulations?

Rule 4307 is equivalent to the applicable federal s tandards and guidelines. As confirmed by the June 2009 EPA Technical Support Do cument (TSD) for Rule 4307, the rule is as stringent as the federal Alternative Con trol 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 Emiss ions from Utility Boilers”, dated March 1994), New Source Performance Standards (NSPS ) (40 CFR 60 Subpart D (Standards of Performance for Fossil-Fuel Fired Ste am Generators for Which Construction Commenced After August 17, 1971) and 4 0 CFR 60 Subpart Dc (Standards of Performance for Small Industrial-Comm ercial-Institutional Steam Generating Units)), and Maximum Achievable Control Technology (MACT) (40 CFR 63 Subpart DDDDD (NESHAP for Industrial, Commercial, a nd Institutional Boilers and Process Heaters)). Additionally, there are no EPA Control Technique Guidelines (CTG) or Best Available Control Technology (BACT) require ments listed for this category.

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

In comparison to other California air districts’ ru les for similar sources, Rule 4307 is at least as stringent as the analogous rules for SCAQM D (Rule 1146.1—Emissions of Oxides of Nitrogen from Small Industrial, Instituti onal, and Commercial Boilers, Steam Generators, and Process Heaters), BAAQMD (Regulatio n 9 Rule 7—Nitrogen Oxides and Carbon Monoxide from Industrial, Institutional and Commercial Boilers, Steam Generators and Process Heaters and Regulation 9 Ru le 10—Nitrogen Oxides and Carbon Monoxide from Boilers, Steam Generators and Process Heaters in Petroleum Refineries), SMAQMD (Rule 411—NOx from Boilers, Pro cess Heaters, and Steam Generators), and VCAPCD (Rule 74.15.1—Boilers, Stea m 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-Ex empt Equipment Registration) to ensure compliance with Rule 4307 requirements.

Emission Reduction Opportunities The District has adopted numerous rule amendments o ver the years for boilers that have significantly reduced emissions from units sub ject 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 em issions. The NOx limits implemented through Rule 4307 and its amendments wi ll reduce emissions from over 1,000 small (2-5 MMBtu/hr) boilers in the Valley wh en 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 fr om 3.81 tpd in 2005 to 0.38 tpd inSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-15 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 2012. Additional emissions reductions are forthcom ing with existing Rule 4307 as additional compliance dates are approaching in 2016 . Given the significant efforts and investments already made to reduce emissions from t his source category, there are little remaining opportunities for obtaining additional em issions reductions.

As discussed above, Rule 4307 is as stringent as or more stringent than federal regulations and requirements and other districts’ r ules and regulations. Any new or additional requirements would extend well beyond RA CT requirements.

EMx as Potential Control Post-combustion controls such as EMx, the second ge neration of the SCONOx technology that reduces NOx, SOx, CO, and volatile organic compound (VOC) emissions, were researched. This technology has no t 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 siz e 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 an d other air districts, the SCONOx and EMx systems have only been utilized by power pl ants for the control of turbine emissions. In fact, cost effectiveness analyses co nducted by the District for the installation of SCONOx/EMx units on large power pla nt turbine installations within the San Joaquin Valley have been found to not be cost e ffective. 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 Valle y 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 ga s, and liquid fuel. Units fired on digester gas or produced gas are already required t o 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. W hile 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 measur e 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 unit s 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 op tions for reducing PM emissions: baghouses, electrostatic precipitators (ESPs), and wet scrubbers. Baghouses control total PM and PM2.5 emissions by 90-99%; ESPs contro l total PM and PM2.5 emissions by 90-99%; and wet scrubbers control large particul ates (>PM5) by 99% and PM2.5San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-16 Appendix D: Stationary and Area Source Control Str ategy 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 saf ety issues. 3

PM Potential Emissions Reductions for an ESP and Sc rubber

For the purposes of these calculations, the followi ng assumptions were made:

1. For simplicity, the analysis will evaluate the c ost effectiveness of these technologies for total PM reductions from liquid fu el fired units. 2. The PM control efficiency of an ESP is 99%. 3. The PM control efficiency of a scrubber is 99%.

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

Potential Emissions Reductions ESP = 0.08 tons/year X 0.99

Potential Emissions Reductions ESP = 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 sm 3 /sec at an average air flow rate of 0.7- 47 sm 3 /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 sm 3 /sec). 4. The average air flow rate for a wet scrubber sys tem is assumed to be the median of the range above (23.85 sm 3 /sec).

2 Northeast States for Coordinated Air Use Managemen t. (November 2008) Applicability and Feasibility of NOx, SO2, and PM Emissions Control Technologies for Indu strial, Commercial, and Institutional (ICI) Boilers

. 3 Northeast States for Coordinated Air Use Managemen t. (November 2008) Applicability and Feasibility of NOx, SO2, and PM Emissions Control Technologies for Indu strial, 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 Quali ty 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 Di strict December 20, 2012

D-17 Appendix D: Stationary and Area Source Control Str ategy 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 un its. 7. Lifetime of the ESP is 10 years at 10% interest. To account for this, the annualized capital cost will be calculated by multi plying the total capital cost by the capital recovery factor of 0.1627 and adding th e annual maintenance costs.

Annual Cost ESP = (Total Capital Cost) x (0.1627) + (Annual Mainten ance Cost)

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

Annual Cost ESP = $423,913/year

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

(Average Flow Rate)

Annual Cost scrubber = ($53,650/ sm 3 /sec) x (25) x (23.85 sm 3 /sec)

Annual Cost scrubber = $31,988,813 year

Cost Effectiveness of an ESP and Wet Scrubber

Cost Effectiveness = Annual Cost / Annual Emissions Reductions

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

Cost Effectiveness ESP = $5,365,987/ton of PM

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

Cost Effectiveness scrubber = $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 do es not include costs of retrofitting equipment and/or the facility or compliance monitor ing costs, which would drive the cost effectiveness up even more. In addition, the annua lized costs provided by EPA for the wet scrubber system are in 2002 dollars, which mean s the value above would be even greater if it were adjusted to 2012 dollars.

At this time, the District’s analysis indicates tha t 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 contr ibute 0.7% of average winter NOx, 2.6% of average winter SOx, and 0.6% of average win ter PM2.5 emitted from stationary and area sources in the 2012 emission inventory. T hese units are primarily fired on PUC-quality natural gas, which is generally conside red a clean burning fuel with low SOx and PM emissions. Overall, Rule 4307 has signi ficantly reduced NOx and SOx

emissions from these units and has assisted in redu cing PM2.5 concentrations through reductions of these key precursors.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-18 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Control Measure Commitments The following is a summary of recommended commitmen ts for Rule 4307.

Regulatory Action The District’s analysis did not identify any additi onal 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 th at have been subject to several generations of regulations; as such, the opportunit ies for incentive programs are

minimal. There are no recommendations for incentiv e actions at this time.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for units subject to Rule 4307. Through its Technology Advan cement Program, the District will continue to seek potential feasible and low-cost te chnologies that may provide for additional emission reduction opportunities in this category.

Policy Initiatives The District’s current legislative platform include s 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 al ready 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. The District does not have recommendatio ns for new education and outreach

efforts for these sources. The District will conti nue to work closely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-19 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.1.3 Rule 4308 Boilers, Steam Generators and Proce ss 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, proces s 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 ac hieves reductions as units subject to the rule are replaced over time.

Rule 4308 was adopted on October 20, 2005 to establ ish 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 be ing at least as stringent as established RACT requirements. This rule has resul ted 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 ru les and regulations?

Rule 4308 is equivalent to the applicable federal s tandards and guidelines. As confirmed by the July 2010 EPA technical support do cument (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”, date d March 1994 and EPA – 452/R-93- 008 “Alternative Control Techniques Document—NOx Em issions from Utility Boilers”, dated March 1994). Federal requirements such as Ne w Source Performance Standards (NSPS), National Emission Standards for H azardous Air Pollutants (NESHAP), and Maximum Achievable Control Technology (MACT) requirements are not applicable to boilers, steam generators, and pr ocess heaters of this size. Additionally, there are no EPA Control Techniques G uidelines (CTG) or Best AvailableSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-20 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Control Technology (BACT) requirements listed for t his category. The District, SCAQMD, BAAQMD, and EPA do not employ BACT requirem ents for this source category because BACT is required for new or modifi ed permitted units and these units are exempt from the permitting process.

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

Air districts’ rules that were evaluated as a part of this control measure effort include BAAQMD Regulation 9 Rule 6 (Nitrogen Oxides Emissio ns from Natural Gas-Fired Boilers and Water Heaters), SMAQMD Rule 411 (NOx fr om Boilers, Process Heaters and Steam Generators), SMAQMD Rule 414 (Water Heate rs, Boilers and Process Heaters Rated Less Than 1,000,000 BTU Per Hour), VC APCD Rule 74.11.1 (Large Water Heaters and Small Boilers), and SCAQMD Rule 1 146.2 (Emissions of Oxides of Nitrogen From Large Water Heaters and Small Boilers and Process Heaters).

District Rule 4308 meets RACT standards, which incl udes a comparison to other air district rules, as confirmed by the previously ment ioned 2010 EPA TSD. Rule 4308 was compared to other California air districts’ rules f or similar sources and cross-referenced with the exemptions in each rule. Multiple air dis tricts 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 regu lated, District Rule 4308 requirements are as stringent as the other Districts’ rules.

For example, SCAQMD Rule 1146.2 does not regulate m obile home water heaters, per the definition for type 1 units, because they are s ubject 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. Distri ct 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 SCAQM D 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 ot her 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 Nove mber 7, 2007) also contains a limit of 20 ppmv NOx effective January 2013. Dis trict Rule 4308 contains a limit of 55 ppmv for these same units. Refer to the Instantane ous Water Heaters discussion below

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

D-21 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Emission Reduction Opportunities The adoption of Rule 4308 and its subsequent amendm ent in 2009 have significantly

reduced NOx and PM emissions from boilers of this s ize 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 effective ly reduce emissions from over 17,000 units in the Valley upon full implementation. Addi tional emissions reductions are forthcoming as consumers continue to replace older units with newer and lower-emitting units. Given the significant regulatory efforts al ready 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 r ange of 0.075 – 0.4 MMBtu/hr. For thoroughness, the possibility of further reducing e missions 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 0.4-2.0MM Btu/hr are currently regulated with a NOx emissions limit of 20 ppmv, which is as strin gent as the limit in the other air districts’ rules. As a result, there is no opportu nity to reduce emissions from the larger instantaneous water heaters. However, the emission s limit for instantaneous water heaters 0.075-0.4 MMBtu/hr in Rule 4308 is not equi valent to the other air districts’ rules, which creates a potential opportunity for fu rther 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 R ule 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 p pmv NOx standard for instantaneous units by 2012 6 . Similarly, BAAQMD amended Rule 09-06 in 2007 to incorporate a 20 ppmv NOx limit for instantaneous water heaters afte r 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 inst antaneous unit. Even though

these units were not available at the time of the r ule 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 b eing available by the compliance

deadlines and because the cost differential for a 2 0 ppmv unit would be at most $200.

SCAQMD has obtained information that six manufactur ers now produce instantaneous water heaters in this size range that meet the 20 p pmv 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: Nitro gen Oxides from Natural GasFired Water Heaters . San Francisco, CA: Bay Area Air Quality Managem ent District.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-22 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan sources. Three of the manufacturers distribute the ir units through planning wholesalers who only sell to licensed contractors, with no dire ct retail sales. The fourth manufacturer sells units through online retailers.

After confirming the availability of this technolog y 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 Instanta neous Water Heater NOx

Limit

For purposes of these calculations, the following a ssumptions were made:

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

information. 2. An average rating was applied to the two size ca tegories since the number of units is assumed to be distributed evenly. Therefo re, the average rating is 0.238 MMBtu/hr for units in this size range.

3. The current emissions rate is based on the curre nt rule requirement of 55 ppmv (0.068 lb NOx/MMBtu).

4. Since instantaneous water heaters heat water onl y 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

Emissions 1 = (average rating) x (emission rate) x (capacity f actor) x (hours/day) x (ton/lb)

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

ton/2,000 lb)

Emissions 1 = 5.34 x 10 -6 tons of NOx/day = 0.0019 tons of NOx/year

Potential Emissions at 20 ppmv

Emissions 2 = (average rating) x (emission rate) x (capacity fa ctor) x (hours/day) x (ton/lb)

Emissions 2 = (0.238 MMBtu/hr) x (0.024 lb NOx/MMBtu) x (0.22) x (3 hr/day) x

(1 ton/2,000 lb)

Emissions 2 = 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/yearSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-23 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Cost Effectiveness of Reducing the Instantaneous Wa ter Heater Limit BAAQMD found that water heaters in the size range o f 0.075 through 0.4 MMBtu/hr vary in cost from $2,500 to $10,000 plus installati on. The additional cost for low-NOx water heaters to achieve 20 ppmv was estimated to b e $200 per unit. The following assumptions were made in the cost effectiveness cal culations:

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 r ecovery 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 o f NOx/year) Cost Effectiveness = $27,117/ton of NOx

Although the cost effectiveness for a 20 ppmv insta ntaneous 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 $2 00 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 $2,5 00-$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 l ower 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 t hat could result in gradual emission reductions as existing higher emitting water heater s are replaced by newer low-NOx
models. However, as discussed above, other air dis tricts 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 mob ile home water heaters are not available in the 0.075-2.0 MMBtu/hr size range. Fo ur 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 wa ter 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 exem ption for mobile home water heaters in Rule 4308 were to be removed, it would not result i n any additional emissions

reductions since units do not exist in this size ra nge.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-24 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Recreational Vehicle Exemption The potential opportunity to reduce emissions by re moving the exemption for recreational vehicles (RVs), per EPA’s suggestion i n the 2011 TSD for the approval of the 2009 amendments to this rule, was explored. Wh ile 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) quali ty natural gas. As noted in the 2009 staff report, most units in RVs are 12 gallons, whi ch is smaller than the 80 gallon size of a typical 0.075 MMBtu/hr unit 7 . Also, RV units are typically not used on a frequ ent basis

and thus are small contributors to the NOx emission s of this source category. Air
Districts such as SCAQMD and BAAQMD include this ex emption in their rules. Removing this exemption would result in little to n o emissions reductions because of the lack of availability of these units and the intermi ttent use of units in RVs. Due to the lack of potential emission reductions, there is no recom mendation for amending this rule to remove this exemption.

Risk-based Strategy Analysis The emissions from units subject to Rule 4308 contr ibute 1.4% of average winter NOx, 4.9% of average winter SOx, and 1.1% of average win ter 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 conside red a clean burning fuel with low SOx and PM emissions. Overall, Rule 4308 has signi ficantly reduced NOx and SOx

emissions from these units and has assisted in redu cing PM2.5 concentrations through reductions of these key precursors.

Control Measure Commitments The following is a summary of recommended commitmen ts 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 emission s limit of 20 ppmv are readily available in the Valley at an additional cost of $1 00-$200 per unit. The District recommends amending Rule 4308 to lower the emission s limit of these units from 55 ppmv to 20 ppmv of NOx.

7 Linebach, Katy. (2009). Final Staff Report for Amendments to Rule 4308 (Boi lers, Steam Generators, and Process Heaters—0.075 MMBtu/hr to less than 2.0 MMBtu/hr) . Fresno, CA: San Joaquin Valley Air Pollution Con trol District.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-25 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Incentive Action Boilers, steam generators, and process heaters subj ect to Rule 4308 are regulated units that have already implemented controls to significa ntly 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 adv ancement project for units subject to Rule 4308. Through its Technology Advan cement Program, the District will continue to seek potential feasible and low-cost te chnologies that may provide for additional emission reduction opportunities in this category.

Policy Initiatives The District’s current legislative platform include s support for the increased development and use of cleaner-burning fuels. The recommendation is to continue supporting the current legislative platform but the re 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. The District does not have recommendatio ns for new education and outreach

efforts for these sources. The District will conti nue to work closely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-26 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.1.4 Rule 4309 Dryers, Dehydrators, and Ovens

Source Category Rule 4309 is applicable to any dryer, dehydrator, o r 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 u nits 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 fu el in the burners. The rule enforces NOx emission limits between 3.5-12 ppmv for four ca tegories 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 ru les and regulations?

Rule 4309 is equivalent to the applicable federal s tandards and guidelines. Rule 4309 is as stringent as the federal Alternative Control Techniques (ACT) (EPA –453/R-94-004 “Emissions from Cement Manufacturing”, updated Sept ember 2000), as determined in the 2005 Rule Consistency Analysis for Rule 4309. Federal requirements such as New Source Performance Standards (NSPS), National Emiss ion Standards for Hazardous Air Pollutants (NESHAP), and Maximum Achievable Con trol Technology (MACT) requirements are not applicable to this source cate gory; additionally, there are no EPA Control Techniques Guidelines (CTG) or Best Availab le Control Technology (BACT) requirements listed for this category.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-27 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan How does District Rule 4309 compare to rules in oth er air districts?

When comparing Rule 4309 to other California air di stricts’ 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 Blowi ng) only regulate asphalt plants and Rule 4309 is more stringent than the requiremen ts in all three rules. SMAQMD does not have an analogous rule to Rule 4309.

Rule 4309 was also compared to SCAQMD and BAAQMD BA CT 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 Ut ilities Commission (PUC) quality natural gas fuel was part of the NOx and SOx BACT r equirements 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 cor rection factor of 19% by volume of O2 (19% O2), whereas Rule 4309 has a limi t of 4.3 ppmv for gaseous fuel and 12 ppmv for liquid fuel @ 19% O2. These potent ial opportunities were evaluated

and have been included in a discussion of the feasi bility of both requirements in the Asphalt Plants section of the emission reduction op portunities discussion.

As previously stated, this rule satisfies RACT requ irements; any additional requirements would be more stringent and go beyond RACT. In add ition to being one of the most stringent rules in the nation for this source categ ory, any new unit brought to the Valley, as well as any major modifications to existing unit s, would trigger Best Available Control Technology (BACT) requirements. Subsequently, thes e new or modified units would be required to use technology and control emissions be yond 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 f rom dryers, dehydrators, and ovens has dropped from 1.93 tpd in 2005 to 0.17 tpd in 20 12. Although this source category had a relatively small emissions inventory prior to the adoption of Rule 4309, stakeholders have installed control equipment and m odified their operations considerably to reduce emissions to ultra-low level s. Given the significant effort already made to reduce emissions from this source category, there are little remaining opportunities for obtaining additional emissions re ductions. For the sake of thoroughness, the possibility of further reducing e missions from these units is evaluated in the following discussion.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-28 Appendix D: Stationary and Area Source Control Str ategy 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-qualit y natural gas because some facilities are physically too far removed from natural gas lin es to use natural gas. Nine of these asphalt plants use LPG fuel or propane to comply wi th the same gaseous fuel fired limit as PUC-quality natural gas-fired facilities. The o ther two facilities utilize diesel gas; however, neither facility operates full time and th eir 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 significan t emission reduction benefit.

The potential opportunity for emission reductions b y lowering the emissions limits for asphalt plants from the current NOx limits of 4.3 p pmv (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, o perators would need to install lowNOx burners or modify existing burners to comply wi th lower limits; however, all of the asphalt plants have already installed new low-NOx b urners or modified their units to meet the 4.3 ppmv @ 19% O2 and 12 ppmv @ 19% O2 emi ssions 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% O 2 NOx limit. However, reducing the limit to 3.9 ppmv @ 19% O2 would reduce the mar gin of compliance the facility has, and would make it more difficult for the facility t o show continued compliance. In addition, reducing the limit from 4.3 ppmv to 3.9 p pmv would be an administrative change in nature, since it would not require any ad ditional 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 h ot mix asphalt facilities, there is a clause that states, “For remote locations where natural gas is not avai lable, 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 B ACT guideline.

Dehydrators Rule 4309 requires dehydrators be fired on PUC-qual ity natural gas. The potential opportunity to further reduce emissions by requirin g 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 qualit y. Additionally, enforcing the emissions limits was found to be potentially infeas ible because monitoring and source testing of dehydrators is difficult to perform, if not impossible.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-29 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan In the 2005 staff report for Rule 4309, a cost effe ctiveness 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 rep lacements of all of the burners in the current units with low-NOx burners, but also an add itional 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/to n 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-NO x 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 em issions from handling the products they are drying. These facilities install baghouse s or cyclones because they do not want to blow their product out of their stack. Whi le 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 w as researched. However, it is technologically infeasible to install a baghouse fo r 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. Bagh ouses can have problems with high humidity exhaust streams because the bags become ca ked. 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 re moving the exemption for column dryers and dryers with no stack and one or more sid es open to the atmosphere was also considered. However, as was true during the 2 005 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 w arm 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, wh ich makes monitoring and testing emissions difficult, if not impossible. Since sour ce testing of these types of dryers is

8 Northeast States for Coordinated Air Use Managemen t. (November 2008) Applicability and Feasibility of NOx, SO2, and PM Emissions Control Technologies for Indu strial, Commercial, and Institutional (ICI) Boilers

.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-30 Appendix D: Stationary and Area Source Control Str ategy 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 th is time.

At this time, the District’s analysis indicates tha t 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 contr ibute 3.9% of average winter SOx and 1.2% of average winter PM2.5 emitted from stati onary 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 an d SOx emissions from these units and has assisted in reducing PM2.5 concentrations t hrough reductions of these key

precursors.

Control Measure Commitments The following is a summary of recommended commitmen ts for Rule 4309.

Regulatory Action The District’s analysis did not identify any additi onal 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 adv ancement project for units subject to Rule 4309. Through its Technology Advan cement Program, the District will continue to seek potential feasible and low-cost te chnologies that may provide for additional emission reduction opportunities in this category.

Policy Initiatives The District’s current legislative platform include s support for the increased development and use of cleaner-burning fuels. The recommendation is to continue supporting the current legislative platform but the re are no recommendations for new policy initiatives at this time because the rule al ready requires effective emission control technologies.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-31 Appendix D: Stationary and Area Source Control Str ategy 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new edu cation and outreach efforts for

these sources. The District will continue to work c losely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-32 Appendix D: Stationary and Area Source Control Str ategy 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 fue l fired boiler, steam generator, or process heater with a total rated heat input greate r than 5 million British thermal units per hour (MMBtu/hr). The purpose of Rule 4320 is t o 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 sou rce category. The first District rule for this source category, Rule 4305 (Boilers, Steam Gen erators, and Process Heaters) was adopted on December 16, 1993. Rule 4305 was supers eded 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. Si nce 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 t han 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-l ow NOx burners (ULNBs), thus making the lower limits technologically feasible. However, through the public workshop process and additional research it was also determi ned 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 lim itations. 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 fee s are used by the District to achieve cost effective NOx reductions through District ince ntive programs, the District’s Technology Advancement Program, and other routes. T he previous versions of Rule 4305 and 4306 combined with the implementation of R ule 4320 results in approximately 96% control of NOx emissions from this source categ ory, once all of the compliance deadlines are in effect in 2014. EPA finalized app roval for Rule 4320 on March 25, 2011 and deemed this rule as being at least as stri ngent as established RACT requirements.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-33 Appendix D: Stationary and Area Source Control Str ategy 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 ru les and regulations?

Rule 4320 is equivalent to the applicable federal s tandards and guidelines. Rule 4320 is as stringent as the EPA Best Available Control T echnology (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 Constr uction Commenced After August 17, 1971) and 40 CFR 60 Subpart Dc (Standards of Pe rformance 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)) req uirements. There are no EPA Control Techniques Guidelines (CTGs) for this categ ory.

How does District Rule 4320 compare to rules in oth er air districts?

Rule 4320 was compared to other California air dist ricts’ rules for similar sources and was found to be at least as stringent as the analog ous rules for SCAQMD (Rule 1146— Emissions of Nitrogen from Industrial, Institutiona l, and Commercial Boilers, Steam Generators, and Process Heaters), BAAQMD (Regulatio n 9 Rule 7—Nitrogen Oxides and Carbon Monoxide from Industrial, Institutional and Commercial Boilers, Steam Generators and Process Heaters and Regulation 9 Rul e 10—Nitrogen Oxides and Carbon Monoxide from Boilers, Steam Generators and Process Heaters in Petroleum Refineries), SMAQMD (Rule 411—NOx from Boilers, Pro cess Heaters and Steam Generators), and VCAPCD (Rule 74.15—Boilers, Steam Generators and Process Heaters). Rule 4320 also meets or exceeds the esta blished BACT requirements for

these units at BAAQMD and SCAQMD. Rule 4320 curren tly dictates SJVAPCD BACT requirements for Valley sources.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-34 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Emission Reduction Opportunities Over the years, the District has adopted numerous g enerations 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 em issions 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 Vall ey have been equipped with the best available NOx and PM control technologies. Additio nal emissions reductions are forthcoming with existing Rule 4320 as more complia nce dates approach in the next couple of years. Given the significant effort alre ady made to reduce emissions from this source category, there are little remaining opportu nities for obtaining additional emissions reductions. For thoroughness, the possib ility of further reducing emissions from boilers greater than 5 MMBtu/hr is evaluated i n the following discussion.

Low Temperature Oxidation Emerging technologies that may have the potential t o reduce emissions were researched. A Low Temperature Oxidation (LTO) Syst em 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 databa se information, capital and installation costs ranged from $360,000 - $400,000 for the LTO system when it was

installed in 1997 9 . Installation within the South Coast region was h eavily 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 qual ify 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 rese arched. 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 m anufacturer’s website states that the technology is transferrable to industrial boile rs. 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 t urbine emissions. In fact, cost effectiveness analyses conducted by the District fo r the installation of SCONOx/EMx units on large power plant turbine installations wi thin the San Joaquin Valley have been found to not be cost effective. Given the high cos t effectiveness demonstrated for turbines and lack of demonstrated practice with boi lers, the District does not expect this technology to be feasible or cost effective for red ucing emissions from this category.

9 (2012). SCAQMD Best Available Control Technology (BACT) Dat abase . Diamond Bar, CA: South Coast Air Quality Management District.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-35 Appendix D: Stationary and Area Source Control Str ategy 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 lo w sulfur content and inherently has low emissions. Few boilers in the Valley use alter native 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 r equired to use inlet gas scrubbers to meet District rule requirements. Current rule lang uage requires that liquid fuel shall be used only during a PUC-quality natural gas curtailm ent period provided it contains no more than 15 ppm sulfur. While the use of liquid f uel is strictly limited, the feasibility of reducing PM emissions through adding PM2.5 limits f or units using liquid fuel was explored as part of the District’s comprehensive co ntrol 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 unit s 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 opportuni ties to reduce PM emissions: baghouses, electrostatic precipitators (ESPs), and wet scrubbers. Baghouses control total PM and PM2.5 emissions by 90-99%; ESPs contro l total PM and PM2.5 emissions by 90-99%; and wet scrubbers control large particul ates (>PM5) by 99% and PM2.5 emissions by approximately 50% 10 . Currently, there are a few crude oil-fired or fi eld gas-fired steam generators operating in crude oil p roduction 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 baghouse 11
and are therefore not a recommended technology due to infeasibility and safety issues.

PM Potential Emissions Reductions for an ESP and Sc rubber

For the purposes of these calculations, the followi ng assumptions were made:

1. For simplicity, the analysis will evaluate the c ost effectiveness of these technologies for total PM reductions from liquid fu el fired units. 2. The PM control efficiency of an ESP is 99%. 3. The PM control efficiency of a scrubber is 99%.

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

Potential Emissions Reduction ESP = 0.02 tons/year X 0.99

Potential Emissions Reduction ESP = 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 Managemen t. (November 2008) Applicability and Feasibility of NOx, SO2, and PM Emissions Control Technologies for Indu strial, Commercial, and Institutional (ICI) Boilers

. 11 Northeast States for Coordinated Air Use Managemen t. (November 2008) Applicability and Feasibility of NOx, SO2, and PM Emissions Control Technologies for Indu strial, Commercial, and Institutional (ICI) Boilers

.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-36 Appendix D: Stationary and Area Source Control Str ategy 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 sm 3 /sec at an average air flow rate of 0.7- 47 sm 3 /sec. 13 The following assumptions in the cost

effectiveness calculations:

1. The capital cost of an ESP for a 5 MMBtu/hr boil er is assumed to be $100,000.

2. The annual maintenance cost of an ESP for a 5 MM Btu/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 sm 3 /sec). 4. The average air flow rate for a wet scrubber sys tem is assumed to be the median of the range above (23.85 sm 3 /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 un its. 7. Lifetime of the ESP is 10 years at 10% interest. To account for this, the annualized capital cost will be calculated by multi plying the total capital cost by the capital recovery factor of 0.1627 and adding th e annual maintenance costs.

Annual Cost ESP = (Total Capital Cost) x (0.1627) + (Annual Mainten ance Cost x 62)

Annual Cost ESP = ($100,000 x 62) x (0.1627) + ($2,000 x 62)

Annual Cost ESP = $1,132,740/year

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

(Average Flow Rate)

Annual Cost scrubber = ($53,650/ sm 3 /sec) x (62) x (23.85 sm 3 /sec)

Annual Cost scrubber = $79,332,255 year

Cost Effectiveness of an ESP and Wet Scrubber

Cost Effectiveness = Annual Cost / Annual Emissions Reductions

Cost Effectiveness ESP = ($1,132,740/year) / (0.0198 tons/ year)

Cost Effectiveness ESP = $57,209,091/ton of PM

Cost Effectiveness scrubber = ($79,332,255/year) / (0.0198 tons/ year)

Cost Effectiveness scrubber = $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 Quali ty 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 Di strict December 20, 2012

D-37 Appendix D: Stationary and Area Source Control Str ategy 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 do es not include costs of retrofitting equipment and/or the facility or compliance monitor ing costs, which would drive the cost effectiveness up even more. In addition, the annua lized costs provided by EPA for the wet scrubber system are in 2002 dollars, which mean s 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 contr ibute 3.0% of average winter NOx, 10.3% of average winter SOx, and 2.3% of average wi nter PM2.5 emitted from stationary and area sources in the 2012 emission in ventory

. These units are also fired on PUC-quality natural gas, which is generally cons idered a clean burning fuel with low SOx and PM emissions. Overall, Rule 4320 has signi ficantly reduced NOx and SOx

emissions from these units and has assisted in redu cing PM2.5 concentrations through reductions of these key precursors.

Control Measure Commitments The following is a summary of recommended commitmen ts for Rule 4320.

Regulatory Action The District’s analysis did not identify any additi onal 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 th at have been subject to several generations of regulations; as such, the opportunit ies for incentive programs are

minimal. There are no recommendations for incentiv e actions at this time.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for units subject to Rule 4320. Through its Technology Advan cement Program, the District will continue to seek potential feasible and low-cost te chnologies that may provide for additional emission reduction opportunities in this category.

Policy Initiatives The District’s current legislative platform include s support for the increased development and use of cleaner-burning fuels. The recommendation is to continue supporting the current legislative platform but the re are no recommendations for new policy initiatives at this time because the rule al ready requires the most effective emission control technologies.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-38 Appendix D: Stationary and Area Source Control Str ategy 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. The District does not have recommendatio ns for new education and outreach

efforts for these sources. The District will conti nue to work closely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-39 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.1.6 Rule 4352 Solid Fuel Fired Boilers, Steam Gen erators, 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 re quirements 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 amend ed three times. The recent December 2011 amendments strengthened the rule by l owering NOx emissions limits for all three source categories. However, no emiss ions reductions were quantified because the rule amendments were meant to satisfy E PA RACT requirements and all units were determined to be operating at the propos ed emission limits. EPA finalized approval of Rule 4352 on November 6, 2012 and deeme d 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 bi omass facilities in the Valley is fostering emissions reductions. As an energy sourc e, biomass can either be used directly or converted into other energy products su ch 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 agricultu ral materials, and urban and forest wood waste products by utilizing these materials. To da te, agricultural burning has been reduced by 70% and approximately 90% of agricultura l 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 1.41San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-40 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Regulatory Evaluation

How does District Rule 4352 compare with federal ru les and regulations?

Rule 4352 is equivalent to the applicable federal s tandards and guidelines. Rule 4352 is as stringent as the federal Alternative Control Techniques (ACT) (EPA –453/R-94-022 “Alternative Control Techniques Document – NOx Emis sions from Industrial/Commercial/Institutional Boilers”, dated March 1994 and EPA – 452/R-93-008 “Alternative Control Techniques Document—NOx Emissi ons from Utility Boilers”, dated March 1994), New Source Performance Standards (NSPS ) (40 CFR 60 Subpart D (Standards of Performance for Fossil-Fuel Fired Ste am Generators for Which Construction Commenced After August 17, 1971) and 4 0 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 C ontrol Technology (BACT) standards and it was noted that Selective Catalytic Reduction (SCR) systems, scrubbers, electrostatic precipitators, and baghous es are amongst the technologies considered to be BACT for this source category. Se e the Emission Reduction Opportunities section for a discussion regarding th ese technologies.

How does District Rule 4352 compare to rules in oth er air districts?

Rule 4352 was compared to several other air distric ts’ rules. Per the 2011 Staff Report 14 , it was determined there are currently no solid fu el fired units subject to the NOx emission limits in the following rules in other air districts:

• BAAQMD Regulation 9 Rule 7 (Nitrogen Oxides and Ca rbon Monoxide from Industrial, Institutional and Commercial Boilers, S team Generators and Process Heaters),

• BAAQMD Regulation 9 Rule 11 (Nitrogen Oxides and C arbon Monoxide from Electric Power Generating Steam Boilers),

• VCAPCD Rule 74.15 (Boilers, Steam Generators and P rocess Heaters),

• SCAQMD Rule 1146 (Emissions of Oxides of Nitrogen from Industrial, Institutional, and Commercial Boilers, Steam Genera tors 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 Fue l Fired Boilers, Steam Generators and Process Heaters). Fresno, CA: San Joaquin Valley Air Pollution Control District.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-41 Appendix D: Stationary and Area Source Control Str ategy 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 Equipm ent—Oxides of Nitrogen Emissions),

• VCAPCD Rule 74.15 (Boilers, Steam Generators and P rocess Heaters), and

• SCAQMD Rule 1135 (Emissions of Oxide of Nitrogen f rom Electric Power Generating Systems) exempt sources burning solid fu els.

In addition to being one of the most stringent rule s 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, the se new or modified units would be required to use technology and control emissions be yond 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. Facilitie s subject to this rule have invested millions of dollars to implement innovative control technologies and have significantly

reduced emissions from solid fuel fired boilers. T he increased presence of biomass facilities in the Valley, from either new facilitie s or other solid fuel fired boilers that have converted to biomass, continues to significantly re duce NOx and PM emissions from open burning practices. Given the significant effo rts and investments already made to reduce emissions from this source category, there a re little remaining feasible opportunities for obtaining additional cost effecti ve emissions reductions. For thoroughness, the possibility of further reducing e missions from these units was evaluated and cost effectiveness analyses were stil l performed as part of the District’s comprehensive control measure evaluation.

Selective Catalytic Reduction When comparing Rule 4352 to EPA and other air distr icts’ 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 t hat 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 Effective ness of Solid Fuel Fired

Boilers by Fuel Type Fuel Type Base line

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 59,769San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-42 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan While these calculations were based off of a new in stallation 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 co ntrols for direct PM2.5 emissions, per EPA’s suggestion in the 2009 and 2012 TSD for the r ule, was researched. Three technologies were recognized as being able to poten tially reduce direct PM2.5 emissions: electrostatic precipitators (ESPs), bagh ouses, and cyclones.

An ESP is a particulate collection device that remo ves 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/h r size range of District units 15 . A baghouse, on the other hand, is a technology in whi ch particulates are removed from a stream of exhaust gases as the stream passes throug h a large cloth bag. Baghouses

have a PM2.5 removal effectiveness of 90-99.9% for solid fuel fired boilers in the size range of District units 16 . Coal and coke-fired units generally use baghouse s, but biomass boilers usually use ESPs because of the hea lth and safety risk of the burning embers causing a fire in the baghouse. However, wh en cyclones are combined with the use of a baghouse, the burning embers are extinguis hed and allow for the use of a baghouse in a biomass facility 17 . 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 ins talled either a baghouse or ESP particulate matter removal system due to permitting requirements. Since the control efficiency ranges for both technologies are equival ent, there are currently no other PM controls more effective than current practices.

Controls for SOx Emissions Potential opportunities to reduce SOx emissions fro m this source category were also researched. Most facilities subject to Rule 4352 c urrently inject limestone into the combustion chamber to react with fuel sulfur and pr oduce various sulfate compounds, which can then be removed by the ESP or baghouse. T his control technology typically

achieves around 50% control of SOx emissions 18 ; however, the emissions reduced are

less for a low sulfuric fuel due to the lower conce ntration of sulfur dioxide (SO2) initially in the combustion products.

15 Senior, C., Afonso, R. (January 2009). Applicability and Feasibility of NOx, SO2, and PM E missions Control Technologies for Industrial, Commercial, and Instit utional (ICI) Boilers. Northeast States for Coordinated Air Use Management.

16 Senior, C., Afonso, R. (January 2009). Applicability and Feasibility of NOx, SO2, and PM E missions Control Technologies for Industrial, Commercial, and Instit utional (ICI) Boilers. Northeast States for Coordinated Air Use Management.

17 Roberts, C. (2009). Information on Air Pollution Control Technology fo r Woody Biomass Boilers. Northeast States for Coordinated Air Use Management and the EPA Offi ce of Air Quality Planning and Standards.

18 (2001). Technical Advice on Air Pollution Control Technolog ies for Coal-fired Power Plants . Edmonton, AB: Alberta

Research Council Inc.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-43 Appendix D: Stationary and Area Source Control Str ategy 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 boilers 19 . 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 scru bber 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 annuali zed capital equipment cost is calculated by multiplying the installed equipment c ost by the capital recovery factor of

0.1627.

Annual Capital Costs (AC capital )

AC capital = $5,800,000 X 0.1627

AC capital = $943,660/year

In addition, this system has additional costs for t he sodium hydroxide reagent used in

the scrubber which are estimated to be an additiona l $642,000 per year. Thus, the total

annual cost would be:

Total Annual Costs (AC total )

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

AC total = $1,585,660/year

Cost effectiveness is calculated by dividing the an nual cost by the annual emissions

reductions from District standard emissions. One c ost 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, bas ed 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 y ear is assumed to reflect the time needed for the startup and shutdown period, when th e exhaust temperature is not high enough for controls to be fully effective. Therefo re, 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 E missions Control Technologies for Industrial, Commercial, and Instit utional (ICI) Boilers. Northeast States for Coordinated Air Use Management.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-44 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Annual Standard Emissions (AE standard )

AE standard = [(0.044 lb/MMBtu) x (341 MMBtu/hour) x (8,760 ho ur/year)] + [(0.27

lb/MMBtu) x (24 hour/year) x (341 MMBtu/hr)]

AE standard = 133,644.7 lb/year

Potential emissions, using the technologically feas ible emission limit of 0.012 lb/MMBtu that is achieved by the use of a wet scrubber syste m, can be calculated as follows:

Annual Emissions with Wet Scrubber System (AE scrubber )

AE scrubber = [(0.012 lb/MMBtu) x (341 MMBtu/hour) x (8,760 ho ur/year)] + [(0.27

lb/MMBtu) x (24 hour/year) x (341 MMBtu/hour)]

AE scrubber = 38,055.6 lb/year

Therefore, the cost effectiveness would be:

Cost Effectiveness (CE)

CE= ($1,585,660/year) ÷ [(133,644.7 lb/year – 38,05 5.6 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, additi onal labor costs, additional solid waste disposal, and other operational changes or addition s that would be required to comply with the lower limit. The option of scrubbers is n ot a cost effective option, and therefore,

is not feasible.

There are no additional technologies available to r educe SOx emissions from solid fuel

fired units.

Start-up Periods The possibility of reducing the allowed start-up pe riod of solid fuel fired boilers was considered, since facilities are exempt from emissi ons limits during this period. Facilities subject to Rule 4352 are currently subje ct to a start-up limit of 96 hours. Operators currently limit their start-up an d 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 n ot 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 Di strict December 20, 2012

D-45 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Risk-based Strategy Analysis The emissions from units subject to Rule 4352 contr ibute 9.2% of average winter NOx and 15.3% of average winter SOx emitted from statio nary and area sources in the 2012 emission inventory. Overall, Rule 4352 has signifi cantly reduced NOx and SOx

emissions from these units and has assisted in redu cing PM2.5 concentrations through reductions of these key precursors.

Control Measure Commitments The following is a summary of recommended commitmen ts for Rule 4352.

Regulatory Action The District’s analysis did not identify any additi onal 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 th at have been subject to several generations of regulations; as such, the opportunit ies for incentive programs are minimal. As discussed above, funding or tax credit s aimed at reducing emissions from biomass facilities in the Valley are available thro ugh some short-term programs such as the Existing Renewable Facilities Program through t he California Energy Commission (CEC) and federal corporate tax credits from a fede ral program called the Renewable Electricity Program Tax Credit. Although there ar e 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 techn ology advancement actions to

reduce emissions from solid fuel fired boilers at t his time. Through its Technology Advancement Program, the District will continue to seek potential feasible and low-cost technologies that may provide for additional emissi on reduction opportunities in this
category.

Policy Initiatives The District’s current legislative platform include s support for the continued operation of biomass facilities and increased development and us e of cleaner-burning fuels. The recommendation is to continue supporting the curren t legislative platform but there are no recommendations for new policy initiatives at th is time because the rule already requires the use of effective emission control tech nologies.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-46 Appendix D: Stationary and Area Source Control Str ategy 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new edu cation 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 Di strict December 20, 2012

D-47 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.1.7 Rule 4702 Internal Combustion Engines

Source Category This rule applies to any internal combustion (IC) e ngine rated at 25 brake horsepower (bhp) or greater. The purpose of this rule is to l imit 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 (Interna l Combustion Engines – Phase 1), was adopted on May 21, 1992, superseded by newly adopte d 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-agri cultural 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 appro ximately 84% control of agricultural operations emissions from this source category. Th e most recent rule amendment in August 2011 added reporting and point-of-sale requi rements for engines 25-50 bhp, which were previously unregulated, and implemented more stringent NOx limits for nonagricultural operations spark-ignited engines, furt her reducing emissions from this source category. EPA finalized approval for Rule 4 702 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 ru les and regulations?

Rule 4702 is equivalent to the applicable federal s tandards 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 Engine s”, dated July 1993), New Source Performance Standards (NSPS) (40 CFR 60 Subpart III I (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 (M ACT) NOx limits (40 CFR 63San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-48 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Subpart ZZZZ (NESHAP for Stationary Reciprocating I nternal Combustion Engines)), and EPA Best Available Control Technology (BACT) re quirements. Additionally, there are no EPA Control Techniques Guidelines (CTG) list ed for this category.

How does District Rule 4702 compare to rules in oth er air districts?

Upon comparing Rule 4702 to other California air di stricts’ rules for similar sources, the rule was found to be at least as stringent as the a nalogous rules for BAAQMD (Regulation 9 Rule 8—Nitrogen Oxides and Carbon Mon oxide from Stationary Internal Combustion Engines), SMAQMD (Rule 412—Stationary In ternal Combustion Engines Located at Major Stationary Sources of NOx), and VC APCD (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 Liqu id-Fueled Engines) specifies a NOx limit of 11 ppmv for all units. Due to the l arge 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 standa rd 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 p pmv limit for non-agricultural operations engines fired on landfill gas or digeste r 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 re sult of SCAQMD’s technology assessment confirms that 11 ppmv is achievable. Du ring a 2011 telephone conversation with SCAQMD during the rule developmen t process of Rule 4702, District staff confirmed that the technology assessment woul d not be completed until 2012. Therefore, the District did not propose chan ges 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 i t is technologically and economically feasible to achieve 11 ppmv for that c ategory of non-agricultural units.

In addition to being one of the most stringent rule s in the nation for this source category, any new unit brought to the Valley, except rare ins tances 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 trigge r 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 220 1 (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 emissi ons 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 emissi on reductions from agricultural ICSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-49 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan engines have been achieved through a combination of regulatory efforts and incentive actions, including the replacement of over 2,000 di esel irrigation pumps with electric

motors since 2007. Additional emissions reduction s are forthcoming with the existing Rule 4702 as compliance dates approach over the nex t six years. Given the significant efforts and investments already made to reduce emis sions from this source category, there are little remaining feasible opportunities f or obtaining additional emissions reductions. While no significant additional opport unities have been identified, the District evaluated several potential additional are as 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 inher ently low-emitters of SOx and PM2.5 emissions. Current Rule 4702 contains string ent requirements requiring the combustion of PUC-quality natural gas, or other equ ivalent 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 lim its and Tier 4 engines are required to meet even lower PM limited through the use of parti culate 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 em issions.

Further NOx Limitations With regard to non-agricultural engines, new more s tringent NOx limits were recently adopted in August 2011. The District conducted a t horough analysis in support of this

recent rule amendment that considered all available control technologies, including their feasibility and cost effectiveness. The District s ubsequently adopted stringent limits with compliance dates ranging from 2014 through 2017. B ased 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 esta blished stringent requirements for reducing emissions from PUC-quality natural gas (sp ark-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 ca tegory. Overall, these requirements reduce emissions from agricultural engines by 84% w hen fully implemented, with significant investments being made by the affected stakeholders to comply with the rule. Additionally, the District and United States Depart ment of Agriculture – Natural Resources Conservation Service (USDA-NRCS) have als o 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, agri cultural 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 newSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-50 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan standards or have only recently come into complianc e with the stringent standards under Rule 4702. Compliance dates for agricultural operations engines range from 2009 to 2010 for spark-ignited engines and 2010 thr ough 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 i nstall emission control devices and comply with the current NOx limits in Rule 4702. A s discussed in the 2011 Final Staff Report for the Revised Proposed Amendments to Rule 4702 , the District is still evaluating the effectiveness and implementation iss ues associated with the control systems currently in place for agricultural spark-i gnited 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 unatt ended operations. While the technologies are capable of meeting the 150 ppmv an d 90 ppmv NOx emissions limits currently in place for agricultural spark-ignited e ngines, 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 appr opriate for agricultural spark-ignited engines considering the potential economic impacts that more stringent NOx limits could create for Valley agriculture. Agriculture i s economically depressed as evidenced by continued economic assistance from the federal g overnment in the form of subsidies/grants to even the economic playing field resulting from increased importation of cheaper cost products from foreign countries int o the U.S. Unlike agricultural diesel (compression-ignited) engines, agricultural spark-i gnited 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 lim its for agricultural spark-ignited engines.

Another important consideration is that the NOx lim its in place prevent operators from replacing agricultural spark-ignited engines with d iesel engines. In light of the different requirements, and related compliance costs, for spa rk-ignited engines and diesel engines, the District was made aware during the 200 5 amendment of Rule 4702 that operators would likely replace an agricultural spar k-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 re quirements for spark-ignited engines and compression-ignited engines as comparable as re asonable; as supported by the rule limits and compliance dates. Agricultural spa rk-ignited engines with higher NOx emissions limits have sooner compliance dates (2009 -2010) and agricultural diesel engines with more stringent NOx limits have a longe r compliance timeline (2010-2018). Reducing the spark-ignited NOx emissions limits cou ld potentially prompt agriculturalSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-51 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan operators to switch to diesel engines and thus incr ease PM2.5 emissions for this source
category.

The potential for changing the exemption requiremen ts for emergency standby engines and low-use engines was evaluated during the 2011 r ule amendment process, it was determined that the existing requirements are consi stent with ARB RACT/BARCT Determination for Spark-Ignited Engines and ARB Air borne Toxics Control Measures (ATCM). The emissions from these units are relativ ely minor, and controlling these emissions is subsequently cost ineffective.

The level of stringency associated with existing Ru le 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 poli cy 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 stati onary internal combustion engines...Because the criteria for BACM/BACT are stri cter than for RACT, by meeting BACT requirements submitted Rule 4702 also fulfills RACT.”

21

Given the significant emissions reductions that hav e been achieved and will continue to be achieved under the existing rule, significant co sts associated with these requirements, and the District’s analysis and relat ed EPA findings, there are no feasible opportunities for additional emission reduction reg ulatory strategies for this source
category.

Risk-based Strategy Analysis The emissions from units subject to Rule 4702 contr ibute 18.2% of average winter NOx emitted from stationary and area sources in the 201 2 emission inventory. These units are primarily fired on PUC-quality natural gas, whi ch 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 h ealth risk assessments of these newer diesel engines have concluded that the toxic health risk associated with the new engines are generally not significant. Overall, Ru le 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 Pl an, San Joaquin Valley Air Pollution Control

District and Sacramento Metropolitan Air Quality management Dist rict . 73 Fed. Reg. 7, pp. 1818 – 1822.

21 Donez, F. (August 2007). Technical Support Document for EPA’s Notice of Prop osed Rulemaking and Direct Final Rule for the California State Implementation Plan S an Joaquin Valley Unified Air Pollution Control Dis trict Rule 4702, Internal Combustion Engines – Phase 2 . San Francisco, CA: Environmental Protection Agenc y, Region IX Air

Division.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-52 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Control Measure Commitments The following is a summary of recommended commitmen ts for Rule 4702.

Regulatory Action The District’s analysis did not identify any additi onal 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 continu ing to reduce emissions from these

sources.

Incentive Action As discussed above, the District implements the sta tionary agricultural irrigation pump engine program component of the Heavy-Duty Engine Program . This program provides

incentives for both the conversion of Tier 1 and Ti er 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 p rogram:

• Prior to the January 1, 2015 (or 12 years from ins tallation) Rule 4702 compliance

deadline for the conversion of Tier 1 and Tier 2 en gines to Tier 4 engines, the program will offer incentive funding for the replac ement of Tier 1 and Tier 2 engines with the latest tier certified engine techn ology or electric motors.

• The District will continue to offer incentive fund ing 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 provi ding further incentives to further promote the replacement of agricultural IC engines with ele ctric motors, including, but not limited to providing additional incentives for the high cos t associated with utility line extensions to remote irrigation pump installations.

Technology Advancement Action One of the 11 projects selected in 2011 for the Dis trict’s Technology Advancement Program is aimed at demonstrating that a compact Se lective Catalytic Reduction (SCR) device on a biogas-powered engine can reduce NOx em issions 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 Dis trict will continue to seek potential feasible and low-cost technologies that m ay provide for additional emission reduction opportunities in this category.

Policy Initiatives The District’s current legislative platform include s support for the increased development and use of cleaner-burning fuels, incen tive funding through the Carl Moyer Program, and the continuation of air quality fundin g in the Farm Bill. The DistrictSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-53 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan recommends continued support of these funding strea ms to continue providing incentives for accelerated reductions from engines in this category. The District will also consider pursuing a renewed public/private collabor ative 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. The District does not have recommendatio ns for new education and outreach

efforts for these sources. The District will conti nue to work closely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-54 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.1.8 Rule 4703 Stationary Gas Turbines

Source Category The provisions of this rule are applicable to all s tationary gas turbine systems, which are subject to District permitting requirements, and wi th electrical generation ratings equal to or greater than 0.3 megawatt (MW) or a maximum h eat 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 t o limit NOx emissions from these stationary gas turbines.

Rule 4703 was adopted on August 18, 1994. Since it s adoption, the rule has been

amended six times. The latest rule amendment in Se ptember 2007 strengthened the rule by establishing more stringent NOx limits for existing stationary gas turbines. EPA finalized approval for Rule 4703 on October 21, 200 9 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 ru les and regulations?

Rule 4703 is equivalent to the applicable federal s tandards 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 Subp art GG (Standards of Performance for Stationary Gas Turbines) & Subpart KKKK(Standards of Performance for Stationary Combustion Turbines)), and Maximum A chievable 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 Di strict December 20, 2012

D-55 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan How does District Rule 4703 compare to rules in oth er air districts?

When comparing Rule 4703 to SCAQMD (Rule 1134—Emiss ions of Oxides of Nitrogen from Stationary Gas Turbines), BAAQMD (Regulation 9 Rule 9—Nitrogen Oxides from Stationary Gas Turbines), SMAQMD (Rule 413—Stationa ry Gas Turbines), and VCAPCD (Rule 74.23—Stationary Gas Turbines), the ru le was found to be at least as stringent as these other rules.

In addition to being one of the most stringent rule s 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 (BA CT) requirements. Subsequently, these new or modified units would be required to us e 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 t o the turbine rule that have successfully and significantly reduced emissions fr om 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 emi ssion reductions have been achieved through the implementation of the most stringent re gulations in the nation for this source category and significant investments by stakeholder s to implement effective and innovative emission control technologies. The Dis trict 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 a nd investments already made to reduce emissions from this source category, there a re little remaining feasible opportunities for obtaining additional emissions re ductions. For the sake of thoroughness, the possibility of further reducing e missions 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 str ingent 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 t he 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 installation s 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 h as undergone several generations of NOx limits for existing units in the Valley; facili ties comply with these limits by retrofitting their existing equipment. Requiring the installati on of entirely new turbine systems is extremely expensive and not cost effective, and the refore not required of facilities.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-56 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Selective Catalytic Reduction Many of the larger units (> 3MW) have already emplo yed 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 th e 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 sys tems, they are typically used for controlling emissions from larger units, greater th an 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 th e 2007 Staff Report for Rule 4703 and some of the newer methodologies used to calcula te 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 sy stem.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-57 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 $12 5,000 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 $141,992San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-58 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 $32 5,000 Freight 5% Purchased Equip. Cost (PEC) Rule 4702 $1 6,250 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 $233,994San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-59 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Potential Emissions Reduction Methodology

The estimated current annual NOx emissions and the estimated potential annual NOx emissions were calculated using the following equat ion:

NOx = LF x MMBtu/hr x HR x EF/ 2,000 lb/ton

Where: NOx = Current annual NOx emissions or potential ann ual 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 ca lculated using the following equation:

NOx Emissions Reduction = Current annual NOx emissi ons - 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/to n = 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 - Poten tial NOx emissions = 0.65 tons/yearSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-60 Appendix D: Stationary and Area Source Control Str ategy 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 l imits for units less than 3 MW are more stringent than the current limit of 9 ppmv, th is is not a cost effective option.

EMx Certain BACT limits for simple cycle plants were ac hieved through the use of SCONOx. This multifaceted technology reduces NOx, SOx, carb on monoxide (CO), and volatile organic compound (VOC) emissions and is stated as a chieving NOx levels less than 1.5 ppmv by its manufacturer. One issue with the use o f 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 facili ty 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 be en achieved in practice (AIP) yet in

the District.

BAAQMD evaluated SCONOx, now known as the EMx syste m, for turbines in a recent Final Determination of Compliance (FDOC) for the Oa kley Generating Station. The FDOC states that EMx could potentially be an improv ement over SCR as an add-on control device for achieving NOx reductions – assum ing it can achieve the same level of

NOx control – because it does not use ammonia. Amm onia has the potential, under certain atmospheric conditions, to react with nitri c acid in the atmosphere to form ammonium nitrate, which can be a form of PM2.5. How ever, based on the implementation of EMx at a facility in Shasta Count y, BAAQMD voiced some concerns

for its use.

EMx has never been used on a large utility-scale tu rbine and so there is no data on

which to make a direct evaluation of how well the t echnology would work on larger

turbines. EMx has been used on a smaller aeroderiv itive turbine at the Redding Power Plant Unit No. 5, a 45-MW combined-cycle facility i n Shasta County, CA. The Shasta County Air Quality Management District evaluated EM x at the Redding facility under a demonstration NOx limit of 2.0 ppm, which SCR can c onsistently achieve. After three years of operation, the Shasta County AQMD evaluate d whether the facility was meeting this demonstration limit with EMx, and conc luded that “ Redding Power is not

22 Brian K. Lusher. (June 2010). Final Determination of Compliance: Marsh Landing Ge nerating Station. San Francisco, CA: Bay Area Air Quality Management Dist rict.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-61 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan able to reliably and continuously operate while mai ntaining 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 consi stently the technology would be able to perform. Recent communications between BAA QMD and Shasta County Air

District confirmed that the earlier conclusions abo ut the achievability of a lower limit

remain valid. 24 In addition, monthly reports of Continuous Emissi ons Monitoring System (CEMS) data submitted by Redding Power Plant to Sha sta County Air District during

2007 and 2008 indicated that emissions have often b een substantially higher. 25
Furthermore, the data from Redding is from a smalle r 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 la rger turbines. For these reasons, BAAQMD concluded that EMx is not as developed as SC R at this time and cannot achieve the same level of emissions performance tha t 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 i s 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 potenti ally be beneficial for evaluating the feasibility of EMx applications for turbines in the future.

SOx The implementation of sulfur dioxide (SO2) limits a t least as stringent as the requirements in 40 CFR 60 Subpart KKKK (Standards o f 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 (PU C) quality natural gas. One Valley facility is in the process of installing SCR onto t heir 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 S CR catalyst if not removed. Other landfill and digester-gas turbines outside th e District are also using these
systems.

There are only 5 facilities in the Valley that util ized a fuel other than natural gas for their turbines in 2011. Each of those facilities operate s 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 a re limited to a sulfur content of 0.0016 lb-SO2/MMBtu. PUC-quality natural gas typically ha s 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 Electri c Utility, June 23, 2005.

24 Kathleen Truesdell. (January 2011). Final Determination of Compliance: Oakley Generatin g Station. San Francisco, CA: Bay Area Air Quality Management Dist rict.

25 Kathleen Truesdell. (January 2011). Final Determination of Compliance: Oakley Generatin g Station. San Francisco, CA: Bay Area Air Quality Management Dist rict.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-62 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan SO2/MMBtu and digester turbines are limited to 0.01 6 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 r ule 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. Po st-combustion controls, including baghouses, electrostatic precipitators, and scrubbe rs 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 s ubject to Rule 4703 operated on strictly natural gas, with the exception of 5 facil ities that operated on an alternate fuel part-time in 2011. Based on District Permits recor ds and information in the BAAQMD FDOC for the Oakley Generating Station, electrostat ic precipitators, baghouses, and scrubbers have not been achieved-in-practice for na tural gas-fired turbines. These devices are normally used on solid fuel fired sourc es 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 tu rbine 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 na tural gas-fired gas turbines. 26

Furthermore, these devices would not be technologic ally 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 em issions per unit power produced. Moreover, these devices are designed to be applied to emissions streams with far higher particulate emissions, and they would have v ery 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 woul d 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 technologicall y feasible for units subject to Rule

4703.

26 Kathleen Truesdell. (January 2011). Final Determination of Compliance: Oakley Generatin g Station. San Francisco, CA: Bay Area Air Quality Management Dist rict.

27 Kathleen Truesdell. (January 2011). Final Determination of Compliance: Oakley Generatin g Station. San Francisco, CA: Bay Area Air Quality Management Dist rict.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-63 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan As previously mentioned, SCAQMD is currently fundin g a research project that will study and demonstrate the feasibility of control te chnologies to reduce PM2.5 and ultrafine particulate emissions from natural gas-fi red turbine power plants. Sulfur removal and the EMx multi-pollutant control system are the two technologies which were selected for demonstration. The findings of t his report could potentially be beneficial for evaluating the cost effectiveness an d feasibility of applying these emerging technologies to turbines in future rule-am ending 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 contr ibute 6.6% of average winter NOx, 5.1% of average winter SOx, and 2.8% of average win ter PM2.5 emitted from stationary and area sources in the 2012 emission inventory. T hese units are primarily fired on PUC-quality natural gas, which is generally conside red a clean burning fuel with low SOx and PM emissions. Overall, Rule 4703 has signi ficantly reduced NOx and SOx

emissions from these units and has assisted in redu cing PM2.5 concentrations through reductions of these key precursors.

Control Measure Commitments The following is a summary of recommended commitmen ts for Rule 4703.

Regulatory Action The District’s analysis did not identify any additi onal 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 re gulated units that have been subject to several generations of regulations; as such, the opportunities for incentive programs

are minimal. There are no recommendations for ince ntive actions at this time.

Technology Advancement Action There are no recommendations for a new technology a dvancement project specific to units subject to Rule 4703. Through its Technology Advancement Program, the District will continue to seek potential feasible and low-co st technologies that may provide for additional emission reduction opportunities in this category.

Policy Initiatives The District’s current legislative platform include s support for the increased development and use of cleaner-burning fuels. The recommendation is to continue supporting the current legislative platform but the re are no recommendations for new policy initiatives at this time because the rule al ready requires the use of the most effective emission control technologies.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-64 Appendix D: Stationary and Area Source Control Str ategy 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. The District does not have recommendatio ns for new education and outreach

efforts for these sources. The District will conti nue to work closely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-65 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.2 INDUSTRIAL PROCESSES

The San Joaquin Valley air basin (Valley) is home t o a wide range of industries and industrial processes. The industrial sector is a v ital contributor to the health of the Valley’s economy, and has made important contributi ons to air quality improvement. Whether coming under regulation for the first time or having undergone several generations of retrofit rules, the reductions achie ved represent significant investments of finances and energy.

While the broad category of Industrial Processes in cludes many source categories, for the purposes of this appendix, this discussion is l imited to the reduction of animal matter, flares, lime kilns, activities involving su lfur, 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 append ix.

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 proce ssing, acid plants, oil and gas production, sewage treatment, landfills, incinerato rs, 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 redu ce emissions to meet attainment requirements and protect public health. The Distri ct’s longstanding, progressive strategy for reducing emissions is a multifaceted e ffort that includes incentive programs and policy initiatives in addition to prohibitory r ules. The following discussion summarizes both the existing District efforts to re duce emissions from this source category, and evaluations for potential opportuniti es for further emissions reductions.

Incentive Programs Incentive programs are an integral part of the emis sion reduction efforts of the District, especially where the District lacks direct jurisdic tion in establishing emission control requirements. The emission units within the Indust rial 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 p olicies 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 Valle y’s air quality. The District does notSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-66 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan currently have a portion of the legislative platfor m dedicated specifically to this control
measure source category.

Rules and Regulations The following is a list of rules specific to the In dustrial Processes category. Each of the following rules will be evaluated to examine potent ial 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 12/17/1992San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-67 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.2.1 Rule 4104 Reduction of Animal Matter

Source Category Rule 4104 is applicable to any source operation use d 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 requ ires 100% VOC capture and a high level of destruction (1,200 degree for 0.3 sec onds). 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 ru les and regulations?

No applicable federal standards and guidelines, suc h as Control Techniques Guidelines (CTG), Alternative Control Techniques (ACT), New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollu tants (NESHAP), and Maximum Achievable Control Technology (MACT) requir ements have been identified for this source category.

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

Rule 4104 is as stringent or more stringent than th e following similar regulations in other air districts in California: SCAQMD Rule 472 (Reduc tion of Animal Matter); BAAQMD Regulation 12 Rule 2 (Rendering Plants); SMAQMD Rul e 410 (Reduction of Animal Matter); and VCAPCD Rule 58 (Reduction of Animal Ma tter).

EPA finalized approval for Rule 4104 on March 9, 20 10 and deemed this rule RACT. There are no animal rendering Best Available Contro l Technology (BACT) guidelines that include any additional control technologies.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-68 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Emission Reduction Opportunities Facilities generally use steam from a boiler (indir ect-fired) or a rotary dryer (direct-fired) for their operations; NOx emissions are generated f rom these combustion units. Combustion units are regulated by other District ru les; 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 e mission reduction opportunities. The emission control equipment generally includes a con denser for VOC control, and a venturi scrubber or cyclone, followed by either a p acked bed scrubber or a thermal oxidizer. Blood drying facilities have additional processes controlled by cyclones and a baghouse. For the sake of thoroughness, the Distri ct 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 fa cilities 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 eff icient 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 doe s not cause an increase in

emissions or violate other District rules. It woul d 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 stringen t 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. T he PM control efficiency is nearly the

same for both thermal oxidizers and RTOs and the to tal NOx emissions from this category is relatively small given that there are o nly a few units subject to this rule that are not already subject to other combustion rules l imiting NOx emissions. Any new units would be evaluated through the District’s Bes t Available Control Technology New Source Review requirements.

There are no feasible opportunities for additional emission reduction regulatory strategies for this source category. The District w ill continue to evaluate the potential for

additional emissions reductions from this source ca tegory through future plan development projects.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-69 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 stationar y 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 commitmen ts for Rule 4104.

Regulatory Action The District’s analysis did not identify any additi onal 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 adv ancement project for units subject to Rule 4104. Through its Technology Advan cement Program, the District will continue to seek potential feasible and low-cost te chnologies that may provide for additional emission reduction opportunities in this category.

Policy Initiatives The District does not currently have any policy ini tiatives 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for additio nal education and outreach efforts

for these sources. The District will continue to w ork closely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-70 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.2.2 Rule 4311 Flares

Source Category The purpose of Rule 4311 is to limit volatile organ ic compounds (VOC), NOx, and SOx emissions from any operation involving the use of f lares, with the exception of a few types of sources identified in the rule. Flaring i s a high temperature oxidation process used to burn combustible components, mostly hydroca rbons, 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 dioxid e (CO 2 ) and water. In some waste gases, carbon monoxide (CO) is the major combustibl e component. Flares generate air pollutants such as NOx, sulfur dioxide, carbon mono xide, 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 smok e. Complete combustion requires proper mixing of air and waste gas. There are two general types of flares, open and enclosed flares. Flares are further categ orized 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-a ssisted). 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 eme rgencies. Flare gas volumes can vary from a few cubic meters per hour during regula r operations up to several thousand cubic meters per hour during major upsets.

This rule was originally adopted June 2002 to estab lish flaring requirements and reduce emissions from flares, and has been amended twice s ince then. The most recent amendment was made in September 2009 to incorporate requirements for flare minimization plans and to make existing requirement s for sulfur emissions more stringent. EPA finalized approval for the most rec ent amendments to Rule 4311 on November 3, 2011 and deemed this rule as meeting es tablished RACT standard requirements.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-71 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 ru les 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 – Fla res). There are no applicable Control Techniques Guidelines (CTG), Alternative Co ntrol Techniques (ACT), National Emission Standards for Hazardous Air Pollutants (NE SHAP) or Maximum Achievable Control Technology (MACT) requirements for this sou rce category.

How does District Rule 4311 compare to rules in oth er air districts?

The standards of Rule 4311 were compared to rules f or similar source categories in other air districts in California, and determined t o 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 R efinery Flares); BAAQMD Regulation 12 Rule 11 (Flare Monitoring at Petroleu m Refineries); BAAQMD Regulation 12 Rule 12 (Flares at Petroleum Refineries); and Sa nta Barbara County Air Pollution Control District Rule 4359 (Flares and Thermal Oxid izers). SMAQMD and VCAPCD do not have flare specific prohibitory rules.

Rule 4311 was found to be more stringent than the f lare 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 n ot 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 Distric t 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 minimi zation plans, monitoring, recordkeeping, and reporting requirements, and NOx and VOC emissions standards for ground-level enclosed flares.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-72 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 Implement ation 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 thoro ugh analysis was performed of the recordkeeping and monitoring requirements during th e rule-amending project, as discussed in the final draft staff report for the a dopted rule. Existing recordkeeping and monitoring requirements are appropriate for facilit ies in the Valley to demonstrate compliance with rule requirements. No emission red uctions, or other benefits to air quality, would result from amending the recordkeepi ng 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 separa te 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 bifur cation 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 facil ities subject to flare minimization plans (FMP) to submit annual reports to the Distric t 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 submi tted FMPs will provide an opportunity to evaluate potential emission reductio n opportunities from this category.

Risk-based Strategy Analysis The emissions from units subject to Rule 4311 contr ibute 0.8% of average winter NOx, and 3.0% of average winter SOx emitted from station ary 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 c ategory are well-controlled through existing Rule 4311 requirements.

Control Measure Commitments The following is a summary of recommended commitmen ts for Rule 4311.

Regulatory Action The District’s analysis did not identify any additi onal technologically feasible and cost effective potential controls. Therefore, there are no recommendations for additional regulatory actions for Rule 4311. EPA comments pre sented in the November 2011 TSD regarding additional recordkeeping and monitori ng requirements will be reevaluated as appropriate the next time that Rule 43 11 is amended.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-73 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Further study of the FMPs and annual reportable fla ring event data and the annual monitoring report data to determine if there are an y opportunities to reduce additional emissions from facilities subject to Rule 4311 is r ecommended.

Incentive Action Facilities that use flares are regulated sources th at have been subject to several generations of rules, and Rule 4311 is one of the m ost stringent rules in the nation for flaring activities, which minimizes opportunities f or incentive actions. There are no

recommendations for incentive actions at this time.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for units subject to Rule 4311. Through its Technology Advan cement Program, the District will continue to seek potential feasible and low-cost te chnologies 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 f or these sources.

Education and Outreach The District currently provides a robust education and outreach program for regulated sources through the Small Business Assistance progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. No new education and outreach efforts ar e recommended for these sources

at this time. The District will continue to work c losely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-74 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.2.3 Rule 4313 Lime Kilns

Source Category Rule 4313 limits NOx emissions from the operation o f lime kilns. Lime kilns are used in a variety of manufacturing and processing operation s, including food and agriculture. There are currently no lime kilns currently operati ng in the Valley. There were a total of three lime kilns in the Valley, used at two sugar p rocessing 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 i n 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 Di strict Rules 2201 (New and Modified Stationary Source Review Rule), and 4001 (New Sourc e Performance Standards), among others, and would be required to meet Distric t Best Available Control Technology (BACT) requirements.

Risk-based Strategy Analysis

No health risks are associated with lime kilns in t he Valley.

Control Measure Commitments

There are no recommendations for future control mea sure commitments for Rule 4313.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-75 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### 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 tota l of 13 glass-melting furnaces subject to Rule 4354 in the Valley. Industrial glass makin g 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 mak ing glass are silica sand and soda ash. Melting these basic materials and forming the m 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 be en subsequently amended six times. This rule is one of the most stringent rule s of its kind in the nation, and is successful in limiting NOx, SOx, volatile organic c ompounds (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 imple ment updated start-up requirements; EPA proposed approval of these amendm ents on November 5, 2012. As a result of this stringent prohibitory rule and con tinuing efforts on behalf of this industry to reduce emissions, the Valley is home to glass-makin g facilities with glass melting furnaces that utilize the most advanced low-NOx firing techn ology.

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 ru les and regulations?

This rule is more stringent than federal rules and regulations. This rule was compared to the following federal rules and regulations: fed eral Alternative Control Techniques (ACT) (EPA-435/R-94-037 – Alternative Control Techn iques Document – NOx Emissions from Glass Manufacturing); the one Nation al Emission Standard for Hazardous Air Pollutants (NESHAP) that is applicabl e to glass melting furnaces (40San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-76 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan CFR 61 Subpart N (National Emission Standard for In organic Arsenic Emissions from Glass Manufacturing Plants); the following two Maxi mum Achievable Control Technology (MACT) standards, 40 CFR 63 Subpart NNN (National Emission Standards for Hazardous Air Pollutants for Wool Fiberglass Ma nufacturing Plants), and 40 CFR 63 Subpart SSSSSS (National Emission Standards for Haz ardous Air Pollutants for Glass Manufacturing Area Sources). There is no Control T echniques Guidelines (CTG) for this source category.

How does District Rule 4354 compare to rules in oth er air districts?

The emission limits of Rule 4354 depend on the type of glass produced, furnace firing technology and the emission-averaging period. Eval uation 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 eva luated 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 prohibitor y 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 S CR 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 d epending on cullet content to the District Best Available Control Technology (BACT) l imit 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 Sta te 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 Cal ifornia’s recycling goals. Due to the variable quality of mixed color cullet, SOx emissio ns 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 acros s furnaces, EPA requires that there be a 10% air quality benefit, meaning that th e 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 t o 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 p roduced if the operator uses at leastSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-77 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 th e 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 additi onal EPA required 10% air quality

benefit.

At this time, the District’s analysis indicates tha t 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 contr ibute12.6% of average winter NOx, and 22.5% of average winter SOx emitted from statio nary 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 e missions 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 commitmen ts for Rule 4354.

Regulatory Action The District’s analysis did not identify any additi onal 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 emissio ns beyond that already required in the rule and achieved by facilities; therefore, the re are no recommendations for incentive actions for glass melting furnaces.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for units subject to Rule 4354. Through its Technology Advan cement Program, the District will continue to seek potential feasible and low-cost te chnologies that may provide for additional emission reduction opportunities in this category.

Policy Initiatives The District does not currently support any legisla tive activities specific to glass melting operations; there are no recommendations for new po licy initiatives at this time.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-78 Appendix D: Stationary and Area Source Control Str ategy 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. The District does not have recommendatio ns for new education and outreach

efforts for these sources. The District will conti nue to work closely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-79 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### 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 be fore August 17, 1971. The rule was adopted on May 21, 1992 and applies to only one fac ility 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 prod uced.

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 ru les and regulations?

The rule reflects conformance with 40 CFR Part 60.3 0d Subpart Cd—Emissions Guidelines and Compliance Times for Sulfuric Acid P roduction 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 pound s per ton of acid produced for sulfuric acid production plants operating before August 17, 1971.

There is one sulfuric acid plant in the Valley; thi s plant has been in operation since before August 17, 1971, and it is subject to the re quirements of District Rule 4802. 40 CFR Part 60.30d Subpart Cd—Emissions Guidelines and Compliance Times for Sulfuric

Acid Production Units establishes emission limits f or such sulfuric acid plants. 40 CFR Part 60.80 Subpart H—Standards of Performance for S ulfuric Acid Plants, sets emission limits for sulfuric acid plants constructe d or modified after August 17, 1971. There are no other federal guidelines, including Co ntrol Techniques Guidelines (CTG), Alternative Control Technology (ACT), Maximum Achie vable Control Technology (MACT), and National Emission Standards for Hazardo us Air Pollutants (NESHAP), that apply to the control of sulfuric acid mist. The Bes t Available Control Technology (BACT)

28 (1999, June 8). Approval and Promulgation of Implementation Plans; California State Implementation Plan Revision, South Coast Air Quality Management Distri ct, San Joaquin Valley Unified Air Pollution Contro l 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)San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-80 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan determination for controlling sulfuric acid mist in volves the use of candle filters (fiber bed mist eliminators), which reduce emissions to 0.10 p ounds per ton of 100% sulfuric acid when measured as a three-hour average.

How does District Rule 4802 compare to rules in oth er air districts?

BAAQMD Regulation 9, Rule 1 (Sulfur Dioxide), regul ates 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 ac id plant effluent process gas containing sulfur dioxide in excess of 300 ppm by v olume calculated at 12% oxygen. BAAQMD’s Regulation 12, Rule 6 (Acid Mist from Sulf uric Acid Plants) requires that an operator not emit from a sulfuric acid production u nit 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 V CAPCD regulate sulfuric acid mist through their new source review process, but d o not have specific sulfuric acid mist

rules.

Emission Reduction Opportunities Only one facility in the Valley—a sulfuric acid pla nt—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 f acility uses a mist eliminator to remove fine particles from the acid gas stream, whi ch 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 w ould be subject to Rule 2201 (New and Modified Stationary Source Review Rule) and would b e required to implement BACT

level controls.

An identified potential opportunity to reduce emiss ions 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 B ACT determination. Source tests conducted in 2010 and 2011 at the single facility p ermitted under Rule 4802, showed an actual sulfuric acid mist emission rate of 0.09 pou nd per ton using existing technology. Hence, the facility is meeting the current national BACT standard with the most advanced technology currently available and enforce d through existing permit requirements, despite the fact that their current p ermit and Rule 4802 do not set that requirement. Therefore, the District has determine d 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 emissi on inventory. As demonstrated in the emission inventory table above, these emissions are consistent throughout the year

with no elevated emission levels in winter months.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-81 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Control Measure Commitments The following is a summary of recommended commitmen ts for Rule 4802.

Regulatory Action The District’s analysis did not identify any additi onal 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 re gulated source that has been subject to this rule since 1992 and no new technologies wer e identified to further reduce

emissions. There are no recommendations for incent ive actions at this time.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for units subject to Rule 4802. Through its Technology Advan cement Program, the District will continue to seek potential feasible and low-cost te chnologies 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. No new education and outreach efforts ar e recommended for these sources

at this time. The District will continue to work c losely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-82 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.3 MANAGED BURNING

Managed burning is the controlled burning of materi als. 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 wildlan d/urban interface, and land management agencies operating on the San Joaquin Va lley floor and within the

National Parks and Forests.

For many years, the District managed the smoke impa cts from the open burning of agricultural materials through a system of county-w ide burn/no burn days. In 2004, the District established the Smoke Management System (S MS), 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 agri cultural burning. Properly managed burning allocations under the existing District SMS ensures that air quality and health impacts of open burning of agricultural materials a re 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 occ ur. The implementation of the District’s SMS, District Rule 4103 (Open Burning), and the use of sustainable agricultural practices have reduced the amount of m aterials being burned, thus resulting

in reduced PM2.5 emissions.

Until recently, Land Management Agencies (LMAs) ope rated under a policy where naturally ignited wildfires (i.e. lightning strikes ) were viewed as unhealthy and destructive for the ecosystem, and therefore were a ctively suppressed upon discovery. As this policy continued through the decades, the a mount of fuel (dead plant materials, etc.) in the Sierra Nevada Mountains grew, which in creased 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 fue ls on the forest floors to give space and a chance for new trees to grow, thus ensuring t he health and continuity of the ecosystem. To achieve this, LMAs within the Valley currently conduct prescribed burning to reduce fuels in areas that are determine d to be overgrown. Through these efforts, LMAs are able to burn on days when it is f avorable from both meteorological and air quality considerations. Through District R ule 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 disp ersion is favorable, thus reducing the chance for high concentrations of smoke to occu r in nearby communities.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-83 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Similarly, hazard reduction burning occurs in commu nities that are within the wildland/urban interface, where homes and businesse s in the foothills are often surrounded by dry brush. This fuel must be dispose d 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 fo rm of burning, and as with prescribed burning, this is only allowed if the District forec asts 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 redu ce emissions to meet attainment requirements and protect public health. The Distri ct’s longstanding, progressive strategy for reducing emissions is a multifaceted e ffort that includes incentive programs and policy initiatives in addition to prohibitory r ules. The following discussion summarizes both the existing District efforts to re duce emissions from this source category, and evaluations for potential opportuniti es for further emissions reductions.

Incentive Programs Incentive programs are an integral part of the emis sion reduction efforts of the District, especially where the District lacks direct jurisdic tion in establishing emission control requirements. The District is not currently implem enting any incentive programs specific to this category. However, the District is activel y seeking technology advancement projects to further develop low-emissions options f or the handling of the wide variety of organic materials in the Valley.

Policy Initiatives Similar to the Incentive Programs, the District’s p olicies 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 Valle y’s air quality. The District’s legislative platform currently includes the followi ng items that are applicable to managed burning categories.

The biomass industry utilizes agricultural material s that would otherwise be burned using open burning methods. To maintain the viabil ity of biomass power-generating plants, the District supports legislation that woul d provide for the continued operation of strategically located biomass facilities to provide disposal options for agricultural, urban, and forest wood materials. Subsidies and/or prefer ential utility rates for power produced

from biomass can serve as measures to enhance the e conomic 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 supportsSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-84 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan policies and initiatives that would encourage rapid disposal of the fuel supply, including the following:

• Additional financial and staffing resources for pu blic 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 environmenta l protection policies that prohibit the use of mechanized methods, or prescrib ed burning to reduce fuels when those are the only feasible methods available.

• Changes in the federal policies that better incorp orate air quality concerns by shifting focus to prescribed burning and employing fire management techniques that reduce air quality impacts when wildfires occu r.

Rules and Regulations The following is a list of rules specific to the Ma naged Burning category. Each of the following rules will be evaluated to examine potent ial 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 06/21/2001San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-85 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.3.1 Rule 4103 Open Burning

Source Category This source category includes the open burning of m aterials such as agricultural materials, diseased materials, and contraband mater ials, as well as fires set for fire department training purposes. Rule 4103 was origin ally adopted on June 18, 1992 and it has since been amended several times to incorpor ate state law requirements. The provisions of Rule 4103 apply to open burning condu cted in the Valley, with the exception of prescribed burning and hazard reductio n burning, as defined in Rule 4106 (Prescribed Burning and Hazard Reduction Burning).

Rule 4103 and the District’s Smoke Management Syste m (SMS) have reduced the total acreage of agricultural materials burned in the Val ley by 80% since 2002. California Senate Bill (SB) 705 (2003, Florez; California Heal th and Safety Code Section (CH&SC) 41855.5 and 41855.6) established a schedule for spe cific types of agricultural materials to no longer be burned, but allowed some postponeme nt of the phase-out where justified by technical and economic impediments. I n an effort to implement SB 705 and enhance the procedures for open burn requests, in 2 004 the District established the SMS, a more refined method of authorizing or prohib iting individual burns, based on modeled smoke impacts. Under the SMS, agricultural burning is prohibited on days

when an exceedance of a federal standard is forecas t to occur.

In 2010, the District evaluated each crop category identified in CH&SC Section 41855.5 to determine any technologically and economically f easible alternatives to open burning. After working extensively with stakeholders to unde rstand viable alternatives to burning and associated costs, the District provided recomme ndations for allowing or prohibiting the open burning of agricultural material categorie s 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 requirement s and require the District to review its determinations for any postponed crops and mate rials 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 ca tegories are still valid and submitted a report of those findings to ARB, of whi ch they concurred.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-86 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 ru les and regulations?

There are no specific federal guidelines for Open B urning in terms of New Source Performance Standards (NSPS), Control Techniques Gu idelines (CTG), Maximum Achievable Control Technology (MACT) and National E mission Standards for Hazardous Air Pollutants (NESHAP).

How does District Rule 4103 compare to rules in oth er 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 resou rces dedicated to implementing the District’s smoke management program. Under Rule 41 03 and the SMS, potential burning is evaluated and authorized only when the b urning will not cause a significant impact on air quality.

The analogous rules of other California air distric ts 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 B urning).

Emission Reduction Opportunities The District evaluated the feasibility and cost eff ectiveness of alternatives to burning in

the 2010 Final Staff Report and Recommendations for Agr icultural Burning

( 2010 Report ). The District determined, and ARB concurred, tha t there were no economically feasible alternatives to open burning of certain cr op categories as outlined in the 2010 Report; this conclusion was reaffirmed in the 2012 Update: Recommendations on Agricultural Burning

( 2012 Report

).San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-87 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Citrus Orchard Removal Threshold

The District has determined that citrus orchard rem ovals less than 3,500 acres, under

certain circumstances should still be allowed to bu rn when no other cost effective and

feasible alternatives are available based on factor s identified and discussed in length in

the 2010 and 2012 Reports . For the largest citrus growers (>3,500 acres), t he District determined that it is economically feasible to send citrus orchard removal matter to biomass plants, as described in June 27, 2011 and O ctober 12, 2012 letters to EPA that provided further clarification on this issue. Ther efore, 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 provid e a steady demand for chippers, the availability of chipping equipment, and the current ly reduced supply of urban wood materials as fuel for biomass plants due to the eco nomic downturn.

Open Burning Burning of citrus orchard removal materials (less t han 3,500 acres) is not automatically allowed, rather, each request to burn citrus orchar d removals is evaluated on a case-bycase basis under the District’s agricultural burn p ermit program, which does not allow burning if it will cause or contribute to the excee dance 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 o pen burning of these materials based on the availability of sufficient biomass capacity and economically feasible chipping services. As of July 2011, the prohibition thresho ld is established as citrus farms with a combined acreage of 3,500 acres or greater. Consis tent with this criteria, any request (beyond the 15 acre allowance provided for all citr us orchard removals) from citrus farms to open burn orchard removals are evaluated o n a case-by-case basis.

The following is a summary of the analysis the Dist rict 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 remo val material is to chip the material and send it to biomass plant. Biomass plant capaci ty and the availability of economically feasible chipping services were evalua ted in order to determine the feasibility of this alternative to open burning cit rus 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 r equired to make the citrus chips acceptable as fuel, especially once the economy imp roves and construction material is

more abundant.

• Chipping. The adobe soil in which citrus crops are usually gr own 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 co sts associated with chipping

citrus material.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-88 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan • Biomass. Biomass facilities have a limited capacity for citr us orchard removals due to the composition of the citrus materials as discu ssed in detail in the 2010 Report

. In addition, ground citrus wood produces stringy ma terial and takes longer to dry out enough to burn properly. As a result, biomass faci lities which do accept citrus material will blend up to 30% of citrus material wi th 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 acce pt 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 biom ass fuel consumption or storage capacity from the addit ion of new/converted facilities.

Previously, monetary incentives have also been prov ided 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 progra m 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 d iscontinued in 2012, making it more cost prohibitive to completely prohibit open b urning. Therefore, there are currently no long-term federal or state funding commitments f or 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 fe asible. Therefore, there are no additional identified opportunities for emissions r eductions from this source category at this time. This category will be re-evaluated in 2 015 as committed to in the 2010 Rule

4103 amendment.

Risk-based Strategy Analysis The emissions from this source category contribute1 0.0% of average winter NOx, and 12.2% of average winter PM2.5 emitted from stationa ry and area sources in the 2012 emission inventory. District regulatory efforts ha ve fostered significant reductions in emission from this source category. Although winte r emissions are slightly elevated compared to summer emission levels, the District’s Smoke Management System (SMS) prohibits agricultural burning on days when an exce edance of federal standards is forecast to occur, thus reducing potential public h ealth impacts from this source
category.

Control Measure Commitments The following is a summary of recommended commitmen ts for Rule 4103.

Regulatory Action The District’s analysis did not identify any additi onal technologically feasible and cost effective potential controls. Therefore, there are no recommendations for additional regulatory actions for Rule 4103. The District car efully 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.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-89 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Incentive Action Over the past ten years, the Natural Resources Cons ervation Service (NRCS) has encouraged growers to chip or shred prunings from a lmond and walnut orchards by providing a cost-share basis through the Environmen tal Quality Incentives Program. According to conversations with NRCS staff, the pro gram 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 emissi ons 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 a nd not yet commercially available.

There is no recommendation for a new technology adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat may provide for additional emission reduction opportunities in this category.

Policy Initiatives The District currently supports legislation that wo uld provide for the continued operation of strategically located biomass facilities to prov ide disposal options for agricultural, urban, and forest wood waste. Subsidies and/or pre ferential utility rates for power produced from biomass can serve as measures to enha nce the economic feasibility of

this alternative. The recommendation is to continu e supporting the current legislative platform but there are no recommendations for new p olicy 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for additio nal education and outreach efforts

for Rule 4103 at this time. The District will cont inue to work closely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-90 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.3.2 Rule 4106 Prescribed Burning and Hazard Reduc tion Burning

Source Category This source category includes all prescribed burnin g within the District. It also includes hazard reduction burning in the wildland/urban inte rface. 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 i mportance of both prescribed burning and hazard reduction burning, but rather the adopti on 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 ens ure that the ignition of burn projects is only allowed when air quality and dispersion con ditions are favorable, thus lessening the health impacts on Valley citizens and on air qu ality in the Valley.

EPA finalized approval for Rule 4106 on February 27 , 2002. Rule 4106 was evaluated in the RACT State Implementation Plan (SIP) demonst ration, however the Technical Support Document (TSD) states the rule is not subje ct 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 ru les and regulations?

There is currently no federal guidance given for th is source category under the federal Alternative Control Techniques (ACT), New Source Pe rformance Standards (NSPS),

National Emission Standards for Hazardous Air Pollu tants (NESHAP), Maximum Achievable Control Technology (MACT), and Control T echniques Guidelines (CTG).

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

Upon comparing Rule 4106 to other California air di stricts’ 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 (Op en Burning), and Placer CountySan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-91 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan APCD Rule 301 (Nonagricultural Burning Smoke Manage ment) and Rule 303 (Prescribed Burning Smoke Management).

Prescribed Burning Emission Reduction Opportunities Land Management Agencies (LMAs) are the agencies th at regularly conduct prescribed burning operations. Since the adoption of Rule 410 6, the District has developed cooperative relationships with the LMAs. Through t his cooperation, the District advises the LMA on which days would be the most conducive f or 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 minimiz ing air quality impacts. This collaborative effort ensures that the ignition of b urn 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 fire box air curtain burners and increased

communication between the District and LMAs in mana ging wild fires.

Firebox Air Curtain Burners As opposed to burning, a LMA may be able to mechani cally remove material from the project site. This could achieve a significant red uction 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 L MA to reduce the fuels in an area as compared to burning, and is not physically possi ble 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 mate rial was placed in piles and prepared for burning, an alternative to open burning would b e to use a firebox air curtain burner.

A firebox air curtain burner is a device that circu lates 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 P M 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 $23 8,182 per ton of NOx. This

alternative is not cost effective and therefore not feasible.

Wild Fires Often, primarily during the warm summer months, wil dfires are naturally ignited through lightning strikes from passing storms. These wildf ires have the potential to produce significant emissions and heavily impact residents within the Valley. When these wildfires occur, the District works with the respon sible LMA in managing the fire as the dispersion and air quality conditions fluctuate. T his cooperation allows the LMA to be more aggressive with the fire when meteorological c onditions are favorable and more defensive when the conditions are poor. The Distri ct will continue to use the tools available to guide the activities of LMAs when wild fires 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 res idents.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-92 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Hazard Reduction Burning Emission Reduction Opportu nities

Section 4291 of the California Public Resources Cod e 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, beca use it’s less expensive, faster, and more convenient than other options. Potential oppo rtunities evaluated in this plan development process included the reorganization of hazard reduction zones, and the feasibility of alternatives to burning the vegetati on.

Reorganization of Hazard Reduction Zones The possibility of reducing emissions by reorganizi ng the currently established hazard reduction zones is examined in the following discus sion. 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. Managi ng the allowance of hazard reduction burning under this type of scheme also ha s the potential to limit smoke impacts on residents. Establishing this type of ma nagement system would not cause an increase in costs for landowners, making this a cos t effective opportunity. However, emissions reduced would be minimal, since the burni ng would still occur, just on different days when conditions are favorable.

Alternatives to Burning As an alternative to the open burning of the vegeta tion, the District could encourage alternative methods like chipping or burn boxes thr ough 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 al ternatives below may be successful, the reductions in the inventory will be minimal.

Chipping As previously mentioned, one alternative to the ope n burning of material is to use a chipper to break down the material into small piece s suitable for landscaping, dust control cover, or biomass burning. Further evaluat ion 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; therefo re, the types of materials to be cleared and disposed of are leaves, pine needles, w eeds, and some small brush, all of which are not considered acceptable materials for w ood chippers. The amount of useable material produced from this type of chippin g would be negligible at best.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-93 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Firebox Air Curtain Burners Another potential opportunity examined is the feasi bility 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 co st 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 ha zard reduction burning by removing the biomass from the area and sending it for combus tion at a biomass plant, similar to a program implemented by the Placer County Air Pollut ion Control District (Placer) was evaluated. Placer implemented a “Biomass Box” prog ram beginning in the spring of

2007 to collect and utilize biomass that would trad itionally be collected and burned as a part of hazard reduction efforts, for use as fuel f or producing energy. The program collected the biomass by distributing 20’ to 40’ in dustrial containers throughout participating communities in the county. When full , the containers were transported to another location where the materials were grinded i nto useable fuel that biomass energy companies accept. The chipped biomass was t hen 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 assert ion that this is a highly successful program and a similar program could benefit the Val ley. However, the Valley faces several challenges in implementing such a program d ue to our unique geography. The Valley is considerably larger than Placer County wi th the Sierra Nevada mountain range stretching the length of the Valley. This poses tw o unique challenges to the feasibility of this program; the first being the challenge of dist ributing the boxes and the quantity of boxes needed to be effective, and the second challe nge 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 ma terials to a biomass power plant would be significantly more than Placer, which brings int o issue the increased truck emissions. Additionally, as stated before, the annual emission s 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.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-94 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 201 2 emission inventory. Because of the nature of the source of these emissions, the em issions are primarily a summer issue, as illustrated in the emission inventory tab le above. This source category does not significantly contribute to winter time PM2.5 c oncentrations; 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 haza rd reduction burning mitigate the impact that a wildfire can have on the landscape, t hus reducing the public’s potential exposure to smoke. Continued support and managemen t of this source category will ensure an improvement in both the health of the pub lic and the ecosystems of the parks and forests within the San Joaquin Valley.

Control Measure Commitments The following is a summary of recommended commitmen ts for Rule 4106.

Regulatory Action The District’s analysis did not identify any additi onal 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 recommen dations for new incentive actions for this source category at this time.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat may provide for additional emission reduction opportunities in this category.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-95 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 encour age rapid disposal of the fuel supply, including the following:

• Additional financial and staffing resources for pu blic 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 environmenta l protection policies that prohibit the use of mechanized methods, or prescrib ed burning to reduce fuels when those are the only feasible methods available.

• Changes in the federal policies that better incorp orate 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 i nitiatives, the recommendation is to continue supporting the policies and initiatives id entified above.

Education and Outreach The District currently provides a robust education and outreach program for regulated sources through the Small Business Assistance progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. No new education and outreach efforts ar e recommended for these sources

at this time. The District will continue to work c losely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-96 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.4 AGRICULTURAL PROCESSES

For many years, the Valley’s agricultural community has employed sound conservation management practices to safeguard the natural resou rces of the land. However, prior to 2004, agricultural operations were exempt from a ir permitting requirements in California. Agricultural processors were regulated as permitted sources; and regulation of agricultural emissions was limited to Title 13 r estrictions on open burning. Particulate emissions for unpaved roads and storage piles were regulated through Regulation VIII, but only where the extent of these emissions exceed ed threshold exemption values.

In September 2003, Governor Gray Davis signed Senat e Bill 700 (2003) which amended air pollution control requirements in the C alifornia Health and Safety Code to include requirements for agricultural sources of ai r pollution. Since then, the District has implemented a series of stringent regulatory change s that added more oversight to agricultural operations and set new emission contro l goals. The agricultural sector has responded with significant investments in new emiss ion control programs, and considerable changes to their longstanding practice s. Collectively, the mitigation measures implemented have met or exceeded desired P M10 and VOC emissions reductions. The agricultural community has also re placed thousands of old, highemitting diesel irrigation engines with cleaner, mo re efficient engines and electric motors with the assistance of District grant programs.

This control measure source category includes in-fi eld food and agriculture production, and food and agriculture product processing. For t he discussions about engines or other combustion devices used at these sources, ref er 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 redu ce emissions to meet attainment requirements and protect public health. The Distri ct’s longstanding, progressive strategy for reducing emissions is a multifaceted e ffort that includes incentive programs and policy initiatives in addition to prohibitory r ules. The following discussion summarizes both the existing District efforts to re duce emissions from this source category, and evaluations for potential opportuniti es for further emissions reductions.

Incentive Programs Incentive programs are an integral part of the emis sion reduction efforts of the District, especially where the District lacks direct jurisdic tion in establishing emission control requirements. The District is currently funding on e incentive program that is specific to engines used in the agricultural sector. The stati onary agricultural irrigation pump engine program component of the District’s Heavy-Duty Engine Program was created to assist agricultural stakeholders in replacing old p olluting internal combustion engines with new more efficient and less polluting units or with electric units with zero emissions.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-97 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan For more information about this incentive program p lease refer to the Combustion Devices control measure source category discussion of this appendix.

In addition to District incentive programs, there a re federal funding opportunities offered by various organizations including the Natural Reso urces Conservation Service (NRCS) and EPA. The Environmental Quality Incentives Prog ram through NRCS for example, provides financial assistance to help plan and impl ement conservation practices specifically to help operators meet environmental r egulations. The variety of programs that provide funding to agricultural operations hav e resulted in significant emissions reductions for the agricultural sector.

Policy Initiatives Similar to the Incentive programs, the District’s p olicies 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 Valle y’s air quality.

The District encourages federal support for the con tinuation of air quality funding in the Farm Bill that is designed to accelerate the replac ement of agricultural equipment. As part of the efforts to attain federal air quality s tandards in the Valley, the California Air Resources Board (ARB) committed to reducing emissio ns from in-use agricultural equipment to achieve five to ten tons per day of NO x reductions in the Valley by 2017. This measure would accelerate fleet turnover of equ ipment 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 Natu ral Resource Conservation Service (NRCS) Conservation Innovation Grants program. Thes e programs combined are on track to achieve the five to ten tons per day of NO x reductions by 2017.

The District supports efforts to secure federal fun ds and other mechanisms to achieve near-term reductions from agricultural equipment th at can be credited to the SIP. Towards that end, the District supports the inclusi on of continued air quality funding through the United States Department of Agriculture (USDA) in the Farm Bill, including funding to reduce emissions from agricultural equip ment.

Adoption of Senate Bill 705, which phases out the a bility to burn certain agricultural material in the field, has underlined the importanc e 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 agricul tural burning, including subsidies and/or preferential utility rates for power produced from biomass and additional research to identify other technologically and economically fea sible alternatives. The legislative platform also supports energy efficiency/alternativ e energy policies and initiatives that

will result in emissions reductions and cost effect ive alternatives to burning agricultural

waste.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-98 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Rules and Regulations The following is a list of rules specific to the Ag ricultural Processes category. Each of the following rules will be evaluated to examine po tential opportunities for additional

emissions reductions. Refer to other sections of t his appendix for discussions on other rules that may be applicable to the agricultural co mmunity, 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 08/19/2004San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-99 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### 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 deeme d 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 acros s 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 gi n 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 ru les and regulations?

There are no specific federal guidelines applying t o cotton gins in terms of New Source Performance Standards (NSPS), Control Techniques Gu idelines (CTG), Alternative Control Technology (ACT), Maximum Achievable Contro l Technology (MACT) and

National Emission Standards for Hazardous Air Pollu tants (NESHAP). There are currently no Best Available Control Technology (BAC T) determinations more stringent than what is currently required in Rule 4204.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-100 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan How does District Rule 4204 compare to rules in oth er air districts?

There are no comparable rules in other air district s in California. Regulations on cotton ginning operations do exist in states other than Ca lifornia; 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 Gi ns

• Louisiana Environmental Regulatory Code

• North Carolina Environmental Management Commission s, Dept. of Environment and Natural Resources, Division of Air Quality Arti cle 21B of Chapter 143

• South Carolina Air Pollution Control Regulations a nd Standards, Regulation 61- 62.5, Standards No. 4 Emissions from Process Indust ries, Section V Cotton Gins

• Oklahoma Dept. of Environmental Quality, Air Pollu tion 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 Grinde rs

Emission Reduction Opportunities Rule 4204 is among the most stringent rules in the nation for cotton gins and cotton ginning operations, leaving little remaining opport unities for additional emissions

reductions. Research 29 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 par ticulate 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 include s a discussion of research of the

undetermined PM2.5 fraction of emissions from cotto n ginning operations, and of potential, but not feasible, opportunities to reduc e 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 partne rship with cotton associations, EPA, the California Air Resources Board (ARB) and t he District to measure actual PM10 and PM2.5 emissions from stack sources and fug itive emissions in and around the ginning facility. This research will provide e mission 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 Calif ornia. This project was designed to

measure emissions from facilities with current emis sions control technologies in place and to improve emission estimation by measurement w ith the highest quality methods and instruments. The project was not designed to e valuate 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 Gi n Particulate Matter

Emissions. United States Department of Agriculture.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-101 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan sampled for the project indicate the estimated rati o of PM2.5 to PM10 is approximately

15%. 30 This fraction of PM2.5 to PM10 is lower than indi cated in the emissions inventory currently being used. According to the 2 011 Final Report update 31 , this study will finish the laboratory analysis for the final g in in early 2012 and continue processing stack sampling data.

1D-3D Cyclones with Expansion Chamber Currently, all cotton gins in the Valley are requir ed 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 chamb er 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 resul ting from use of the standard, small-diameter (D/4) exit 32 . However, there is no completed research indicati ng the

fraction of PM2.5 emitted or the effectiveness of r educing PM2.5 by installing an expanded chamber. As 1D-3D cyclones are already re quired 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 opportuni ty to reduce emissions.

Loadout Rule 4204 currently requires wind screens for loado ut. Two potential opportunities to reduce emissions through control options to capture PM10 emissions from the truck loading operation were identified as follows: 1) ve nting the loadout area to pre-cleaning cyclones and a baghouse; and 2) venting the receivi ng 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 Gui deline 5.1.8 has found those options to not be cost effective. This previous analysis w as calculated according to PM10 emission factors and again, the PM2.5 fraction is u nknown at this time.

Mechanical Conveyance Mechanical conveyance for the main trash handling s ystem could be a potential opportunity to reduce emissions but it has only bee n demonstrated as feasible for newly constructed or re-built cotton gins. Mechanical co nveyance 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 gi nning process. Newer or re-built gins are able to accommodate a mechanical conveyance sys tem since they are able to design the gin around the equipment and space neede d. Operators that have installed a mechanical conveyance system for their gin have h ad to build a lower floor, below the main level containing the major gin equipment, to h ouse the mechanical conveyors. Therefore, as confirmed by industry representatives and equipment manufacturers, it is not technologically feasible to retrofit existing g ins with a mechanical conveyance

30 Agricultural Research Service. (2012). 2012 2 nd 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 Gi n 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 1D3 D Cyclone Performance. Transactions of the ASAE, vol. 42(1): 17-21.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-102 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan system to replace existing trash handling equipment . Additionally, any new facilities would trigger New Source Review requirements and wo uld be required to implement

BACT level controls.

Plenum Chambers Plenum chambers are in use at a number of gins in t he Valley. Plenum chambers are placed upstream of selected cyclones to remove larg e trash. Studies have been inconclusive in demonstrating an increase in PM con trol efficiency with the utilization of a plenum chamber. Most cotton ginning facilities t hat 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 in creased 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 201 2 emission inventory. The emissions from this source category are relatively small throughout the year, with no significant increase in emission levels in the wint er months.

Control Measure Commitments The following is a summary of recommended commitmen ts for Rule 4204.

Regulatory Action The District’s analysis did not identify any additi onal 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 adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat may provide for additional emission reduction opportunities in this category.

Policy Initiatives The District does not currently have any policy ini tiatives specific to cotton ginning activities. There are no recommendations for new p olicy initiatives specific to these

units.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-103 Appendix D: Stationary and Area Source Control Str ategy 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for additio nal education and outreach efforts

for these sources. The District will continue to w ork closely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-104 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.4.2 Rule 4550 Conservation Management Practices

Source Category Rule 4550 was adopted on August 19, 2004 to help br ing the Valley into attainment of federal PM10 standards, and applies to on-field far ming 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 agricult ural sources. EPA finalized approval of Rule 4550 on February 14, 2006 and determined th at the rule met Best Available Control Measure (BACM) requirements of Clean Air Ac t (CAA) 189(b).

The District worked extensively with numerous stake holders, growers, and the Agricultural Technical Committee for the San Joaqui n Valleywide Air Pollution Study Agency (AgTech) for two years prior to developing t he 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 agricu ltural industries. The selected CMPs are listed on application forms that are submi tted to the District for approval as a CMP Plan. The District worked with agricultural st akeholders 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 creati ng an informational pamphlet, assisting stakeholders through the application proc ess, 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 0San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-105 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Regulatory Evaluation

How does District Rule 4550 compare with federal ru les and regulations?

Federal requirements such as New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NE SHAP), and Maximum Achievable Control Technology (MACT) requirements are not appl icable to this source category; additionally, there are no EPA Control Techniques G uidelines (CTGs) or Alternative Control Techniques (ACTs) listed for this category.

How does District Rule 4550 compare to rules in oth er air districts?

Rule 4550, when compared to other California air di stricts’ rules for similar sources and is found to be at least as stringent as the analogo us rules for Imperial County Air Pollution Control District (ICAPCD) Rule 806 (Conse rvation Management Practices) and SMAQMD Rule 215 (Agricultural Permit Requirements a nd New Agricultural Permit Review). SCAQMD and the Arizona Department of Envi ronmental Quality have adopted agricultural best management practices prog rams, which were approved by EPA as Best Available Control Measures (BACMs); how ever, the District’s CMP rule

exceeds these standards. Similar rules were not fo und for BAAQMD or VCAPCD.

Emission Reduction Opportunities

Rule 4550 was the first rule of its kind in the nat ion to target fugitive particulate emissions from agricultural operations. Through th is rule, PM10 emissions have been reduced by 35.3 tons per day, which is approximatel y a 24% reduction for this source category. Similarly, implementation of Rule 4550 b y agricultural operations has resulted in the reduction of PM2.5 emissions through the red uction of passes of agricultural equipment and implementation of other conservation practices. A full evaluation of the success seen through implementation of the Rule 455 0 CMP Program can be found on

the District’s website at: http://www.valleyair.org/farmpermits/updates/cmp_pr ogram_report_for_2005.pdf.

While Rule 4550 has been successful in reducing bot h PM10 and PM2.5 emissions,

recent studies have indicated that the PM2.5 fracti on of emissions makes up a small portion of the total particulate emissions from agr icultural operations. Additionally, particulate emissions from agricultural operations are geologic in nature. As described in Chapter 2 of this plan, these geologic particula te 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 attainme nt 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 re view of similar rules in other regions also demonstrate that the District has adop ted the most stringent rule of its kind. Given the relatively low contribution that emission s from this category make to the Valley’s 24-hour PM2.5 concentrations and current s tringent requirements under RuleSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-106 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 4550, the District has not identified any additiona l opportunities for further emission reductions from this category.

Risk-based Strategy Analysis Particulate matter emissions from agricultural oper ations are primarily geologic in nature, and do not constitute a significant fractio n of the total PM2.5 concentrations during the winter season, the period during which e xceedances 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. G iven the relative insignificance of PM2.5 emissions from this category and the relative low t oxicity, 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 commitmen ts for Rule 4550.

Regulatory Action There are no recommendations for additional regulat ory 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 red ucing PM2.5 emissions is

recommended.

Incentive Action

There are no recommendations for new incentive acti ons at this time.

Technology Advancement Action Through its Technology Advancement Program and othe r research efforts, the District will continue to seek projects that support the dev elopment of new technologies and practices that provide further potential options fo r reducing emissions from agricultural operations. One example of a research effort in th is area includes a recent study aimed at understanding of the effectiveness of reducing p articulate emissions through implementation of CMPs. This Regional Applied Rese arch Effort (RARE) is a collaborative study by the District and EPA, and is focused on comparatively evaluating particulate emissions from conventional agricultura l 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. Preliminar y results indicate that the Combined Operations tillage method reduced PM2.5 emissions b y 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 Anal ysis.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-107 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Policy Initiatives The District currently supports efforts to secure f ederal funds and other mechanisms to achieve near-term reductions from agricultural equi pment that can be credited to the State Implementation Plan (SIP), and supports the i nclusion of continued air quality funding through the NRCS in the Farm Bill, includin g funding to reduce emissions from agricultural equipment and conservation practices. Although there are no recommendations for new policy initiatives, the rec ommendation is to continue supporting the current District legislative platfor m 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. The outreach program developed collabora tively with the USDA-NRCS and agricultural stakeholders to assist affected agricu ltural 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 con tinue to work closely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-108 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.5 RESIDENTIAL AND COMMERCIAL

Significant emissions have been reduced in the Vall ey through several generations of regulations focused on industrial stationary source s. 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 so urces continues, but it is critical that Valley residents reduce emissions in their daily ro utines 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 exam ple, ARB regulates consumer products. Also, since direct regulatory authority on motor vehicle tailpipe emissions rests with ARB and EPA, the District can only decre ase pollutant emissions from vehicles through incentives, public outreach, and i nnovative 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 Fire places and Wood Burning Heaters), Valley residents are taking actions that are achieving significant reductions of health-impacting pollutants when and where these re ductions are most needed. Through the District’s Healthy Air Living program, Valley residents (as well as businesses) are provided the tools to make air qual ity a priority in their day-to-day

decisions.

Additionally, emissions from under-fired charbroile rs in the Valley continue to be a concern. Local restaurants using uncontrolled unde r-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 b e hazardous to human health, and therefore reductions in this category would be valu able in light of the District’s Riskbased Strategy.

There is potential for both regulatory and innovati ve approaches for reducing emissions from residential sources, as is shown in the follow ing control measure source category

discussion.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-109 Appendix D: Stationary and Area Source Control Str ategy 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 redu ce emissions to meet attainment requirements and protect public health. The Distri ct’s longstanding, progressive strategy for reducing emissions is a multifaceted e ffort that includes incentive programs and policy initiatives in addition to prohibitory r ules. The following discussion summarizes both the existing District efforts to re duce emissions from this source category, and evaluations for potential opportuniti es for further emissions reductions.

Incentive Programs Incentive programs are an integral part of the emis sion reduction efforts of the District, especially where the District lacks direct jurisdic tion in establishing emission control requirements. The District is currently funding tw o 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-pow ered 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 Source s section of this appendix. The Wood Stove Change Out program has provided $1,190,000 in grant money towa rd the replacement of 1,988 units, resulting in a reductio n 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 Di strict established the Charbroiler Incentive Program (ChIP) in October 2009, concurren t with the last amendment of Rule 4692. Due to lack of participation from the indust ry, the program was extended until

March 2011 and outreach efforts were increased. Ho wever, no applications for funding were submitted during the extended solicitation per iod. With new technology options potentially becoming available, the District will c ontinue to seek local demonstration projects to develop control technology options.

Policy Initiatives Similar to the Incentive Programs, the District’s p olicies 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 Valle y’s air quality. The District supports policies and has legislative platforms for energy e fficiency and clean alternatives, and opposes legislation that limits the District’s abil ity to regulate the installation and utilization of wood-burning devices at residences.

The District promotes energy efficiency and clean a lternatives as they provide an opportunity for meaningful reductions in emissions in areas with well-established strong regulatory measures on stationary sources such as i n the Valley. For more details

about these efforts refer to the Additional Sources section of this appendix.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-110 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Rules and Regulations The following is a list of rules specific to the Re sidential and Commercial category. Each of the following rules will be evaluated to ex amine 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 10/20/2005San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-111 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.5.1 Rule 4692 Commercial Charbroiling

Source Category There are two types of commercial charbroilers: cha in-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 spe cific 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 t he grid to cook the food. The smoke and vapors generated by cooking on either type of c harbroiler contain water, volatile organic compounds (VOCs), and PM. Larger particles and grease are typically captured by the grease filter of the ventilation ho od 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 applicabil ity thresholds. Charbroiler exhaust is directed through the catalytic oxidizer with little loss of temperature. As hightemperature exhaust goes through the heated catalys t, PM and VOC are oxidized to carbon dioxide and water vapor. This chemical reac tion releases energy that heats the catalyst and is transferred to a heat recovery syst em, so no additional fuel is needed for

the unit.

The original rule, adopted in March 2002, reduced P M2.5 emissions from chain-driven charbroilers by 84%. The September 2009 rule amend ment 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 an d it does not regulate major

sources.

The District created and implemented a pilot progra m, the Charbroiler Incentive Program (ChIP), to provide grant funding to cover a significant portion of the cost of installing particulate control devices on under-fir ed 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.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-112 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan The District has also been tracking and involved wi th technology demonstration projects for under-fired charbroilers at other agencies:

• SCAQMD: South Coast has partnered with the University of C alifornia at Riverside to test control technologies for under-fi red 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 pr oject, which should be complete by the end of 2012.

• EPA: EPA contracted with Innova Tech, who has manufact ured a low-cost and

low-maintenance under-fired charbroiler filtration device. Initial testing of Innova

Tech’s NovaMistTM aerosol particulate filtration technology has show n that their system has the capability of removing over 98% of a erosol particulates at particulate concentrations less than or equal to 40 μ g/m 3 , 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 In nova 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 bot h chain-driven and under-fired

charbroilers. Based on the data included in the Di strict’s 2009 emission inventory methodology for commercial charbroiling, chain-driv en 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 emission s 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.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-113 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 coo king equipment is a very small component of the NOx and SOx emissions in the Stati onary Source Fuel Combustion category, “Service and Commercial,” which is not re flected in the inventory for this

control measure.

Regulatory Evaluation

How does Rule 4692 compare with federal rules and r egulations?

There is currently no guidance given for this sourc e category under the federal Alternative Control Techniques (ACT) documents, the New Source Performance Standards (NSPS), the National Emission Standards f or Hazardous Air Pollutants (NESHAP), and the Maximum Achievable Control Techno logy (MACT) requirements. Additionally, there is no EPA CTG listed for this c ategory.

How does Rule 4692 compare to rules in other air di stricts?

Rule 4692 was compared to other California air dist ricts’ rules for similar sources and was found to be more stringent than SCAQMD Rule 113 8 (Control of Emissions from Restaurant Operations) and VCAPCD (Rule 74.25 Resta urant 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 Distri ct rule applies to charbroilers cooking 400 pounds of meat or more per week. BAAQM D Regulation 6 Rule 2(Commercial Cooking Equipment) is applicable to ch ain-driven charbroilers in a restaurant that purchases 500 pounds of beef or mor e per week or an under-fired charbroiler in a restaurant that purchases 1,000 po unds of beef or more per week. SMAQMD does not currently have a rule for commercia l 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 l b of PM10 per 1,000 lbs of cookedSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-114 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan beef. Effective January 2013, the same emissions r equirements will also apply to preexisting units. However, as the BAAQMD rule is imp lemented, a significant portion of under-fired charbroilers are below the applicabilit y thresholds for grill size or amount of food cooked, and are thus exempt from rule requirem ents.

Emission Reduction Opportunities Potential emission reduction opportunities from thi s source category include emissions from two types of charbroilers: chain-driven charbr oilers and under-fired charbroilers. District Rule 4692 is one of the most stringent rul es in the nation for chain-driven charbroilers and therefore the primary focus for po tential emissions reductions as

discussed below focus on the under-fired charbroile rs. Discussions on both technologies are discussed below.

Chain-Driven Charbroilers Rule 4692 requires emission controls for chain-driv en charbroilers that cook 400 pounds of meat or more per week. In 2009, the amended rul e 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 percen tage 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-exem pt 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 cont rols for under-fired charbroilers. Catalytic oxidizers are not effective for reducing emissions from under-fired charbroilers

because the exhaust from these devices loses too mu ch heat as it is directed to the control device, and the reactions at the catalyst c annot take place under this lower temperature. The following control strategies are more effective for under-fired

charbroilers:

• High efficiency particulate-arresting (HEPA) filtra tion systems: This system adds a HEPA filter to the appliance’s existing grea se filters to effectively eliminate particulates down to about 0.3 microns in diameter. System maintenance is relatively easy to perform, but filt ers 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 charge d screen. These ionized particles are then collected by one of two opposite ly-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 require d once or twice a year.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-115 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Routine maintenance often requires hiring an outsid e 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/de tergent mix is then filtered: the filtered water/detergent mix is recycled throug h to clean more exhaust, and the particulate-laden wash water is discharged to t he sewer system. In addition to the cost of the system itself, associated water/ sewer usage costs and detergent costs can be high, although recent improv ements in design are improving system efficiencies.

These controls for under-fired charbroilers were un proven and extremely costly as of

the District’s 2009 amendment of Rule 4692. The co sts 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 red uced. However, the control technology for under-fired units has continued to d evelop over the past few years, in part through the SCAQMD and EPA technology demonstr ation efforts. Since underfired charbroilers are a larger part of the total c ommercial 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 include d a draft commitment in Chapter 4

of their Draft 2012 AQMP to achieve a 1 tpd PM2.5 reduction from under-fire d charbroilers, though the details of their approach are yet to be determined 34 . 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 contr ibute 5.2% of average winter PM2.5 emitted from stationary and area sources in the 201 2 emission inventory. Although the emissions from commercial charbroiling are small in comparison to the total emissions inventory, this category is one of the largest sing le contributors of directly emitted PM2.5 in the Valley. Photochemical modeling conducted fo r 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 popula ted 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 a nd 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 positiv e impact on public health. The air quality impacts on neighborhoods near restaurants w ith 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.pd f

35 See Schauer and Cass (2000) Environmental Science and Technology, Vol. 34 (9), pp. 1821-1832.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-116 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan limited and emissions are trapped near the surface within the surrounding neighborhoods. This potential for neighborhood-lev el concentration of emissions during evening or multi-day stagnation events raises envir onmental justice concerns.

Control Measure Commitments The following is a summary of recommended commitmen ts 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 D istrict would conduct a thorough review

of all available information about under-fired char broilers 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 a nd other related rule development work, the recommendation is to amend Rule 4692 in 2 016. The District estimates that this amendment would achieve, at minimum, a 20% red uction in the baseline emissions inventory for under-fired charbroilers. The modeli ng 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% Val ley-wide, the District achieves significant health benefits Valley-wide per the Dis trict’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 demonstratio n plan, rather than a more widelyavailable incentive program. After completion of a few pilot demonstration projects under ChIP, though, the District could consider exp anding its charbroiling incentive efforts into a broader incentive program. Therefor e, although there are no

recommendations for new incentive actions at this t ime, 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-f ired charbroiler emissions controls in a working-restaurant setting in the Valley. Suc h a demonstration project could eventually be developed into a larger incentive pro gram. Additionally, the District will

continue to collaborate with EPA and South Coast te chnology demonstration efforts forSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-117 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 n ew 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. It is recommended that the District prov ide strong stakeholder outreach in conjunction with the regulatory, incentives, and te chnology demonstration commitments as appropriate. The District will continue to work closely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-118 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.5.2 Rule 4901 Wood Burning Fireplaces and Wood Bu rning

Heaters

Source Category Residential wood burning is one of the Valley’s lar gest sources of directly-emitted PM2.5 in the winter. Rule 4901 (Wood Burning Firep laces 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 woo d 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 cur tailments, also called “No Burn” days, since 2003. Check Before You Burn and Distri ct Rule 4901 reduce harmful species of PM2.5 when and where those reductions ar e 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 tech niques to reduce wood burning emissions. It also enforced EPA Phase II requireme nts for new wood burning heaters, prohibited the sale of used wood burning heaters, e stablished a list of prohibited fuel types, and required the District to request volunta ry curtailment of wood burning on days when the ambient air quality was unhealthy.

In 2003, the rule was amended to include episodic w ood 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. T he 2003 amendments also added restrictions on the installation of wood burning de vices in new residential developments, based on housing density. In 2008, the District am ended Rule 4901 again, this time to lower the mandatory curtailment level to a PM2.5 co ncentration of 30 μg/m3 (based on EPA’s 2006 PM2.5 National Ambient Air Quality Stand ard (NAAQS) of 35 μg/m3 with an added margin of safety). The 2008 amendments al so 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 Novemb er 10, 2009.

Rule 4901 wood burning curtailments only apply in a reas 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 t his 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 “avera ge winter emissions”. On a Valleywide “No Burn” day, Rule 4901 has the potential to reduce 16 tons of directly emitted

PM2.5.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-119 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 ru les and regulations?

Rule 4901 is as stringent as the current federal Ne w Source Performance Standards (NSPS) (40 CFR 60 Subpart AAA (Standards of Perform ance for New Residential Wood Heaters). The District continues to track EPA ’s current efforts to revise this NSPS. Additionally there are no EPA Control Techni ques Guidelines (CTG), Alternative Control Techniques (ACT), National Emission Standar ds 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 oth er 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 Arti cle VIII; Oregon Department of Environmental Quality Division 262 (Heat Smart Prog ram 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 Applian ces), and SMAQMD Rules 417 (Wood Burning Appliances); and 421 (Mandatory Episo dic Curtailment of Wood and other Solid Fuel Burning). SCAQMD Rule 445 prohibi ts installation of wood burning devices in new developments that have access to nat ural gas service. However, District Rule 4901 has the most stringent wood burn ing curtailment level, compared to

those of other air districts.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-120 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Emission Reduction Opportunities The District evaluated Rule 4901 for potential oppo rtunities to reduce emissions. Potential opportunities evaluated include an analys is of benefits from reducing the curtailment level, allowing cleaner wood burning de vices under certain circumstances to encourage consumers to switch to these clean device s from uncontrolled fireplaces, the possibility of extending the wood burning season, a nd the possibility of amending the portion of the rule pertaining to the quantity of u nits allowed in new developments.

These evaluations resulted in the District committi ng 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 reduc tions is to lower the curtailment level, which would reduce emissions by increasing the numb er 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 t he Valley during the winter season, and would help avoid exceedances of the PM2.5 stand ard. The table below shows the average number of days wood burning could be prohib ited 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 occu r under the lower curtailment level would likely be lower when actually implemented, si nce 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 concentrati ons in Kern County, and greatly assist in attaining the 24-hour PM2.5 standard.

Table D-12 Average Number of Days Forecast Above Cu rtailment 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-b urning seasons.

Wood burning curtailments under Rule 4901 have been shown to significantly reduce PM2.5 concentrations on “No Burn” days, as demonstr ated in the District’s annual “End of the Season Wood Burning Reports.” Currently, Va lley-wide curtailment of woodSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-121 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan burning during winter is estimated to reduce 16 ton s per day of PM2.5 emissions. Prohibitions are declared by county or forecast are a and apply to areas with natural gas service, allowing the rule to target the most dense ly-populated urban areas that are most likely to experienced localized effects of woo d 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 co uld also offset increased natural gas costs by spending less on wood. Compared to ot her 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 burni ng devices, and limits the use of wood burning devices on “No Burn” days in areas tha t 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, sea soned 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 ef ficiently, these devices can lower the overall home heating cost. District Rule 4901 neither prohibits nor requires wood burning device upgrades. However, the District enc ourages such upgrades through its public outreach and through its Burn Cleaner Program , which provides funding to Valley residents to upgrade their current wood-burning dev ices and open fireplaces to natural or propane gas devices, to certified wood stoves or inserts, or to pellet devices. The District’s webpage 36 has more information on program eligibility and qu alified 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: catal ytic 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 sto ves, but burn compressed pellets made of ground, dried wood and other biomass wastes . Pellet stoves are generally more expensive than wood stoves and require electri city for operation; however, they are typically more efficient than wood stoves due t o the better fuel-to-air ratio in the combustion chamber. EPA also certifies pellet stov es.

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 pr imary source of heat, but serve as a secondary heating source or for ambiance. Fireplac es generate much more emissions than wood stoves or pellet stoves, but fireplace in serts are available to reduce

36 www.valleyair.org/Grant_Programs/GrantPrograms.htm# WoodStoveChangeOutSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-122 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan emissions. EPA does not certify fireplaces or fire place inserts, but does have a voluntary program for devices that meet qualificati ons to be considered cleaner burning than typical fireplaces and fireplace inserts. Pha se I qualified units are approximately 57% cleaner than older fireplace models, while Phas e II qualified units are approximately 70% cleaner. While these devices red uce 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 p ropane, emit very little air pollution, and require little maintenance. Gas devices are no t subject to the requirements of Rule 4901, so they can be used on “No Burn” days. For m ore information about the various types of wood burning devices available, see EPA’s Burn Wise program webpages 37

.

The District will consider allowing the use of clea ner EPA-certified wood burning devices, particularly during new potential curtailm ent days aimed at reducing the buildup

of PM2.5 emissions. EPA-certified devices have bee n designed and demonstrated to reduce PM2.5 emissions by 70% or greater in compari son to uncertified woodstoves, and by 95% in comparison to wood-burning fireplaces . Pellet stoves have demonstrated even greater reductions in PM2.5 emiss ions, with an 89% reduction in comparison to uncertified woodstoves and a 98% redu ction from wood-burning fireplaces. Figure D-1 illustrates the average PM2 .5 emissions based on various heat

sources.

37 www.epa.gov/burnwiseSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-123 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Figure D-1 Average PM2.5 Emissions based on Device 38

Many Valley residents have upgraded their homes wit h these newer devices, including through programs such as the District’s Burn Cleaner Program and federal tax

incentives. Given their much lower relative emissi ons, allowed use of these devices during a lower curtailment level could still achiev e the goal of significantly reducing the overall emissions that ultimately lead to violation s of the standard. This potential allowance and the appropriate level of acceptable c lean certified devices will be examined through the public rule amendment process. Enforcing this added flexibility would be difficult given the challenge in distingui shing wood smoke emissions from various wood burning devices, and the District woul d explore various options during the rule development process for ensuring that this iss ue is addressed. Along with this potential allowance, the District will continue to provide incentives to encourage the replacement of existing older devices with newer cl ean devices.

Wood Burning Season An additional opportunity for further reducing emis sions from this source includes lengthening the wood burning curtailment season, gi ven 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 curtailme nt season runs from the beginning of November until the end of February. Expanding Dist rict Rule 4901’s curtailment season to include October and/or March would potentially i ncrease the number of curtailment days in each wood burning season, particularly in O ctober, based on recent air quality data. However, measured Valley concentrations of l evoglucosan, a primary indicator for

38 EPA. Consumers – Energy Efficiency and Wood-Burning Stoves and Fireplaces. (2012, November 14). Retri eved

from http://www.epa.gov/burnwise/energyefficiency.html

.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-124 Appendix D: Stationary and Area Source Control Str ategy 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 Febr uary. Therefore, while total PM2.5 concentrations are often relatively high duri ng 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 seaso n to include curtailments in October and/or March and the associated potential air quali ty 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 instal lation of wood burning fireplaces and heaters in new residential developments by strength ening 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 ba sed on their housing densities, the emissions reduction potential is minimal.

Risk-based Strategy Analysis Wood smoke contains PM2.5, carbon monoxide, formald ehyde, sulfur dioxide, irritant gases, and known and suspected carcinogens, such as polycyclic aromatic hydrocarbons (PAH). The toxic air pollutants in wo od smoke can cause human health impacts such as coughs, headaches, and eye and thro at irritation. Studies show that prolonged inhalation of wood smoke contributes to c hronic interstitial lung disease, pulmonary arterial hypertension, and cor pulmonale, which can eventually lead to heart failure, in adults 39 . Wood smoke has also been linked to detrimental m utagenic and systemic effects such as oxidative stress and coagu lation, which can ultimately result in cell damage and possibly lead to cancer 40, 41, 42 . Children with the highest exposure to wood smoke show a significant decrease in lung func tion 43 . Studies also found that wood smoke is twelve times more carcinogenic than a n equal concentration of cigarette

smoke 44 . Efforts to reduce wood smoke target some of the most harmful species of

PM2.5.

39 Sandoval, J.; Slas, J.; Martinez-Guerra, M.L.; Gom ez, A.; Martinez, C.; Portales, A.; Palomar, A.; Vi llegas, M.; and Barrios, R. Pulmonary Arterial Hypertension and Cor Pulmonale Associated with Chronic Domestic Woodsmo ke Inhalation. (1993) Chest 103:12-20.

40 Danielsen, P.H.; Bräuner, E.V.; Barregard, L.; Säl lsten, G.; Wallin, M.; Olinski, R.; Rozalski, R.; M øller, P.; Loft, S. Oxidatively damaged DNA and its repair after experi mental exposure to wood smoke in healthy humans. (2 008) Mutat Res. 642(1-2):37-42.

41 Barregard, L.; Allsten, G.S.; Gustafson, P.; Johan sson, L.; Johannesson, S.; Basu, S.; Stigendal, L. Experimental Exposure to Wood-Smoke Particles in Healthy Humans: Effects on Markers of Inflammation, Coagulation, a nd Lipid Peroxidation (2006) Inhalation Toxicology 18:845–85 3.

42 Sapkota, A.; Gajalakshmi, V.; Jetly, D.H.; Roychow dhury, S.; Dikshit, R.P.; Brennan, P.; Hashibe, M.; Boffetta, P. Indoor air pollution from solid fuels and risk of h ypopharyngeal/laryngeal and lung cancers: a multice ntric case-control study from India. (2008) Int J Epidemiol. 37(2):321 -8.

43 Heumann, M.; Foster, L.R.; Johnson, L; Kelly, L. W oodsmoke Air Pollution and Changes in Pulmonary Fun ction Among Elementary School Children (1991) Air & Waste Management Association 84th Annual Meeting & Exhib ition, Vancouver, British Columbia.

44 Lewtas, J.; Zweidinger, R.B.; Cupitt, L.; Mutageni city, Tumorigenicity and Estimation of Cancer Risk from Ambient

Aerosol and Source Emissions from Woodsmoke and Mot or Vehicles. (1991) Air and Waste Management Association 84th Annual Meeting & Exhibition, Vanco uver, British Columbia.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-125 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan People can be exposed to wood smoke when they use t heir wood burning devices. Additionally, people can be exposed to wo od smoke when people in their neighborhoods use their wood burning devices; windo ws 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 i n Cambria, California and published in 2011. Using aethalometers designed to monitor carbon black as the definitive chemical signature of wood smoke, the st udy found nocturnal outdoor concentrations in Cambria neighborhoods that were 2 to 10 times higher than the cleanest part of the city. Most significantly, ove r 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 import ance of reducing wood burning emissions to improve public health. Rule 4901 proh ibits 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 impa cted urbanized areas when the local weather is forecast to hamper PM dispersion.

Given the time, location, and type of PM2.5 emissio ns 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 re duced annual exposure by about 13% in Bakersfield and Fresno, resulting in 30 to 7 0 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 201 2 emission inventory making residential wood burning one of the Valley’s larges t source of directly-emitted PM2.5. Also, emissions associated with residential wood bu rning are confined to the time of year when the Valley experiences its PM2.5 exceedan ce 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. Photochemic al modeling conducted for this plan shows that further reducing residential wood burnin g emissions would contribute to improved PM2.5 air quality in the Valley.

Control Measure Commitments The following is a summary of recommended commitmen ts for Rule 4901.

Regulatory Action There is potential to reduce residential wood combu stion PM2.5 emissions by lowering the threshold at which a “No Burn” day is called fo r each county. As discussed above,San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-126 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan the recommendation is to lower the curtailment thre shold to 20 μg/m3. While significantly below the federal standard of 35 μg/m 3, 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 d etails 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 allow ing 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 cert ain curtailment levels could still achieve the goal of significantly reducing the over all emissions that ultimately lead to

violations of the standard.

Expanding the applicability of Rule 4901 curtailmen ts to include October and/or March

will also be considered when Rule 4901 is next amen ded. 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 pro cess.

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 forma lly lower the curtailment level to 20 μg/m3, the District proposes a new contingency leve l 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 achie ve an additional 1.5 tons per day of PM2.5, as an average day during the wood burning se ason (November - February). This would serve as additional contingency reductio ns 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 1.5San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-127 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Table D-14 Estimated Change in Number of No Burn Da ys

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 b urning 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 qualif ied fireplace inserts and fireplaces that emit less PM2.5 than their uncontrolled firepl ace counterparts. However, Phase II certified wood stoves, pellet stoves, and natural g as heating emit less PM2.5 than even the cleanest Phase 2 qualified fireplaces and firep lace inserts. The District does not anticipate participating in any technology advancem ent 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 Bef ore You Burn” outreach utilizes billboards, radio ads, brochures, social media, str ong media partnerships and more to ensure the public is informed about wood burning cu rtailments. 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 Di strict December 20, 2012

D-128 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.5.3 Rule 4902 Residential Water Heaters

Source Category Rule 4902 applies to manufacturers, distributors, r etailers, and installers of Public Utilities Commission (PUC) quality natural gas-fire d residential water heaters with heat input rates less than or equal to 75,000 Btu/hr. I t 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 N Ox 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 r ule by enforcing a limit of 10 ng/J for new or replacement water heaters and a lim it of 14 ng/J for instantaneous water heaters. EPA finalized approval for Rule 4902 on M ay 5, 2010. Rule 4902 is not subject to RACT because it is not a Control Techniq ues Guidelines (CTG) category and it is applicable to sources that are too small to e xceed 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 ru les and regulations?

There is currently no federal guidance given for th is source category under the federal CTG, Alternative Control Techniques (ACT), New Sour ce Performance Standards (NSPS), National Emission Standards for Hazardous A ir Pollutants (NESHAP), and Maximum Achievable Control Technology (MACT) requir ements.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-129 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan How does District Rule 4902 compare to rules in oth er air districts?

District analysis compares Rule 4902 to the followi ng analogous rules in other air districts: SCAQMD Rule 1121 (Control of Nitrogen Ox ides 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 H our), 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 Heat ers) 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 cont rolled by approximately 88% for this source category. Units subject to Rule 4902 are fi red on PUC quality natural gas, and are inherently low-emitters of SOx and PM2.5 emissi ons. Given the significant efforts and investments already made to reduce emissions fr om this source category, there are little remaining opportunities for obtaining additi onal emissions reductions. For the sake of thoroughness, the possibility of further reducin g emissions from natural-gas fired water heaters is evaluated in the following discuss ion.

The potential opportunity evaluated is the possibil ity of achieving additional emission reductions from this category by taking advantage o f 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 tha t operate on natural gas. The potential opportunity would be to replace natural g as and propane water heaters with units that run on electricity. A comparison of thr ee water heaters that utilize the different fuel types with an emissions reduction and cost eff ectiveness analysis for these units is

summarized below.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-130 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Table D-15 Emissions Reductions and Cost Effectiven ess of Water Heaters by

Fuel Type

Fuel Type Low NOx Propane Electricity Natural Gas

Capacity 1 50 gallons 50 gallons 50 gallons

Shipping Weight 1 180 lbs 151 lbs 109 lbs

Energy Factor 1 0.62 0.59 0.91

Purchase Price 1 $902.00 $899.00 $473.25

Estimated Life Expectancy 2 13 years 13 years 13 years

Lifetime Energy Use 2 3,133 therms 2,867 gallons of

LP 62,439 kWh

Lifetime Energy Costs 3 $3,568 $7,176 $9,834

Lifetime NOx Emissions 4 30.60 lbs 48.09 lbs 0.00 lbs

Annual NOx Emissions 2.35 lbs 3.70 lbs 0.00 lbs

Comparing Natural Gas and Propane to Electricity

N/A Annualized capital cost 5 $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 Grain ger Industrial Supply as of August 7, 2012

2 Data from US Department of Energy – Energy Cost Ca lculator for Electric and Gas Water Heaters http://www1.eere.energy.gov/femp/technologies/eep_w aterheaters_calc.html

3 Cost data based on the of the average cost of unit s of energy in 2010 according to the US Energy Info rmation Administration. http://www.eia.gov/

4 Emissions factors derived from Appendix EA-1 of US Department of Energy’s Energy Assessment for Propo sed Energy

Conservation Standards for Residential Clothes Wash ers

5 The annualized capital equipment cost is calculate d by multiplying the installed equipment cost by th e capital recovery factor of

0.1627.

The operating cost for electric water heaters is hi gher than for propane and natural gas units, due to the higher cost of electricity over p ropane and natural gas. However, the initial purchase price is considerably lower for el ectric units. Converting to an electric water heater also may require modifications to the residence and have associated costs, though electric water heaters are amongst th e 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 bene fits may make converting to electric water heating a viable control strategy.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-131 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Risk-based Strategy Analysis The emissions from units subject to Rule 4902 contr ibute 6.0% of average winter NOx emitted from stationary and area sources in the 201 2 emission inventory. As illustrated in the emission inventory table above, the emission s from this source category are more prominent during winter months. However, these uni ts 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 significantl y 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 commitmen ts for Rule 4902.

Regulatory Action The District’s analysis did not identify any additi onal 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 i ncentive programs for these

sources at this time.

Technology Advancement Action There are no recommendations for technology advance ment actions at this time. Through its Technology Advancement Program, the Dis trict will continue to seek potential feasible and low-cost technologies that m ay provide for additional emission reduction opportunities in this category.

Policy Initiatives The District does not currently have any policy ini tiatives specific to this rule. There are no recommendations for new policy initiatives speci fic to these units.

Education and Outreach The District currently provides a robust education and outreach program for regulated sources through the Small Business Assistance progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. As this is a point of sale rule, this ou treach would be applicable to retailers

and manufacturers of residential water heaters. Th e 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 Di strict December 20, 2012

D-132 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.5.4 Rule 4905 Natural Gas-Fired, Fan-Type, Reside ntial Central

Furnaces

Source Category Rule 4905 is a point of sale rule that applies to a ny person who sells, offers for sale, installs or solicits the installation of natural-ga s-fired, fan-type residential central furnaces, for use within the Valley with a rated he at input capacity of less than 175,000 Btu/hour, and for combination heating and cooling u nits with a rated cooling capacity of less than 65,000 Btu/hour.

The rule was adopted on October 20, 2005 to establi sh 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/MMB tu). EPA finalized approval for Rule 4905 on May 30, 2007. Rule 4905 is not subjec t to RACT requirements because it is not a Control Techniques Guidelines (CTG) catego ry and it is applicable to sources that are too small to exceed the major source thres hold.

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 ru les and regulations?

There are no applicable CTG, Alternative Control Te chniques (ACT), New Source Performance Standards (NSPS), National Emission Sta ndards 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 oth er air districts?

Rule 4905 when compared to other California air dis tricts’ rules for similar sources is found to be at least as stringent as the other rule s. Specifically, Rule 4905 was compared to the following rules: SMAQMD Rule 414 (W ater Heaters, Boilers and Process Heaters Rated Less Than 1,000,000 BTU Per H our), BAAQMD Regulation 9San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-133 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Rule 4 (Nitrogen Oxides from Fan Type Residential C entral Furnaces), and VCAPCD Rule 74.22 (Natural Gas-Fired, Fan-Type Central Fur naces).

SCAQMD Rule 1111 (Reduction of NOx Emissions from N atural Gas-Fired, Fan-Type Central Furnaces) limits NOx emissions of all furna ces to 0.0325 lb/MMBtu by October 1, 2018, whereas the Rule 4905 NOx limit is 0.093 l b/MMBtu. In addition, SCAQMD Rule 1111 applies to both commercial and residentia l units, whereas District Rule 4905 only applies to residential units. The District ha s 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 ha s still not been determined if

manufacturers will be able to meet the limits in SC AQMD Rule 1111. In 2010, SCAQMD released a Request for Proposal (RFP) for th e development of prototype ultra-low NOx natural gas-fired fan-type central fu rnaces. 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, NO x 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 re gulates small residential and commercial furnaces less than 175,000 Btu/hr, where as District Rule 4905 regulates residential furnaces of the same size, but not comm ercial furnaces. The technology of

commercial furnaces does not differ from residentia l central furnaces.

As a part of their on-going research efforts, SCAQM D 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 201 4. SCAQMD plans on following up the assessment with a rule amendment that incorpora tes 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 exten ding the applicability of this rule to include commercial units based on technological fea sibility 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 technol ogies for commercial furnaces.

Risk-based Strategy Analysis The emissions from units subject to Rule 4905 contr ibute 8.9% of average winter NOx emitted from stationary and area sources in the 201 2 emission inventory. As illustrated in the emission inventory table above, the emission s from this source category are primarily a winter issue.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-134 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Control Measure Commitments The following is a summary of recommended commitmen ts 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 possibi lity of extending the applicability of rule requirements to include natur al gas-fired, fan-type, commercial

central furnaces.

Incentive Action Rule 4905 is currently under commitment to be amend ed to make the rule more stringent, and no new technologies were identified to further reduce emissions beyond those technologies that will be evaluated during th e 2014 rule amending project. No

new incentive actions are recommended for these nat ural 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 inten ds to use the findings from that testing to make determinations as to the appropriat e amendments for the rule. This effort, aside, there is no recommendation for a new technology advancement project for this source category. Through its Technology Advan cement Program, the District will continue to seek potential feasible and low-cost te chnologies 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 a re 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. This is a point of sale rule; District o utreach is primarily applicable to retailers of these natural gas-fired, fan-type, residential c entral furnaces. No new education and

outreach efforts are recommended for these retailer s at this time. The District will continue to work closely with affected sources to e nsure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-135 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.6 FUGITIVE PARTICULATE MATTER

District Regulation VIII is comprised of eight rule s that regulate fugitive dust emissions. Regulation VIII applies only to outdoor anthropogen ic (human-caused) fugitive dust sources; primary PM10 sources that result in fugiti ve 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 v ehicle/equipment traffic areas (such as parking, shipping, receiving, transfer, and serv ice areas), and off-field agricultural sources. Regulation VIII does not apply to PM10 pr ecursor sources or sources of smoke. Regulation VIII prohibitory standards are p erformance based whereby the operators are allowed to determine the control tech nique sufficient to limit visible dust emissions to 20 percent opacity and, in certain ins tances, to implement requirements for

a stabilized surface.

Regulation VIII was critical in the District’s atta inment of the National Ambient Air Quality Standard for PM10. However, a variety of s tudies have been conducted which may indicate that the PM2.5 fraction of the PM emis sions 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 emi ssions inventory for the various activities in this category and to indicate the lev el of significance of those PM2.5 emissions. At this time, PM2.5 emission control fa ctors are not well defined and it is not known if controls for PM10 are effective for produc ing PM2.5 emissions reductions for this category.

In the Risk-based Strategy chapter of this plan, mo deling results show that the geologic fraction of PM2.5 found in the San Joaquin Valley m akes a relatively small contribution to overall PM2.5 mass (see Figure 2.1). In additio n, 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 s ources. Refer to Chapter 6 (Incentive Programs) and Appendix C (Mobile Source Control Str ategies) for details on how the

District addresses mobile sources.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-136 Appendix D: Stationary and Area Source Control Str ategy 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 redu ce emissions to meet attainment requirements and protect public health. The Distri ct’s longstanding, progressive strategy for reducing emissions is a multifaceted e ffort that includes incentive programs and policy initiatives in addition to prohibitory r ules. The following discussion summarizes both the existing District efforts to re duce emissions from this source category, and evaluations for potential opportuniti es for further emissions reductions.

Incentive Programs Incentive programs are an integral part of the emis sion reduction efforts of the District, especially where the District lacks direct jurisdic tion in establishing emission control requirements. Because the District has regulatory authority and currently regulates these control measure source categories, the opport unities for incentive programs are minimal. In fact, there are not currently any ince ntive programs specific to the reduction of fugitive PM from sources subject to the Regulati on VIII rules. The District does however implement incentive programs for off-road v ehicles; refer to Chapter 6 for details on those programs.

Policy Initiatives Similar to the Incentive Programs, the District’s p olicies 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 Valle y’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 b are 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 fug itive dust is wet suppression, which also requires water. With this in mind, the Distri ct supports measures to provide reliable water supplies to the Valley.

Rules and Regulations The following table identifies the District Regulat ory VIII rules, each of which will be evaluated to examine potential opportunities for ad ditional emissions reductions.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-137 Appendix D: Stationary and Area Source Control Str ategy 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 08/19/2004San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-138 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.6.1 Rule 8011 General Requirements

Source Category The provisions of Rule 8011 are applicable to speci fied outdoor fugitive dust sources. The definitions, exemptions, requirements, administ rative requirements, recordkeeping requirements, and test methods set forth in this ru le are applicable to all rules under District Regulation VIII (Fugitive PM10 Prohibition s). The Regulation VIII series was adopted in November 2001, and subsequently amended in 2004. The rules were developed pursuant to EPA guidelines for serious PM 10 nonattainment areas. In 2004, the District adopted amendments to Regulation VIII to upgrade existing Reasonably Available Control Measure (RACM) level rules to mee t the more stringent Best Available Control Measure (BACM) level required in serious PM 10 nonattainment areas.

Emission Inventory The emission inventory for this rule is not quantif ied 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 emissi on reductions are addressed in the other seven Regulation VIII Rules. Emissions from R egulation VIII Rules can be found in Appendix B, and summarized in the other seven Re gulation VIII rule discussions in this appendix.

Regulatory Evaluation

How does District Rule 8011 compare with federal ru les and regulations?

Rule 8011 when compared to EPA rules, regulations, and guidelines that apply to fugitive dust is found to meet or exceed these stan dards. Federal requirements are

located in General Preamble for Title I of the Clea n Air Act Amendments of 1990 Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and

Technical Information Document for Best Available C ontrol Measures (EPA-450/2-92- 004).

How does District Rule 8011 compare to rules in oth er 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 s tringent, than other districts’ rules. Comparisons to other air district rules, included S CAQMD Rule 1156 (Further

Reductions of Particulate Emissions from Cement Man ufacturing Facilities), SCAQMD Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations), SMAQMD Rule 403 (Fugitive Dust), VCAPCD Rule 55 (Fu gitive 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 Di strict December 20, 2012

D-139 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Emission Reduction Opportunities
This rule is administrative in nature, and is inten ded to be a supplementary rule to the other District Regulation VIII rules. Opportunitie s 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 e mission 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 req uirement rule meant to supplement and support the other Regulation VIII rules. The emiss ions 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 rel atively low toxicity. The emissions associated with sources subject to each of the Regu lation VIII rules are identified and discussed in each rule control measure source categ ory discussion.

Control Measure Commitments The following is a summary of recommended commitmen ts for Rule 8011.

Regulatory Action This rule is an administrative and supplemental rul e 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 actio ns were to be recommended, they would need to be directed at the other Regulation V III rules.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat may provide for additional emission reduction opportunities in this category.

Policy Initiatives As discussed previously, one of the key dust contro l measures that residents and operators in the Valley rely upon to control fugiti ve dust is wet suppression. Being mindful of this, the District currently supports le gislative measures to provide reliable water supplies to the Valley. While there are no r ecommendations for new policy initiatives, the recommendation is to continue supp orting legislative activities that aim to provide reliable water supplies to the Valley.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-140 Appendix D: Stationary and Area Source Control Str ategy 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. The District does not have recommendatio ns for new education and outreach

efforts for these sources. The District will conti nue to work closely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-141 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.6.2 Rule 8021 Construction, Demolition, Excavatio n, Extraction, and Other Earthmoving Activities

Source Category Rule 8021 applies to construction or demolition rel ated disturbances of soil, including land clearing, grubbing, scraping, excavation, extr action, 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 p rior to commencement of landfilling

activities.

In 2004, the District adopted amendments to Regulat ion VIII to upgrade existing RACM level rules to meet the more stringent BACM level r equired in serious PM10

nonattainment areas. Rule 8021 was amended to add dust suppression requirements, and to require submittal of Dust Control Plans on r esidential construction sites 10.0

acres or more in size and on non-residential constr uction 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 ru les and regulations?

Rule 8021, when compared to EPA rules, regulations, and guidelines that apply to fugitive dust, is found to meet or exceed these sta ndards. Federal requirements are

located in General Preamble for Title I of the Clea n Air Act Amendments of 1990 Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and

Technical Information Document for Best Available C ontrol Measures (EPA-450/2-92- 004).

How does District Rule 8021 compare to rules in oth er 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 s tringent, than other districts’ rules. Comparisons to other air district rules included SC AQMD Rule 1156 (FurtherSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-142 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Reductions of Particulate Emissions from Cement Man ufacturing Facilities), SCAQMD Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations), SMAQMD Rule 403 (Fugitive Dust), VCAPCD Rule 55 (Fu gitive Dust), and Clark County Department of Air Quality (CCDAQ) Section 94 (Permitting and Dust Control for Construction Activities). BAAQMD does not have a c omparable rule.

Emission Reduction Opportunities District analysis identified one potential opportun ity to further reduce emissions from this source category; to require signs to be posted at c ertain 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 th e 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 201 2 emission inventory. The particulate matter emissions are geological and the inventory is relatively small and consistent throughout the year, with no elevated em ission 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 ove rall 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 commitmen ts for Rule 8021.

Regulatory Action The District’s analysis did not identify any additi onal 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 p rogram 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 adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat may provide for additional emission reduction opportunities in this category.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-143 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Policy Initiatives As discussed previously, one of the key dust contro l measures that residents and operators in the Valley rely upon to control fugiti ve dust is wet suppression. Being mindful of this, the District currently supports le gislative measures to provide reliable water supplies to the Valley. While there are no r ecommendations for new policy initiatives, the recommendation is to continue supp orting 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new edu cation 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 Di strict December 20, 2012

D-144 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.6.3 Rule 8031 Bulk Materials

Source Category Rule 8031 applies to the outside storage and handli ng 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 re strict dust from material transfer, and reduce emissions from transport material and storag e piles that emit dust. Facilities subject to Rule 8031 are required use control measu res to ensure that visible dust emissions are limited to 20% opacity or less. Thes e control measures can include application of water or other dust stabilizers, cov ering of bulk materials, construction of wind barriers, covering of haul trucks, etc.

In 2004, the District adopted amendments to Regulat ion VIII to upgrade existing RACM level rules to meet the more stringent BACM level r equired in serious PM10 nonattainment areas. Rule 8031 was amended to requ ire construction and maintenance of wind barriers when handling bulk mat erials.

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 ru les and regulations?

Rule 8031, when compared to EPA rules, regulations, and guidelines that apply to fugitive dust, is found to meet or exceed these sta ndards. Federal requirements are

located in General Preamble for Title I of the Clea n Air Act Amendments of 1990 Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and

Technical Information Document for Best Available C ontrol Measures (EPA-450/2-92- 004).San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-145 Appendix D: Stationary and Area Source Control Str ategy 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 s tringent, than other districts’ rules. Comparisons to other air district rules included SC AQMD Rule 1156 (Further

Reductions of Particulate Emissions from Cement Man ufacturing Facilities), SCAQMD Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations), SMAQMD Rule 403 (Fugitive Dust), VCAPCD Rule 55 (Fu gitive 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 mitigatio n techniques; there are no additional potential opportunities for further reductions of e missions 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 stand ard requires significant mitigation

efforts from sites that store bulk materials.

Risk-based Strategy Analysis The PM2.5 emissions from this source category contr ibute to 0.04% of average winter PM2.5 emitted from stationary and area sources in t he 2012 emission inventory. The particulate matter emissions are geological and the inventory is relatively small and consistent throughout the year, with no elevated em ission 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 ove rall 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 commitmen ts for Rule 8031.

Regulatory Action The District’s analysis did not identify any additi onal 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 prog rams specific to the outside storage and handling of bulk materials. There are no recom mendations for new incentive

actions at this time.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat may provide for additional emission reduction opportunities in this category.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-146 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Policy Initiatives As discussed previously, one of the key dust contro l measures that residents and operators in the Valley rely upon to control fugiti ve dust is wet suppression. Being mindful of this, the District currently supports le gislative measures to provide reliable water supplies to the Valley. While there are no r ecommendations for new policy initiatives the recommendation is to continue suppo rting 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new edu cation 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 Di strict December 20, 2012

D-147 Appendix D: Stationary and Area Source Control Str ategy 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 w orkday; thresholds for any site with 150 daily vehicle trips; addressing carryout and tr ackout in Dust Control Plans; removing carryout and trackout in urban areas; pave d interior roads; and prevention of carryout and trackout.

In 2004, the District adopted amendments to Regulat ion VIII to upgrade existing RACM level rules to meet the more stringent BACM level r equired in serious PM10 nonattainment areas. Rule 8041 was amended to requ ire a threshold for vehicles with three or more axles to takes actions for carryout/t rackout. Amendments included a threshold for projects located in rural areas, a pr ovision requiring actions within half an hour if specified measures are insufficient to prev ent carryout/trackout, and specifications for dust collectors, gravel pads, an d paved surfaces.

Emission Inventory The emission inventory for this rule is not quantif iable 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 ru les and regulations?

Rule 8041, when compared to EPA rules, regulations, and guidelines that apply to fugitive dust, is found to meet or exceed these sta ndards. Federal requirements are

located in General Preamble for Title I of the Clea n Air Act Amendments of 1990 Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and

Technical Information Document for Best Available C ontrol Measures (EPA-450/2-92- 004).

How does District Rule 8041 compare to ru l es 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 s tringent, than other districts’ rules. Comparisons to other air district rules included SC AQMD Rule 1156 (Further

Reductions of Particulate Emissions from Cement Man ufacturing Facilities), SCAQMD Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations), SMAQMD Rule 403 (Fugitive Dust), VCAPCD Rule 55 (Fu gitive Dust), and Clark County Department of Air Quality (CCDAQ) Section 94 (Permitting and Dust Control for Construction Activities). BAAQMD does not have a c omparable rule.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-148 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Emission Reduction Opportunities Two potential opportunities to reduce emissions wer e identified, evaluated, and determined to not be feasible. The first potential emission reduction opportunity would be to reduce the threshold for daily trips per work site that requires a carryout and trackout prevention system (currently 150 trips). Reducing this threshold would require smaller worksites to install costly trackout preven tion equipment like wheel washers, metal grates, and gravel pads. At these smaller wo rksites the emission reductions that

would be achieved would be minimal and not cost eff ective 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 track out 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 de termined to not be feasible.

Risk-based Strategy Analysis The emissions from this source category are documen ted 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 201 2 emission inventory. The particulate matter emissions are geological and the inventory is relatively small and consistent throughout the year, with no elevated em ission 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 ove rall 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 commitmen ts for Rule 8041.

Regulatory Action The District’s analysis did not identify any additi onal 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 prog rams specific to this source category;

there are no recommendations for new incentive acti ons at this time.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat may provide for additional emission reduction opportunities in this category.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-149 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Policy Initiatives As discussed previously, one of the key dust contro l measures that residents and operators in the Valley rely upon to control fugiti ve dust is wet suppression. Being mindful of this, the District currently supports le gislative measures to provide reliable water supplies to the Valley. While there are no r ecommendations for new policy initiatives the recommendation is to continue suppo rting 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new edu cation 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 Di strict December 20, 2012

D-150 Appendix D: Stationary and Area Source Control Str ategy 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 mor e 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 visib le dust emissions (VDE) to 20% opacity, to comply with the conditions of a stabili zed surface, and to install barriers to prevent unauthorized vehicles from accessing the st abilized areas.

In 2004, the District adopted amendments to Regulat ion VIII that upgraded existing RACM level rules to meet the more stringent BACM le vel 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 ru les and regulations?

Rule 8051, when compared to EPA rules, regulations, and guidelines that apply to fugitive dust, is found to meet or exceed these sta ndards. Federal requirements are

located in General Preamble for Title I of the Clea n Air Act Amendments of 1990 Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and

Technical Information Document for Best Available C ontrol Measures (EPA-450/2-92- 004).

How does District Rule 8 051 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 s tringent, than other districts’ rules. Comparisons to other air district rules included SC AQMD Rule 1156 (Further

Reductions of Particulate Emissions from Cement Man ufacturing Facilities), SCAQMD Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations), SMAQMD Rule 403 (Fugitive Dust), VCAPCD Rule 55 (Fu gitive Dust), and ClarkSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-151 Appendix D: Stationary and Area Source Control Str ategy 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 c omparable rule.

Emission Reduction Opportunities The District’s analysis did not identify any potent ial opportunities to further reduce emissions from this source category beyond those em issions that are already being reduced by rule requirements. As a part of due dil igence 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 201 2 emission inventory. The particulate matter emissions are geological and the inventory is relatively small and consistent throughout the year, with no elevated em ission 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 ove rall 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 commitmen ts for Rule 8051.

Regulatory Action The District’s analysis did not identify any additi onal technologically feasible and cost effective potential controls that would result in r educed emissions. Therefore, there are no recommendations for additional regulatory action s 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 ince ntive actions at this time.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat may provide for additional emission reduction opportunities in this category.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-152 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Policy Initiatives As discussed previously, one of the key dust contro l measures that residents and operators in the Valley rely upon to control fugiti ve dust is wet suppression. Being mindful of this, the District currently supports le gislative measures to provide reliable water supplies to the Valley. While there are no r ecommendations for new policy initiatives the recommendation is to continue suppo rting 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. No new education and outreach efforts ar e recommended for these sources

at this time. The District will continue to work c losely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-153 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.6.6 Rule 8061 Paved and Unpaved Roads

Source Category

Rule 8061 establishes standards for the constructio n of new and modified paved roads in accordance with published guidelines by the Amer ican Association of State Highway and Transportation Officials for road construction and applies to any paved, unpaved, or modified public or private road, street highway, fr eeway, alley way, access drive, access easement, or driveway. The rule also allows altern ative means of achieving the same

level of dust reduction. Rule 8061 also establishe s thresholds that when exceeded require that roads are treated to reduce visible du st emissions.

In 2004, the District adopted amendments to Regulat ion VIII to upgrade existing RACM level rules to meet the more stringent BACM level r equired in serious PM10 nonattainment areas. Rule 8061 was amended to repl ace the existing 75 maximum daily vehicle trip threshold with a 26 annual avera ge 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 0San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-154 Appendix D: Stationary and Area Source Control Str ategy 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 ru les and regulations?

Rule 8061, when compared to EPA rules, regulations, and guidelines that apply to fugitive dust, is found to meet or exceed these sta ndards. Federal requirements are

located in General Preamble for Title I of the Clea n Air Act Amendments of 1990 Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and

Technical Information Document for Best Available C ontrol Measures (EPA-450/2-92- 004).

How does District Rule 8061 compare to rules in oth er 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 s tringent, than other districts’ rules. Comparisons to other air district rules included SC AQMD Rule 1156 (Further

Reductions of Particulate Emissions from Cement Man ufacturing Facilities), SCAQMD Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations), SMAQMD Rule 403 (Fugitive Dust), VCAPCD Rule 55 (Fu gitive Dust), Clark County Department of Air Quality (CCDAQ) Section 91 (Fugit ive Dust from Unpaved Roads, Unpaved Alleys, and Unpaved Easement Roads), and CC DAQ 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 emiss ions 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 Di strict December 20, 2012

D-155 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Analysis of the emission inventory indicates that t he majority of the particulate emissions attributable to unpaved roads are generat ed 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 lowe st in the winter months, when the

District’s PM2.5 24-hour exceedances occur. Distri ct staff believes the winter average PM2.5 emission inventory is overestimated for the f ollowing 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 th e winter months.

• Many US Forest and Park Roads are inaccessible dur ing winter months due to
increased amounts of rain and snow, yet emissions f rom these roads make up a
larger percentage of the total unpaved road emissio ns in winter (42.8%) than in
the annual average (40.7%)

For these reasons, lowering the trip threshold is n ot a viable emission reduction opportunity.

Risk-based Strategy Analysis The emissions inventory from this source category i ncludes the inventory for emissions from sources subject to the Rule 8041 (Carryout and Trackout) control measure source category. The emissions from these two source cate gories combined contribute to 11.2% of average winter PM2.5 emitted from stationa ry and area sources in the 2012 emission inventory. The particulate matter emissio ns are geological and the inventory is relatively small and consistent throughout the y ear, with no elevated emission levels in winter months. As discussed in Chapter 2, resea rch 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 rel atively low toxicity.

Control Measure Commitments The following is a summary of recommended commitmen ts for Rule 8061.

Regulatory Action The District’s analysis did not identify any additi onal technologically feasible and cost effective potential controls. Therefore, there are no recommendations for additional regulatory actions for Rule 8061. The key potentia l opportunity identified to reduce emissions for this rule is to lower the trip thresh old that requires dust control measures on public unpaved roads. Staff reviewed this sourc e category and determined that lowering this threshold would not result in measure able emission reductions.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-156 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Incentive Action The District does not currently fund an incentive p rogram specific to paved and unpaved roads; there are no recommendations for new incenti ve actions specific to this rule at

this time.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat may provide for additional emission reduction opportunities in this category.

Policy Initiatives As discussed previously, one of the key dust contro l measures that residents and operators in the Valley rely upon to control fugiti ve dust is wet suppression. Being mindful of this, the District currently supports le gislative measures to provide reliable water supplies to the Valley. While there are no r ecommendations for new policy initiatives the recommendation is to continue suppo rting 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new edu cation 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 Di strict December 20, 2012

D-157 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.6.7 Rule 8071 Unpaved Vehicle/ Equipment Traffic Areas

Source Category Rule 8071 is applicable to unpaved vehicle/equipmen t areas, parking, fueling and service areas, and shipping, receiving, and transfe r areas. The rule contains requirements for when vehicle traffic reaches or ex ceeds specified thresholds, limitations on visible dust emissions (VDE), compli ance requirements with the conditions of a stabilized surface, and lists contr ol techniques, which could be implemented to limit VDE and to comply with the con ditions of a stabilized surface.

In 2004, the District adopted amendments to Regulat ion VIII to upgrade existing RACM level rules to meet the more stringent BACM level r equired in serious PM10

nonattainment areas. Rule 8071 was amended to remo ve the 1.0 acre or larger threshold; change the vehicle threshold from 75 veh icle 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 ru les and regulations?

Rule 8071, when compared to EPA rules, regulations, and guidelines that apply to fugitive dust, is found to meet or exceed these sta ndards. Federal requirements are

located in General Preamble for Title I of the Clea n Air Act Amendments of 1990 Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and

Technical Information Document for Best Available C ontrol Measures (EPA-450/2-92- 004).San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-158 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan How does District Rule 8071 compare to rules in oth er 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 s tringent, than other districts’ rules. Comparisons to other air district rules included SC AQMD Rule 1156 (Further

Reductions of Particulate Emissions from Cement Man ufacturing Facilities), SCAQMD Rule 1157 (PM10 Emission Reductions from Aggregate and Related Operations), SMAQMD Rule 403 (Fugitive Dust), VCAPCD Rule 55 (Fu gitive Dust), and Clark County Department of Air Quality (CCDAQ) Section 92 (Fugitive Dust from Unpaved Parking Lots and Storage Areas). BAAQMD does not h ave a comparable rule.

Emission Reduction Opportunities Section 5.2.1 of current rule language requires dus t control measures for any unpaved traffic area with 50 or more annual average daily t rips. Analysis of lowering this threshold to determine if it is a feasible option t o 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 re sult in the requirement that owners and/or operators implement a dust control measure. The most common control measures are watering and covering with gravel. Lo cal cost estimates indicate that installing a 2 inch gravel base with another 2 inch es 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, an d the estimated mitigation costs, requiring control measures for areas with such mini mal 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 201 2 emission inventory. The particulate matter emissions are geological and the inventory is relatively small and consistent throughout the year, with no elevated em ission 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 ove rall 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 commitmen ts for Rule 8071.

Regulatory Action The District’s analysis did not identify any additi onal 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 prog rams specific to this source category at this time.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-159 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Technology Advancement Action There is no recommendation for a new technology adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat may provide for additional emission reduction opportunities in this category.

Policy Initiatives As discussed previously, one of the key dust contro l measures that residents and operators in the Valley rely upon to control fugiti ve dust is wet suppression. Being mindful of this, the District currently supports le gislative measures to provide reliable water supplies to the Valley. While there are no r ecommendations for new policy initiatives the recommendation is to continue suppo rting 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new edu cation 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 Di strict December 20, 2012

D-160 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.6.8 Rule 8081 Agricultural Sources

Source Category Rule 8081 applies to “off-field” agricultural sourc es 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 techniqu es which could be implemented to limit VDE and to comply with the conditions of a stabiliz ed surface.

In 2004, the District adopted amendments to Regulat ion VIII to upgrade existing RACM level rules to meet the more stringent BACM level r equired in serious PM10 nonattainment areas. The amendments added an exemp tion to the rule for vehicle/equipment traffic areas if they are less th an one acre in size and more than one mile from an urban area; expanded rule applicabilit y by updating the vehicle threshold from 75 vehicle daily trips to 50 annual average ve hicle 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 ru les and regulations?

Rule 8081, when compared to EPA rules, regulations, and guidelines that apply to fugitive dust, is found to meet or exceed these sta ndards. Federal requirements are

located in General Preamble for Title I of the Clea n Air Act Amendments of 1990 Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and

Technical Information Document for Best Available C ontrol Measures (EPA-450/2-92- 004).San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-161 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan How does District Rule 8081 compare to rules in oth er air districts?

Rule 8081, when compared to EPA rules, regulations, and guidelines that apply to fugitive dust, is found to meet or exceed these sta ndards. Federal requirements are

located in General Preamble for Title I of the Clea n Air Act Amendments of 1990 Appendix (57 FR 13498, April 16, 1992) and Fugitive Dust Background Document and

Technical Information Document for Best Available C ontrol Measures (EPA-450/2-92- 004).

Emission Reduction Opportunities The District’s analysis did not identify any potent ial opportunities to further reduce emissions from this source category. However, a po tential opportunity to improve enforceability of this for this source category has been identified. Section 5.4 of the rule

references California Vehicle Code section 23112-23 113 for prevention of carryout and trackout. This section could be removed and replac ed with specific language from the vehicle code, however, as previously stated, this a mendment 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 201 2 emission inventory. The particulate matter emissions are geological and the inventory is relatively small and consistent throughout the year, with no elevated em ission 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 ove rall 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 commitmen ts for Rule 8081.

Regulatory Action The District’s analysis did not identify any additi onal 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 subjec t to Rule 8081 at this time.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat may provide for additional emission reduction opportunities in this category.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-162 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Policy Initiatives As discussed previously, one of the key dust contro l measures that residents and operators in the Valley rely upon to control fugiti ve dust is wet suppression. Being mindful of this, the District currently supports le gislative measures to provide reliable water supplies to the Valley. While there are no r ecommendations for new policy initiatives, the recommendation is to continue supp orting 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. No new education and outreach efforts ar e recommended for these sources

at this time. The District will continue to work c losely with affected sources to ensure successful compliance.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-163 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.7 ADDITIONAL SOURCE CATEGORIES

The Valley’s ongoing air quality attainment challen ges require the District to look beyond the successes of its stringent rules and inn ovative incentive programs for further emissions reductions. The following potential contr ol measure source categories and programs represent the District’s continuing effort s to consider and evaluate new and existing sources for potential emissions reductions

.

Through its incentives program and its policy and l egislative platform, the District is able to positively affect emissions reductions from non- regulated sources and sources that are outside of its jurisdiction. These efforts inc lude educational programs and public outreach that encourage fuel and energy savings, fu nding for cleaner-running vehicles and engines, and the support of legislation that im pacts 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 e missions. This analysis will look beyond such efforts at refinements and new technolo gy to potentially obtain additional emissions reductions for each of the source categor ies.

Table D-17 Additional Source Categories Source Categories

SC 001 Lawn and Garden Equipment

SC 002 Energy Efficienc y 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 G rinding 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 redu ce emissions to meet attainment requirements and protect public health. The Distri ct’s longstanding, progressive strategy for reducing emissions is a multifaceted e ffort that includes incentive programs and policy initiatives in addition to prohibitory r ules. The following discussion summarizes existing District efforts to reduce emis sions from sources under this
category.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-164 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Incentive Programs Incentive programs are an integral part of the emis sion reduction efforts of the District, especially where the District lacks direct jurisdic tion in establishing emission control requirements. As a part of the District’s continui ng efforts to reduce emissions from sources through the use of incentive programs, the District has already implemented a successful incentive program aimed at replacing law n 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 pollutin g 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 repla cement of 8,600 gas-powered lawn mowers in the Valley.

Other air districts also have incentive programs fo r lawn and garden equipment. The corresponding programs are generally similar to the District’s residential lawn and garden replacement program, using rebates or hostin g 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. Cur rently, the SCAQMD 2-stroke gas leaf blowers are being replaced with lower emitting 4-stroke equipment.

The availability of zero-emitting or battery powere d lawn equipment has been challenging, especially in the commercial sector du e to the need for a longer battery life and durability to allow for more frequent and prolo nged equipment use. Local operators have previously expressed concerns about the cost a nd reliability of cordless electric equipment, and how this equipment might affect prod uctivity and competition with other operators. In May 2012, the District solicited pro posals from interested equipment manufacturers and vendors to partner with the Distr ict and implement the Cordless Zero-Emission Commercial Lawn and Garden Equipment Demonstration Program (using Assembly Bill 118 funding from ARB). The Di strict finalized a contract with the selected equipment manufacturers and vendors and re leased a Request For Applications in August. The demonstration program has generated significant interest and support from the commercial lawn and garden app licators, which include businesses that provide landscaping services and or ganizations that have their own maintenance team. District staff is currently work ing with 61 participants to complete the contract phase and order the cordless zero-emis sion commercial lawn and garden equipment for the Demonstration Program. Participa nts will begin using the equipment and provide feedback on the performance and durabil ity of the cordless zero-emission commercial lawn and garden equipment. Based on sug gestions from local lawn and garden operators, as a part of the demonstration pr ogram, 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 equip ment becomes more readily available to operators.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-165 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan The District launched an incentive program in early 2012 for alternatives to professionally-managed pyrotechnic fireworks displa ys. The program committed to provide up to 50% of the cost of a laser-light base d display to replace pyrotechnic fireworks displays at existing, annual July 4th eve nts. 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 su pport of several pilot programs examining the potential benefits of providing energ y efficiency tools to Valley manufacturing facilities and other businesses. Ear ly results from this program indicate significant potential opportunities for generating emission reductions from the manufacturing and industrial sectors through the pr omotion 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 Distr ict 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 p olicies and Legislative Platform are important components to the District’s strategy to attain federal ambient air quality standards. The District uses this platform to brin g attention to major issues that impact air quality in the Valley, including energy efficie ncy and clean-energy alternatives and legislation that limits the District’s ability to r egulate the installation and use of woodburning devices in residences.

The District promotes energy efficiency and clean-e nergy alternatives as an additional

means of emissions reductions in areas with well-es tablished, strong regulatory measures on stationary sources, such as in the Vall ey. These extra efforts will help the District attain air quality standards as expeditiou sly as possible. As such, the District supports policies and initiatives that encourage re newable energy and energy efficiency including the following:

• Develop additional biomass capacity using agricult ural waste materials

• Expand net metering and feed-in tariffs for the ut ilization of solar and other renewable energy sources

• Promote energy efficiency for energy end-users tha t will result in lower pollutant

emissions and a more stable electric distribution s ystem

• Encourage and incentivize low-emission technologie s that use waste gas as an alternative to waste-gas venting or flaring.

California Senate Bill (SB) 1468 would allow the sa le of fireworks for the period immediately before New Year’s Eve. Historically, t he 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 Di strict December 20, 2012

D-166 Appendix D: Stationary and Area Source Control Str ategy 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 a llowed in conjunction with the New Year’s Eve celebration, and the usage coincides wit h a stagnation event, Valley residents will likely be exposed to elevated and un healthy particulate matter levels, and will likely result in additional fireplace curtailm ents. Therefore, given the potential for extreme adverse impact to public health, the Distri ct 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 prove n 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 re duce emissions and achieve the attainment of federal air quality standards as expe ditiously as possible.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-167 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.7.1 SC 001 Lawn and Garden Equipment

Source Category This source category includes the commercial and re sidential lawn and garden sectors. The commercial sector includes larger businesses th at employ licensed contractors, public agencies and organizations that maintain the ir own properties or provide landscape services, and small businesses serving re sidential properties. The residential sector of lawn and garden equipment inc ludes equipment purchased by the public for personal use. A survey conducted in 200 3 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 s ector, and 88% in the residential sector. Although there are more pieces of equipmen t used by the residential sector, the survey showed that the commercial sector accounts f or 68% of annual use of all lawn care equipment.

Lawn and garden equipment includes the following: c hainsaws, chippers, commercial turf equipment, front mowers, lawn and garden tract ors, lawn mowers, leaf blowers and vacuums, rear-engine riding mowers, shredders, snow blowers, tillers, trimmers, edgers, brush cutters, wood splitters, and other la wn and garden equipment.

Handheld lawn and garden tools (such as leaf blower s) 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 typ e of engine. Two-stroke engines rely on oil mixed with the gasoline to lubricate th e engine components. Much of this oil is not completely combusted by the engine thus crea ting high exhaust emissions. The major pollutants from a two-stroke engine, for exam ple, are oil-based particulates, PM2.5, NOx, and a mixture of hydrocarbons, which co mbine with other gases in the atmosphere to form ozone, carbon monoxide, and othe r toxic air contaminants. Overall, four-stroke engines emit significantly lower emissi ons than their two-stroke counterparts, with significantly lower levels of hy drocarbons and particulate matter. Lawn care equipment, particularly leaf blowers, can also cause a significant amount of fugitive dust depending on the work practices emplo yed such as blowing on bare dirt or very dusty paved surfaces. These types of activiti es would increase fugitive emissions including PM, toxic air contaminants (TAC) and ultr afine particles (UFP) resulting in a negative health impact on those in proximity to the activity.

Emission Inventory The emissions inventory for lawn care includes exha ust and evaporative emissions from lawn care equipment. Exhaust emissions from lawn c are 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 relativ ely 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 certa in hours of the day.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-168 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 the ir 2003 emissions inventory methodology for lawn care, it is expected that resi dential activity levels for lawn care equipment in the Valley have been underestimated. ARB is currently planning on conducting a survey of California residents to upda te and improve the inventory. Concurrently, the District will be conducting addit ional research to quantify Valleyspecific lawn care activity levels to improve the e missions inventory.

Regulatory Evaluation The District does not currently have any prohibitor y rules specifically addressing lawn care emissions, though the Indirect Source Review ( ISR) rule does account for lawn

care emissions in the model that calculates emissio ns increases from new developments. Providing electric lawn equipment an d incorporating convenient electric charging stations and outlets on the property are c urrently recognized on-site mitigation measures for meeting ISR requirements. The list of on-site mitigation measures could be expanded to include additional landscape measure s such as zero or low-water landscaping. However, the emission reduction benef its would have to be quantified.

The District’s innovative strategies to reduce emis sions 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 out reach efforts to the community. Additionally, in March of 2012 the District hosted a conference on lawn care, landscaping, and air quality to discuss emerging lo w-emission technologies.

How would District SC 001 compare with federal rule s and regulations?

EPA’s small non-road spark-ignition engine rule app lies to engines rated below 25 horsepower, including lawn care equipment. The EPA regulation requires exhaust emission standards by 2011 and 2012 depending on th e class of the engine. New evaporative emission standards for both handheld an d non-handheld equipment include requirements to control fuel tank permeation, fuel line permeation, and diffusion

emissions.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-169 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan ARB also has a rule addressing spark-ignition small off-road engines (SORE) less than 25 horsepower. It was originally adopted in 1990 a nd 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 turno ver 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 guide lines, such as New Source Performance Standards (NSPS), National Emission Sta ndards for Hazardous Air Pollutants (NESHAP), and Maximum Achievable Control Technology (MACT) requirements, for this category. Additionally, the re are no Control Techniques Guidelines (CTG), Alternative Control Technology (A CT), or Best Available Control Technology (BACT) guidelines requiring additional t echnologically feasible controls.

How would District SC 001 compare to rules in other air districts?

SCAQMD adopted Rule 1623 (Credits for Clean Lawn an d 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 p lace at other air districts.

Emission Reduction Opportunities ARB and EPA have regulatory authority over engine s tandards. As described above, the ARB and EPA rules rely on natural turnover and do not push zero emissions technology; therefore, there are still opportunitie s to reduce emissions by closing the emissions gap and accelerating the use of zero emis sions 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 quali ty challenges and the potential benefits, the District may explore in-use regulator y options as a long-term strategy. The District’s analysis of potential opportunities to r educe 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, fu rther study is recommended for the evaluation of the emission inventory and of the res ults from current and future District technology demonstration activities.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-170 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Emerging Technologies There has been recent improvement in the availabili ty 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 equip ment has significantly improved in recent years, the viability of cordless electric te chnology 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, landscap ing, and air quality. The conference highlighted challenges operators face when using lo wer emitting equipment and commercial viability. Local operators expressed co ncerns about the cost and reliability of cordless electric equipment, and how this equipm ent might affect productivity and competition with other operators.

The District is actively pursuing demonstrations of new opportunities through its Technology Advancement Program, including the recen t launch of the Cordless ZeroEmission Commercial Lawn and Garden Equipment Demon stration Program . The program is funded with State Air Quality Improvemen t Program and District program funds and would provide eligible cordless zero-emis sion 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 c ommercial viability through the implementation of this program. Technologies capab le of reducing emissions in the Valley are being demonstrated, and if successful th ese demonstrations may provide an opportunity for the District to develop incentive p rograms to promote these technologies.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-171 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Potential Strategies to Reduce Emissions In evaluating potential control strategies, the Dis trict’s analysis identified a number of potential regulatory and outreach opportunities. H owever, 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 standpoi nt.

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 requ ire operators to implement Best Management Practices (BMPs) using a menu approach f or the use of lawn and garden equipment in the commercial sector. Some examples of potential BMPs include:

• Restrictions near schools and other heavily popula ted areas

• Courtesy practices, e.g. don’t point at people or open windows, don’t blow material onto public roads, sidewalks, or neighbori ng properties

• Particulate prevention practices (no leaf blower u se 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 ch allenging 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 complet e a certification course so that they can be educated on proper work practices. The Dis trict could also require operators to show a certificate of completion to purchase gas eq uipment after a certain date, to ensure contractors operating gas equipment are usin g 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-pollutio n days. There has also been precedence set throughout California with numerous cities and counties adopting ordinances banning or prohibiting the use of leaf b lowers on specified days, times, distances from residential areas, or noise levels. The District could create a model ordinance for cities and counties to adopt througho ut the Valley to limit or prohibit the use of gas equipment and/or leaf blowers. One exam ple was found where the city of Menlo Park prohibited the use of gas equipment on S pare the Air days in the Bay AreaSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

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2012 PM2.5 Plan Air Quality Management District (BAAQMD). This cou ld be an option for future regulatory control in the Valley to reduce emission s, 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 w eek dependent on determined city districts; Residential restricted b y 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 c ould 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 approa ch, known as “greenzoning,” is currently being pioneered in Los Angeles County. G reenzoning could potentially be included as a part of the Healthy Air Living outrea ch program to individual businesses, schools, cities, and counties. A related option co uld 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 adop ted 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 equi pment is limited. This strategy would also be a win-win by reducing noise nuisances in neighborhoods and near schools. The District could provide model ordinanc es to cities and counties to adopt to assist them in implementing this type of measure.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-173 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 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 emissi on inventory. Lawn care emissions can have a potential health impact due to its wides pread use in densely populated urban areas. The use of equipment and resultant em issions are typically more concentrated in areas of schools, parks, and commer cial districts where lawn and garden upkeep require more frequent equipment use f or a longer duration.

Lawn care emissions include criteria pollutants and their precursors, toxic air contaminants from engine emissions and fugitive sou rces, and PM 0.1 (ultrafine particles, or UFP) from engine emissions and work p ractices. As noted in Chapter 2 of this plan, PM 0.1 is a special concern for public h ealth. In 2010, the District entered into a contract with UCSF-Fresno to conduct a pilot char acterization of PM 0.1 and PM2.5 associated with emission plumes from vehicular traf fic, lawn care equipment, and wood combustion in the Fresno/Clovis metro area. The pi lot study found very high PM 0.1 emission concentrations from lawn care engines, ind icating 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 p lumes. 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 conventiona l lawn care equipment and speciate collected PM2.5 samples. The resultant ma ss and chemical species assessment will provide a much more solid assessmen t of the risk facing lawn care workers. It will also help establish a firmer empi rical basis for estimating the contribution of small lawn care engines to ambient concentrations of PM2.5.

Health effects resulting from exhaust emissions, fu gitive dust, and noise generated by lawn equipment range from mild to serious, dependin g on exposure and the sensitivity of the individual exposed. In particular, lawn and landscape operators are exposed to potentially hazardous concentrations of carbon mono xide (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 mo re difficult than for workers because exposures, and reactions to those exposures, are mu ch 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 commerci al buildings whose landscapes are being maintained or serviced, and persons withi n 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 fragm ents, 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 potent ially high intake fraction from this equipment, defined as that fraction of engine emiss ions that are actually inhaled bySan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-174 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan individuals. The timing, proximity, and potency of emissions from lawn care equipment can thus pose a significant health risk to operator s and the public.

Noise from lawn care equipment, especially leaf blo wers, has the potential of causing hearing loss and other adverse health impacts. Whi le the majority of the public is likely exposed to noise as bystanders, given the widesprea d use and the increasing density of cities and towns, there is presently no way of know ing for certain how many are actually exposed, because of the lack of studies. Regulatin g the use of lawn care equipment could prove to be a win-win from an emissions stand point as well as for noise concerns.

Control Measure Commitments The following is a summary of recommended commitmen ts 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 invento ry 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 prog rams 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 equip ment technologies capable of reducing emissions in the V alley as they are being demonstrated as a part of the Cordless Zero-Emissio n Commercial Lawn and Garden Equipment Demonstration Program. The program parti cipants 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 togethe r to complete a final report and submit the findings to ARB. Based on these finding s and feedback from program participants, the District commits to developing mo re incentive program options for commercial operators to assist in deploying zero em issions lawn and garden technologies.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-175 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Technology Advancement Action There are no recommendations for new technology adv ancement programs at this time.

The recommendation is to continue the current techn ology advancement program for cordless zero-emission technologies. In May 2012, the District solicited proposals from interested equipment manufacturers and vendors to p artner with the District and implement the Cordless Zero-Emission Commercial Lawn and Garden E quipment Demonstration Program . The District finalized a contract with the selec ted equipment manufacturers and vendors and released a Request Fo r Applications in August. The demonstration program has generated significant int erest and support from the commercial lawn and garden applicators, which inclu de businesses that provide landscaping services and organizations that have th eir 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 gard en equipment for the Demonstration Program. Participants will begin usi ng the equipment and provide feedback on the performance and durability of the c ordless 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 outre ach 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 source s through the Small Business Assistance program, Permit Stakeholder Meetings, Co mpliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new education and outreach prog rams beyond those that the District currently supports, as discussed above.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-176 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.7.2 SC 002 Energy Efficiency

Source Category This category does not include specific emissions i nventory sources in the Valley, but, rather, the opportunity to reduce emissions from al l Valley sectors through the promotion of energy efficiency and conservation mea sures. Generally, emissions

reductions could be obtained from reductions in ele ctrical power generation or fuel through the implementation of such measures. Poten tial areas of focus include residential and commercial buildings, manufacturing and industrial facilities, agricultural operations, and oil/gas production and processing f acilities.

Emission Reduction Opportunities Energy use is not a regulated activity; however, em issions from the generation of electricity are regulated at the power plant. Over all, electricity generation in California is relatively clean when compared to emission factors (criteria pollutants and greenhouse gases (GHG)) from other states. California has bee n on the forefront of developing renewable energy sources, and has implemented regul ations to ensure cleaner nonrenewable energy. Whereas coal-fired electricity g eneration provides a significant percentage of electricity in other parts of the cou ntry, 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 surr ounding states (2009 data from California Energy Commission (CEC)). The state’s f our major utility companies use this electricity, as well as resources from around the s tate to supply continuous, reliable electricity to its customers. The inter-related na ture of California’s electricity transmission leads to a complex relationship betwee n local energy efficiency programs and emissions reductions. Energy dispatch for need ed demand is time and market dependent; the closest plant does not necessarily s upply 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 othe r highly variable factors.

In 2010, the CEC commissioned an evaluation of ener gy usage and potential reductions from energy efficiency and renewable energy measure s. Using sophisticated dispatch modeling, Synapse Energy Economics Inc. (Synapse) w as able to estimate NOx emissions reductions for renewable energy and energ y efficiency projects within California and within each of the four major utilit y companies. 45 In preliminary model runs, Synapse showed that approximately 45 pounds o f NOx could be reduced for each gigawatt of displaced base load electricity. Likew ise, 76 pounds of NOx could be

45 California Energy Commission. (2011, May). Emission Reductions from Renewable Energy and Energ y Efficiency in California Air Quality Management Districts: Fin al Project Report (Draft). Synapse Energy Economics, Inc. for CEC Public Interest Energy Research (PIER) Program. CEC -XXX-XXX-XXX.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-177 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan reduced for each gigawatt of displaced peak load el ectricity displaced by targeted energy efficiency efforts during peak demand hours.

Recently, EPA released a roadmap manual 46 to assist state, tribal, and local air agencies with quantifying and including emissions r eductions from energy efficiency and renewable energy in State Implementation Plans (SIP s). 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 plannin g process. The complex nature of electricity transmission and dispatch, combined wit h import and export of electricity in and out of the District and California, will requir e sophisticated energy modeling to pinpoint emissions reductions attributable to poten tial 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 w as adopted in January 2010. 47
This policy document identifies the District’s comm itment 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 commitmen ts for SC 002.

Regulatory Action The District’s analysis did not identify any techno logically feasible and cost effective potential controls. Therefore, there are no recomm endations 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 followin g:

• 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 f unding was used to retrofit municipal facilities with lighting and other cost e ffective energy efficiency retrofits;

• The funding of an innovative pilot program to asse ss the potential to operate more efficiently, thus saving money and using less energy; and

46 U.S. Environmental Protection Agency: Incorporatin g Energy Efficiency/Renewable Energy in State and T ribal Implementation Plans. (2012). Retrieved July 10, 20 12 from http://www.epa.gov/airquality/eere/

47 San Joaquin Valley Air Pollution Control District. (2010). Approval of the District’s Regional Energy Efficien cy Strategy . Memorandum to the SJVAPCD Governing Board. Public Hearing, January 21, 2010. http://www.valleyair.org/Board_meetings/GB/agenda_m inutes/Agenda/2010/January/Agenda_Item_7_Jan_21_201 0. pdfSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-178 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan • The funding of an outreach program showing governm ental 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 Va lley.

While there are no recommendations for new incentiv e programs at this time, the recommendation is to continue supporting existing i ncentive programs.

Technology Advancement Action The District’s Technology Advancement Program respo nds 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 cha llenges. Two of the three focus areas for FY 2012–2013 are renewable energy and waste sol utions, which take into account energy efficiency. The recommendation is to contin ue to pursue technology advancement programs that may result in further red ucing emissions in the Valley.

Policy Initiatives Consistent with the District’s 2012 Legislative Pla tform, the recommendation is to continue to work with stakeholders and state agenci es to expand net metering and feedin tariffs for use of solar and other renewable ene rgy sources, promote energy efficiency programs for energy end users that will result in l ower emissions and a more stable electrical distribution system, and develop measure s that incentivize and encourage low-emission technologies for use of waste gas as a n 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. Many of the previously-identified action s and commitments rely heavily on the existing District outreach and communication effort s and will continue with those efforts.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

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2012 PM2.5 Plan 

### D.7.3 SC 003 Fireworks

Source Category This category consists of fireworks sold and/or use d in the Valley. This includes consumer fireworks for home displays as well as pro fessional products for use by licensed operators in public displays.

Emission Inventory The emission inventory for this category has not be en quantified.

Regulatory Evaluation

How would District SC 003 compare with federal or s tate 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 cons umer (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 clas sification of consumer fireworks. Pyrotechnic operators who discharge fireworks in pu blic 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 illega l fireworks.

No federal guidance has been identified for this so urce category under the federal Alternative Control Techniques (ACT), New Source Pe rformance Standards (NSPS),

National Emission Standards for Hazardous Air Pollu tants (NESHAP), Maximum Achievable Control Technology (MACT), and Control T echniques 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 require ments. Additionally, fireworks and fireworks displays and pyrotechnics used for creati on of special effects at theme parks are excluded from the open burning requirements of SCAQMD Rule 444 (Open Burning), and prohibitory Rule 401 (Visible Emissio ns) and Rule 402 (Nuisance) do not exempt fireworks displays.

No references to the use of fireworks or pyrotechni cs for entertainment purposes were
identified for the BAAQMD or the SMAQMD.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-180 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Emission Reduction Opportunities Fireworks usage in the Valley is limited to occasio nal displays at a small number of entertainment venues (minor league sporting events, for example) and Independence Day/July 4 th . On July 4 th , with wide-spread consumer fireworks use, the Vall ey’s air monitors typically show peak PM2.5 concentrations f or several hours on the evening of July 4 th and into July 5 th . These hourly PM2.5 concentrations are much highe r than normal PM2.5 concentrations during the summer, alth ough 24-hour average PM2.5 concentrations on July 4 th and 5 th do not always go above the level of EPA’s standard

. In addition, exceedances of the National Ambient Ai r Quality Standards (NAAQS) due to fireworks qualify as an exceptional event under fed eral regulations and, with proper documentation and EPA concurrence, do not count aga inst an area’s attainment

status. 48 However, the clear relationship between firework s activity and ambient PM2.5 levels; the location of emissions in populated area s; and the fact that the PM2.5 species associated with fireworks are health-impacting meta ls 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 re sidents of the risks associated with firework emissions, and the dangers to sensitive po pulations. Enhancements to future outreach efforts may include partnering with other state and local agencies’ outreach

efforts.

Despite the strong public affinity for July 4 th fireworks, many parts of the country are moving away from pyrotechnic fireworks displays and towards laser light-based shows – particularly in regions with severe drought conditi ons and extreme fire danger. According to the International Laser Display Associ ation, laser-light-based shows are gaining steadily in popularity as more and more com munities are moving in this direction. Several companies in California and thr oughout the country are engaged in the business of incorporating laser-light based sho ws into 4 th of July celebrations.

In spring 2012, the District offered an incentive p rogram to provide up to 50% of the cost of a municipal laser-light based display for existi ng annual 4 th 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 fun d any shows for 2012. The District is interested in reviewing and again providing the pro gram in 2013.

Some fireworks are lower-emitting than others. Dis neyland 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 t he cost and permanent installation.

48 Treatment of Air Quality Monitoring Data Influence d by Exceptional Events, 40 C.F.R. § 50.14 (b)(2), (2011).San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-181 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Risk-based Strategy Analysis The emissions from this source category have not be en quantified. Fireworks displays

and their associated emissions are occasional and o ccur primarily in the summer time. Reducing these emissions will not significantly acc elerate attainment because exceedances of the PM2.5 NAAQS occur during winter months.

However, the PM2.5 species associated with firework s 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 aerosol ized metals used as fuel and coloration, and may cause exposures exceeding occup ational 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 commitmen ts for fireworks.

Regulatory Action Fireworks use is infrequent and isolated to the sum mer 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 incent ive program for municipal laser-light shows to replace fireworks displays in 2012, but du e to timing issues, was not able to fund any shows. Recommendations for incentive acti on are to continue this effort with continued research to make any needed program impro vements, and making the program available again in future years. Another r ecommendation would be to seek partners earlier in the year, and consider sponsori ng shows combining a small amount of fireworks with an otherwise predominantly laser driven show.

Technology Advancement Action There are no recommendations for technology advance ment actions at this time because the technologies discussed already exist an d are in use in some areas. Through its Technology Advancement Program, the Dis trict will continue to seek potential feasible and low-cost technologies that m ay 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., S evranckx, R., D’amours, R., Malo, A., and Brook, J. (2910) Charac terization 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.2010.05.048San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

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2012 PM2.5 Plan Policy Initiatives On August 16, 2012, the District Governing Board vo ted to adopt a position in opposition of California Senate Bill (SB) 1468 (Cal deron), which would have allowed for the sale of safe and sane fireworks during the peri od of December 6 th to January 2 nd 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 conditi ons 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 collecti on and analysis associated with the

bill.

No additional policy initiatives are proposed at th is 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 whe n there are already high particulate

levels.

Education and Outreach The District currently has a robust education and o utreach program, as discussed above, to encourage residents to avoid or reduce co nsumer fireworks use. The

recommendation is to continue current education and outreach activities and possibly seek to partner with local police and fire departme nts in this messaging, since these entities also encourage residents to avoid or limit fireworks use (especially illegal fireworks use). Another recommendation is to gener ate interest in the District’s municipal incentive program by sponsoring a technol ogy demonstration of lasers at a pre-July 4 th public event, such as a minor league sporting even t, and invite staff and public representatives from Valley municipalities w ho might consider laser light shows for their local July 4 th celebrations. Such a demonstration could showcase the laser technology before July 4 th to improve public acceptance of reducing fireworks

.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

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2012 PM2.5 Plan 

### D.7.4 SC 004 Sand and Gravel Operations

Source Category Particulate matter emissions from sand and gravel o perations occur as excavated aggregate material is conveyed, screened, crushed, and stored. This source category is not subject to RACT because this is not a volati le 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 reg ulations?

“EPA promulgated its New Source Performance Standar d (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 p articulate matter (PM) emissions. Subpart OOO of the NSPS standard covers nonmetallic mineral processing, which includes regulations for emissions from operating e quipment that was manufactured, modified or reconstructed after August 31, 1983. NS PS Subpart OOO was further revised on April 28, 2009. Processing equipment reg ulated under Subpart OOO affecting the crushed stone, sand and gravel indust ry includes crushers, grinding mills, screens, bucket elevators, bagging operations, stor age 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), th at apply to the control of particulate matter from sand and gravel operations.

51 National Stone, Sand and Gravel Association: New S ource Performance Standards, Subpart OOO. (2012). Retrieved April 4, 2012 from http://www.nssga.org/e nvironment/nsps.cfmSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

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2012 PM2.5 Plan How would SC 004 compare to rules in other air dist ricts?

SCAQMD Rule 1157 (PM10 Emission Reductions from Agg regate and Related Operations) identifies requirements for general per formance standards; loading, unloading, and transferring; conveyor; crushing equ ipment; screening equipment; storage piles; internal roads; and track-out. Such operations are also covered by SCAQMD Rule 403 (Fugitive Dust), which also identif ies Best Available Control Measures (BACM) applicable to all construction acti vity sources. Other than new source review rules, specific rules were not identified in BAAQMD, SMAQMD, and VCAPCD. As described below, the District has regulated thes e 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 technolog y and achieved-in-practice controls are generally sufficient to limit visible dust emis sions to less than 20 percent opacity as required by District Rule 8011 (General Requirement s for Regulation VIII) and District Rule 4101 (Visible Emissions).

While other districts have specific rules for aggre gate 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, crush ing, screening, and storage), but the

emissions limits are the same as the District’s lim its. 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 Avai lable Control Technology (BACT) requirements, thus requiring operators to apply the best controls to reduce emissions during operational activities including crushing, s creening, 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 201 2 emission inventory. As illustrated in the emission inventory table above, the emission inventory is relatively small and consistent throughout the year, with no elevated em ission 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 commitmen ts for SC 004.

Regulatory Action The District’s analysis did not identify any techno logically feasible and cost effective potential controls. Therefore, there are no recomm endations for regulatory actions.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-185 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Incentive Action

There are no incentive action recommendations for t his sand and gravel operations.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new edu cation and outreach efforts for

these sources.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-186 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.7.5 SC 005 Asphalt/Concrete Operations

Source Category This source category includes emissions from asphal t and concrete production operations. Cement concrete production includes ce ment manufacturing and concrete production. There are only a few cement plants in C alifornia, but none within the Valley. However, many operations contribute to potential em issions associated with concrete production, which include the blending of cement po wder, water, sand, and coarse aggregate. Similarly, there are operations produci ng 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 batc hes. If a cement production plant were to be built within the Valley, it would be rev iewed and evaluated under District Rule 2201 (New and Modified Stationary Source Review) an d would trigger Best Available Control Technology (BACT) requirements for equipmen t 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 reg ulations?

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, Standa rds of Performance for Nonmetallic Mineral Processing Plants, is also appl icable to asphalt and concrete operations. NSPS Subpart I, Standards of Performanc e for Hot Mix Asphalt Facilities, and NSPS Subpart UU, Standards of Performance for A sphalt Processing and Asphalt Roofing Manufacturing, are also applicable to aspha lt operations.

Asphalt processing is also subject to National Emis sion 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).San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-187 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan How would SC 005 compare to rules in other air dist ricts?

SCAQMD Rule 1157 (PM10 Emission Reductions from Agg regate and Related Operations) identifies requirements for general per formance standards; loading, unloading, and transferring; conveyor; crushing equ ipment; screening equipment; storage piles; internal roads; and track-out. Such operations are also covered by SCAQMD Rule 403 (Fugitive Dust) which also identifi es Best Available Control Measures (BACM) applicable to all construction acti vity sources. SCAQMD provides only guidance for minimizing emissions during these activities, but, ultimately, the emissions limits are the same as those being achiev ed under District rules. Similar rules were not identified in BAAQMD, SMAQMD, and VC APCD.

Emission Reduction Opportunities Emissions from concrete production operations and a sphalt concrete operations are minimized by achieved-in-practice controls meeting the opacity requirements of District Rule 4101 (Visible Emissions) and Rule 2201 (New an d Modified Stationary Source Review). For concrete production operations, this technology includes baghouses for screens, crushers, and concrete weight batchers; bi n 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 dryi ng aggregate in the asphalt production process are regulated under District Rule 4309 (Dry ers, Dehydrators, and Ovens), which limits NOx and CO to 4.3 and 42 ppmv, respect ively, for gaseous-fuel fired units.

Specific to asphalt operations, warm-mix asphalt te chnologies show promise in reducing emissions associated with the production of asphalt for paving projects when compared to hot-mix asphalt. Both mechanical (foaming) and a dditive (chemical and organic) technologies “allow the producers of asphalt paveme nt material to lower the temperatures at which the material is mixed and pla ced on the road.” 52 Lower temperatures—50 to 100 degrees Fahrenheit below wha t is necessary for hot-mix asphalt—result in lower fuel consumption, decreased production of greenhouse gases, lower criteria pollutant emissions, and lower fugit ive VOC emissions during application. The amount of emissions reductions is dependent on the additive or process used 53 , 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 r elatively new in the United States. There have been many demonstration projects through out the U.S. and California, and

52 National Asphalt Pavement Association, Warm Mix As phalt Technical Working Group: Warm Mix Asphalt Tak es 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 War m-Mix Asphalt in California. Proceedings, 2 nd International Warm-Mix Conference, St. Louis, Missouri, October 1 1–13. http://www.asphaltpavement.org/big_files/11mwmx/Pap ers/WM19_Jones.pdf

54 MeadWestvaco Corporation [MWV]: Evotherm® Warm Mix Asphalt (2012). http://www.meadwestvaco.com/SpecialtyChemicals/Asph altAdditives/MWV002106San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-188 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan there is ongoing research to evaluate long-term dur ability, to verify emissions reductions, and to develop best practices for the u se of warm-mix asphalt. The California Department of Transportation (Caltrans), in conjunction with the University of California, Davis, has been investigating implement ation issues specific to the use of warm-mix asphalt in California. Caltrans already u ses warm-mix asphalt for projects requiring nighttime work or application in cooler t emperatures. Caltrans has also issued a contractor-permissive specification that allows t he use of warm-mix asphalt for paving projects as conditions and requirements allow. Des pite the general acceptance of warm-mix asphalt technologies by Caltrans, use by l ocal jurisdictions has not been wellreceived; cost and unfamiliarity with the technolog y remain as barriers to technology penetration.

Of the emissions inventory for this category, appro ximately 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 se ason 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 stationar y 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 s mall portion of the Valley inventory and

do not have elevated emission levels in winter mont hs. 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 tox icity.

Control Measure Commitments The following is a summary of recommended commitmen ts for SC 005.

Regulatory Action There are no recommendations for regulatory actions for asphalt and concrete operations. Further study to evaluate the potentia l 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 Di strict December 20, 2012

D-189 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Technology Advancement Action There are no recommendations for new technology adv ancement actions at this time. Through its Technology Advancement Program, the Dis trict will continue to seek potential feasible and low-cost technologies that m ay 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new edu cation and outreach efforts for

these sources.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-190 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### 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 an d 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 a lmond meats are obtained as about 20% of the field weight. Processes for removing th e 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 dou bled 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 sou rce category includes the emissions from the SC 007 (Pistachio Hulling/Shelling Operati ons) 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 reg ulations?

There are no specific federal guidelines applying t o almond hulling/shelling operations in terms of Control Techniques Guidelines (CTG), Alter native Control Techniques (ACT), New Source Performance Standards (NSPS), National E mission Standards for Hazardous Air Pollutants (NESHAP), Best Available C ontrol Technology (BACT), and Maximum Achievable Control Technology (MACT) for th is category.

55 The Tioga Group. (2012). SJV Nut Industry Profile Preliminary Draft. http://www.sjvcogs.org/pdfs/2012/Nut%20Industry%200 30612.pdfSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-191 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan How would SC 006 compare to rules in other air dist ricts?

No rules or Best Available Control Technology (BACT ) guidelines were identified in

other California air districts for this source cate gory. 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 e fforts, and the technologicial feasibility and cost effectiveness of Poly Tetra Fl uoro Ethylene bags.

On-Going Research Efforts Research is currently being conducted by Texas A&M University in partnership with almond harvesting equipment manufacturers, almond f armers, United States Department of Agriculture-Natural Resources Conserv ation Service (USDA-NRCS), and the District to compare “low dust” almond harvester s and an exhaust abatement device to conventional harvesters in the harvesting of alm onds at a Valley farm. No differences were detected in the particle size distribution (PS D) characteristics of PM emitted from each harvester, with the exception of the exhaust a batement device, where large particles were efficiently captured by the cyclone. Emissions of total suspended particulates (TSP) and PM10 trended lower for all n ew 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% reductio n 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 produ ct quality.

Poly Tetra Fluoro Ethylene Bags District BACT guidelines for almond hullers and she llers require the use of a baghouse, which controls PM by moving the contaminated flow o f air through bag type filters. The technology has been achieved in practice in the Dis trict. 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, mem brane type bags treated with Poly Tetra Fluoro Ethylene (PTFE) contain extremely smal l 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 polyest er 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 polyeste r 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 Technolo gy 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 Offi ce of Air Quality Planning and Standards.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-192 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan so there should not be a significant increase in el ectrical costs by using one bag over another. Additionally, existing baghouses would no t require modifications to accommodate PTFE bags so the increased cost lies so lely in the cost of the bags. A PTFE bag typically costs $23, whereas a polyester b ag 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 u p 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% cont rol 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 f rom 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/t on PM2.5 reduced.

Although the initial annual capital cost may seem r elatively low; in terms of cost effectiveness, PTFE bags are not a cost effective a lternative to standard bags. TheSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-193 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan additional control efficiency gains are in the frac tions 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 em issions 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 wi th polyester bags, the technology primarily provides PM10 control. Additionally, cyc lones typically achieve 80-85% control efficiency. Approximately 37 facilities in the Val ley use cyclones to control PM emissions. Therefore, if these facilities were req uired to replace cyclones with baghouses, the cost effectiveness would be as follo ws:

Potential PM2.5 Emission Reductions for replacing c yclones with Baghouses with

PTFE

The PM2.5 control efficiency for cyclones is assume d 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 cos ts of installation, electrical system upgrades, ductwork, demolition or disposal of the c yclone. Therefore, replacing cyclones with baghouses is not a cost effective con trol option. As previously stated, theSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-194 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan emission inventory used in these calculations (0.08 1 tons/day PM2.5) includes the emissions of both almond hulling and pistachio hull ing, meaning the actual inventory is smaller, and making the actual cost effectiveness e ven 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 inclu de 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 wint er PM2.5 emitted from stationary and area sources in the 2012 emission inventory. A s illustrated in the emission inventory table above, the emissions from this sour ce 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 ar e of low relative toxicity.

Control Measure Commitments The following is a summary of recommended commitmen ts for SC 006.

Regulatory Action The District’s analysis did not identify any techno logically feasible and cost effective potential controls. Therefore, there are no recomm endations 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 in centive programs for almond hulling activities at this time. One potential opp ortunity 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 incen tive program would be unlikely due to the high cost effectiveness and low emission s reductions.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat 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 Di strict December 20, 2012

D-195 Appendix D: Stationary and Area Source Control Str ategy 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new edu cation and outreach efforts for

these sources.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-196 Appendix D: Stationary and Area Source Control Str ategy 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 op erations are permitted together under the same permit with the pistachio receiving and pr e-cleaning portions of the operation. These operations use 1D-3D cyclones to control PM e missions 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 neg ligible. 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 producti on looks like it will continue to

increase in the near future. 58 In the interest of identifying every possible str ategy to reduce PM2.5 emissions, pistachio hulling and shell ing operations were evaluated for potential opportunities to reduce emissions, see th e discussion below.

Emission Inventory The emission inventory for this category is include d 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 combin ed inventory.

Regulatory Evaluation

How would SC 007 compare with federal rules and reg ulations? There are no specific federal guidelines applying t o pistachio hulling/shelling operations in terms of New Source Performance Standards (NSPS) , Control Techniques Guidelines (CTG), Alternative Control Technology (A CT), Maximum Achievable Control Technology (MACT) and National Emission Standards f or 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 dist ricts? This source category was compared to other air dist ricts in California including SCAQMD, BAAQMD, SMAQMD, and VCAPCD; no rules were i dentified 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%200 30612.pdfSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-197 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Emission Reduction Opportunities Pistachio shelling operations are served by a bagho use, which is the industry standard for shelling operations. While there is no specifi c 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/Shelli ng 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 Hullin g/Shelling Operations) for the cost effectiveness analysis.

Unlike almonds which are shaken on the ground and v acuumed off the soil during harvesting, pistachios are caught with a canvas cat cher before they hit the ground, which allows for a very small amount of dust and de bris in addition to the pistachios. Much of the PM emissions associated with the proces sing 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 redu ction regulatory strategies for this
source category.

Risk-based Strategy Analysis The PM2.5 emissions from this source category inclu de 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 e missions from this source category are relatively small throughout the year, with peak emissions occurring in summer months. Additionally, the emissions are geologic i n nature, and, as described in Chapter 2, do not contribute significantly during t he peak winter season, and are of low relative toxicity.

Control Measure Commitments The following is a summary of recommended commitmen ts for SC 007.

Regulatory Action The District’s analysis did not identify any techno logically feasible and cost effective potential controls. Therefore, there are no recomm endations 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 in centive program specific to pistachio hulling activities. One potential opport unity 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 incen tive program would be unlikely due to the high cost effectiveness and low emission s reductions.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-198 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Technology Advancement Action There is no recommendation for a new technology adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new edu cation and outreach efforts for

these sources.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-199 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.7.8 SC 008 Agricultural Material Screening/Shakin g Operations

Source Category This control measure source category would be appli cable to the handling and processing of agricultural materials in biomass, co mposting, and other agricultural material handling facilities.

Emission Inventory The emission inventory for this category is account ed for in other control measure source categories. Refer to Appendix B for the emi ssion inventory.

Regulatory Evaluation

How would SC 008 compare with federal rules and reg ulations?

There are no applicable federal standards and guide lines, such as Control Techniques Guidelines (CTG), Alternative Control Techniques (A CT), New Source Performance Standards (NSPS), National Emission Standards for H azardous Air Pollutants (NESHAP), and Maximum Achievable Control Technology (MACT) for this source category. EPA Best Available Control Technology (B ACT) requirements were also evaluated for potential opportunities; however no s tandards were listed for this category.

How would SC 008 compare to rules in other air dist ricts?

SCAQMD Rule 1131.1 (Chipping and Grinding Activitie s) is the only rule in California identified to be applicable to agricultural materia l screening and shaking operations. Rule 1133.1 contains provisions to ensure that gree nwaste is chipped or ground and used within 48 hours to prevent inadvertent decompo sition. Biomass facilities are exempt from most requirements if the material tempe rature 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 orga nic compound (VOC) emissions rather than NOx or PM2.5. District analysis did not ident ify similar rules, regulated categories, or BACT requirements at BAAQMD and SCAQMD.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-200 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Emission Reduction Opportunities District analysis of potential emission reduction o pportunities includes an evaluation of feasibility of wet suppression systems and enclosin g conveyors and transfer points.

Wet Suppression System A wet suppression system can achieve between 40-65% control of PM2.5 59 . In a wet suppression system, water is generally applied to a ll 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 con trol is currently in use at all identified facilities in the Valley and would be re quired 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 th e emissions of PM is a practice used in addition to water spray at seven facilities in t he Valley. This control option would potentially reduce emissions at the drop or transfe r points on the conveyors. However, in addition to the control efficiency of enclosed c onveyors being unknown, conveyors are already operated so that they move very slowly to avoid entraining dust and limit visible emissions. Therefore, the potential to red uce emissions is minimal and reduced emissions would not be quantifiable.

At this time, the District’s analysis indicates tha t 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 account ed 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 significa ntly 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 commitmen ts for SC 008.

Regulatory Action The District’s analysis did not identify any techno logically feasible and cost effective potential controls. Therefore, there are no recomm endations for regulatory actions.

59 Environmental Protection Agency [EPA]. (1995). Compilation of Air Pollutant Emission Factors, Tabl e B.2-3. Research Triangle Park, NC.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-201 Appendix D: Stationary and Area Source Control Str ategy 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 adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat 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 c ontrol of these operations.

Education and Outreach The District currently provides a robust education and outreach program for regulated sources through the Small Business Assistance progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new edu cation and outreach efforts for

these sources.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-202 Appendix D: Stationary and Area Source Control Str ategy 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 trans portable, 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 powe r and is exempt from District permits since it is considered to be mobile equipme nt. The diesel engines powering the transportable units are subject to District Rule 47 02 (Internal Combustion Engines) and Best Available Control Technology (BACT) Guideline 3.2.11. This control measure source category discussion addresses the particulat e matter (PM) emissions from the loading, grinding, and conveying of the process mat erials.

Emission Inventory Emissions generated by the engines of the tub grind ers are accounted for as a part of the inventory for District Rule 4702 (Internal Comb ustion Engines). The fugitive particulate emissions from these units are accounte d for as a part of the stationary and area inventory. See Appendix B.

Regulatory Evaluation

How would SC 009 compare with federal rules and reg ulations?

There are no specific federal guidelines applying t o wood chipping and stump grinding operations in terms of New Source Performance Stand ards (NSPS), National Emission

Standards for Hazardous Air Pollutants (NESHAP), Maximum Achievable Control Technology (MACT), Control Techniques Guidelines (C TG) or Alternative Control Techniques (ACT) for this category.

How would SC 009 compare to rules in other air dist ricts?

Upon comparing this source category to other Califo rnia 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 t o maintain the material temperature below 122 degrees Fahrenheit and the moisture conte nt to less than 30%; however, these limits are targeted at controlling volatile o rganic compound (VOC) emissions rather than NOx or PM2.5. Portable chipping and gr inding, agricultural chipping and grinding, land clearing chipping and grinding, wood waste chipping and grinding, and palm chipping and grinding activities are exempt fr om Rule 1133.1

. AnalysisSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-203 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan determined that no other air district regulates thi s source category. Air districts analyzed include BAAQMD, SMAQMD, and VCAPCD.

Emission Reduction Opportunities No technologically feasible or alternative basic eq uipment are identified in the District’s Best Available Control Technology (BACT) guidelines

.

Currently, fugitive particulate emissions from tran sportable and self-propelled tub grinders are controlled with a water sprinkler syst em during loading, grinding, and unloading of the process materials to prevent visib le emissions in excess of 5% opacity per Rule 2201 (New Source Review) and BACT guidelin e 6.4.2. Water sprinkler systems achieve between 40-65% control of PM2.5 60 . It is standard practice to use water spray on this type of equipment to meet the v isible emission requirements of Rule 4101 (Visible Emissions); therefore, requiring wate r 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 bag house 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 feasib le for a transportable unit.

Risk-based Strategy Analysis The emissions from this source category are account ed 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 en gines 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 th at 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 significa ntly during the peak winter season, and are of low relative toxicity.

Control Measure Commitments The following is a summary of recommended commitmen ts for SC 009.

Regulatory Action The District’s analysis did not identify any techno logically feasible and cost effective potential controls. Therefore, there are no recomm endations for regulatory actions.

60 Environmental Protection Agency [EPA]. (1995). Compilation of Air Pollutant Emission Factors, Tabl e B.2-3. Research Triangle Park, NC.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-204 Appendix D: Stationary and Area Source Control Str ategy 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 gri nders at this time. The District analysis did not identify new technologies that cou ld potentially reduce emissions from this source category.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat 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 ar e no recommendations for new policy initiatives for PM control of tub grinding o perations.

Education and Outreach The District currently provides a robust education and outreach program for regulated sources through the Small Business Assistance progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new edu cation and outreach efforts for

these sources.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-205 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan 

### D.7.10 SC 010 Abrasive Blasting

Source Category Abrasive blasting involves the cleaning or preparin g 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 ty pe of surface or application. Abrasive materials commonly used are walnut shells, various mineral or metal products, garnet, sand or aggregate, slag, steel grit abrasiv e, 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 reg ulations?

EPA promulgated management practices, and monitorin g, recordkeeping, and reporting requirements for dry abrasive blasting within 40 CF R 63, Subpart XXXXXX–National

Emission Standards for Hazardous Air Pollutants Are a Source Standards for Nine Metal Fabrication and Finishing Source Categories.

Air pollution standards for abrasive blasting opera tions, 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 t hat no air district regulation can

be stricter than the state standard. The state sta ndard 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 dist ricts?

No rule from another air district has requirements beyond what is already required in state standards. BAAQMD Regulation 12, Rule 4 (San dblasting), 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 Di strict December 20, 2012

D-206 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan Emission Reduction Opportunities Achieved-in-practice Best Available Control Technol ogy (BACT) controls for sandblasting include baghouses, filters, or cartrid ge dust collectors. With such technologies, 99% control efficiency can be achieve d. As emissions sources, sandblasting operations within the District are sub ject to District Rule 4102 (Nuisance) and the standards of 17 California Code of Regulati ons (CCR) Section 92200 (opacity) and 17 CCR Section 92500 (performance standards suc h as CARB-certified abrasives).

Opportunities for further emissions reductions are limited because of the CH&SC stipulation that air districts cannot impose strict er rules on sandblasting operations. The District’s analysis has determined that there are n o 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 201 2 emission inventory. As illustrated in the emission inventory table above, the emission s 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 commi tments for SC 010.

Regulatory Action The District’s analysis did not identify any techno logically feasible and cost effective potential controls. Therefore, there are no recomm endations for regulatory actions.

Incentive Action The District does not currently have an incentive p rogram specific to abrasive blasting operations. There is no recommendation for a new i ncentive program for abrasive blasting operations at this time.

Technology Advancement Action There is no recommendation for a new technology adv ancement project for this source category. Through its Technology Advancement Progr am, the District will continue to seek potential feasible and low-cost technologies t hat 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 ini tiatives for these sources.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-207 Appendix D: Stationary and Area Source Control Str ategy 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 progr am, Permit Stakeholder Meetings, Compliance Assistance Bulletins, and public notices for public workshops and public hearings. There are no recommendations for new edu cation and outreach efforts for

these sources.San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-208 Appendix D: Stationary and Area Source Control Str ategy 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, an d 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 emis sions for each rule. Those respective percentages are applied to the combined inventory to get the individual emission i nventories.

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, an d 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 emis sions for each rule. Those respective percentages are applied to theSan Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-209 Appendix D: Stationary and Area Source Control Str ategy 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 in ventory. 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, an d 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 emis sions 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;650-650-5400-0 000;

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 610-608-0110-0000San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-210 Appendix D: Stationary and Area Source Control Str ategy 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 Unpav ed 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 conta in emissions data on unpaved vehicle and equipment tra ffic

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 Di strict December 20, 2012

D-211 Appendix D: Stationary and Area Source Control Str ategy 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;

430-428-7090-0000San Joaquin Valley Unified Air Pollution Control Di strict December 20, 2012

D-212 Appendix D: Stationary and Area Source Control Str ategy Evaluation

2012 PM2.5 Plan This page intentionally blank.