# APPENDIX B

Emission Reduction Analysis for Amendments to Rule 4308 (Boilers, Steam Generators, and Process H eaters -

0.075 MMBtu/hr to less than 2.0 MMBtu/hr)

December 17, 2009SAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis for Rule 43 08 December 17, 2009

B-2
Final Staff Report with Appendices

For A mendments to Rule 4308 (This page is intentionally blank)SAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis for Rule 43 08 December 17, 2009

B-3
Final Staff Report with Appendices

For A mendments to Rule 4308 ESTIMATED EMISSIONS REDUCTIONS FROM BOILERS, STEAM

GENERATORS, AND PROCESS HEATERS –

0.075 MMBtu/hr to less than 2.0 MMBtu/hr

I. SUMMARY

The District estimated in its 2008 PM2.5 Plan that the 2009 emissions baseline is 3.59 tons per day (tpd) of NOx and 3.3 tpd of SOx a re emitted in the SJVAB from this source category. The new estimated NOx emissio ns and emissions

reduction are summarized in Table B-1 and detailed in Section III.

Table B-1 Summary of Baseline Emissions and Emissio n Reductions

Size (MMBtu/hr) Baseline NOx (tpd) NOx

Reductions (tpd) Percent Reductions

> 0.075 but < 0.4 1.03 0.77 75%

> 0.4 but < 2.0 2.36 2.0 85%

Total 3.39 2.77 82%

II. CALCULATION METHODOLOGY

A. Data Source

District staff gathered data from stakeholders, man ufacturers and the SCAQMD to determine emission capacity factors, emission ra tes, average unit size and unit population. District staff extrapolated data from the SCAQMD’s staff report on Rule 1146.2 (2007) to estimate the number of units located in the SJVAB.

The SJVAPCD sent out a survey to try to gather info rmation on the number of units in this size category. However, only 50% of s urveys were returned, and most of them did not contain any information on the number of units for this size category. Therefore, District staff calculated the population-to-unit ratio, using information from Bay Area and South Coast staff rep orts, in order to derive the number and size of units needed to support the huma n population in the SJVAB. District staff found that for every 350 people ther e is one unit in the size range of 0.075 MMBtu/hr to 0.4 MMBtu/hr and that for every 7 50 people there is one unit in the size range of greater than 0.4 MMBtu/hr to l ess than 2.0 MMBtu/hr. Multiplying the Valley’s estimated population of 4. 2 million people (in 2010) by the population-to-unit ratios, District staff estim ated the unit inventory shown in

Table B-2.SAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis for Rule 43 08 December 17, 2009

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Final Staff Report with Appendices

For A mendments to Rule 4308 District staff also used the average emission rates derived by the SCAQMD to calculate the baseline emissions for this category. In South Coast’s implementation studies for Rule 1146.2 the average emission rate was110 ppm (0.136 lb NOx/MMBtu) for units in this size categor y. This accounts for units that are considerably older and also for ones that have not had continual maintenance and upkeep.

A capacity factor of 0.22 was used to develop basel ine emissions. The capacity factor was derived by the SCAQMD and BAAQMD and rep resents the fraction of fuel actually burned or consumed by the unit in a y ear compared to the

theoretical maximum amount of fuel that a unit coul d use in a year. A 0.22 capacity factor was determined from the statistical survey conducted by the South Coast AQMD and was developed from unit operat ion and fuel usage information provided in that survey. Bay Area AQMD used information from the local gas company and surveys to users to determine the typical usage for these

units.

B. Assumptions for the Emissions Reductions Analysi s

District staff used the unit population, the emissi on rates and capacity factor to

calculate the estimated NOx reductions that would b e achieved upon the compliance of the draft rule requirements. Because of a lack of input and data, District staff has assumed certain specifications t o perform the cost effectiveness analysis. More information from stakeholders and ot her organizations would help to improve the analysis in future staff reports. T he following are some of the assumptions that were made:

1. In order to account for the worst case scenario, District staff assumed the units operated 24 hours a day. 2. A 0.22 capacity factor was assumed based on Sout h Coast Rule 1146.2

information. 3. An average rating was applied to the two size ca tegories since the number of units is assumed to be distributed evenly. For example, for the larger unit category, the calculation was (0.4 + 2.0) ÷ 2 = 1.2 MMBtu/hr.

4. The emissions rate is still the same as what Sou th Coast Implementation Study found a few years ago. Table B-2: Estimated Number of Units For the SJVAB Based on Population Total Inventory of Units 17,600 Inventory > 0.075 but < 0.4 12,000 Inventory > 0.4 but < 2.0 5,600SAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis for Rule 43 08 December 17, 2009

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Final Staff Report with Appendices

For A mendments to Rule 4308 C. Baseline Emissions

Equations 1 and 2 below show the calculations to es timate baseline emissions. The methodology for the equations is also given. T he number of units is based on the population-to-unit ratio shown in Table B-2. The average rating used in the

calculations is based on the mean value of the two different size categories. Also, an emissions rating of 0.136 lbs NOx/MMBtu was used in order to have a

conservative estimate of baseline emissions and is based on SCAQMD’s Implementation Studies for Rule 1146.2 results.

Equation 1
- Emissions for Units 0.075 MMBtu/hr - < 0.4 MMBtu/hr

Emissions = (No. of units) x (average rating) x (em ission rate) x (capacity factor) x (hours/day) x (ton/lb)

Emissions = 12,000 x 0.238 MMBtu/hr x 0.136 lb NOx/ MMBtu x 0.22 x 24 hr/day x 1 ton/2,000 lb

Emissions = 1.03 tons NOx/day

Equation 2
- Emissions for Units > 0.4 MMBtu/hr - < 2.0 MMBtu/hr

Emissions = (No. of units) x (average rating) x (em ission rate) x (capacity factor) x (hours/day) x (ton/lb)

Emissions = 5,600 x 1.2 MMBtu/hr x 0.136 lb NOx/MMB tu x 0.22 x 24 hr/day x 1 ton/2,000 lb

Emissions = 2.36 tons NOx/day

The total baseline emission inventory of 3.39 (1.03 + 2.36) tons NOx per day tpd is estimated for this proposed rule.

III. EMISSION REDUCTION CALCULATIONS

Using the rule limits for PUC-gas fired units < 0.4 MMBtu/hr and units > 0.4 MMBtu/hr and their associated capacity factor and b aseline emissions, the

emissions reduction can be estimated as follows:

Emissions Reductions =



###      

× × × ∆ × × lb tons

day hrs factor capacity limits emissions category for units of rating mean Units of No.SAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis for Rule 43 08 December 17, 2009

B-6
Final Staff Report with Appendices

For A mendments to Rule 4308 For the number of units, District staff continued t o use the population-to-unit ratio estimates. The average rating is the mean between t he lowest and highest size units for that category. As of yet, District staff still does not have information on the number of units to know how better to weigh the average rating for the categories. The change in emissions is from the cu rrent rule requirement to the proposed emission limits. District staff estimated the number of typical units to be

80% and the number of instantaneous water heaters a nd pool heaters to be 20% of the total estimated number for this category. Th e District staff is looking for further stakeholder input on what percentage of uni ts in the SJVAB are used in these tankless water heater and typical units categ ories.

A. TOTAL EMISSIONS REDUCTIONS IN TPD

The daily emissions reductions that are calculated below estimate the total emissions reductions achieved after full implementa tion of the rule. Because this rule is a point of sale rule, these reductions will be achieved over a 20 year period.

1) Units ≥ 0.075 MMBtu/hr to < 0.4 MMBtu/hr:

Emissions Reductions =

day tons 0.67

= 1 Reductions Emissions lbs 2,000 ton 1 day hr 24 0.22 MMBtu lb 0.0247)

- (0.136 MMBtu 0.238 9,600

× × ×      

× ×

Emissions Reductions for Instantaneous and Pool Hea ters =

day tons 0.10

= 1 Reductions Emissions lbs 2,000 ton 1 day hr 24 0.22 MMBtu lb 0.068)

- (0.136 MMBtu 0.238 2,400

× × ×      

× ×

Total Emission Reductions for this Size Category = 0.77 tpdSAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis for Rule 43 08 December 17, 2009

B-7
Final Staff Report with Appendices

For A mendments to Rule 4308 2) Units > 0.4 MMBtu/hr to < 2.0 MMBtu/hr:

Because the emission limits for Instantaneous Water heaters and Pool heaters for this size category are the same as othe r units, there is no need for a separate emission calculation.

Emissions Reductions =

day tons 2.0 = 2 Reductions Emissions lbs 2,000 ton 1 day hrs 24 0.22 MMBtu lb

* .0247) 0

- (0.136 MMBtu 1.2 5,600

× × ×      

× ×

Total Emission Reductions for this Size Category = 2.0 tpd

The emissions reductions from 0.075 -0.4 and the 0. 4 – 2.0 need to be added together for the total expected emissions reduction s from this rule.

Total Emissions Reduction for Both Size Categories = 2.77 tpd

B. ANNUAL EMISSIONS REDUCTIONS

District staff then took this emission reductions i nformation to calculate the emissions reductions on a yearly basis. The number of units is based on how many units should be replaced each year in the diff erent size categories. 17,600 units will be replaced over 20 years comes out to 8 82 units per year. Of the 882 units, 68% should be 0.075 - 0.4(small units) and 3 2% should be 0.4 - 2.0 (large units).These calculations will show how many reduct ions can be expected on a yearly basis, spread over a 20 year period because of the useful life of a typical

unit.

1) For Units ≥ 0.075 MMBtu/hr to < 0.4 MMBtu/hr: Emissions Reductions for Regular Units =

year tons 12.3

= 1 Reductions Emissions year 1 days 365

x lbs 2,000 ton 1 day hr 24 0.22 MMBtu lb 0.0247)

- (0.136 MMBtu 0.238 year x per units 480

× × ×      

×SAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis for Rule 43 08 December 17, 2009

B-8
Final Staff Report with Appendices

For A mendments to Rule 4308 Emissions Reductions for Instantaneous and Pool Hea ters =

year tons 2.0

= 1 Reductions Emissions year 1 days 365

x lbs 2,000 ton 1 day hr 24 0.22 MMBtu lb 0.068)

- (0.136 MMBtu 0.238 year per units 120

× × ×      

× ×

Total Emissions for this Size Category = 15.3 tpy

2) For Units > 0.4 MMBtu/hr to < 2.0 MMBtu/hr:

day tons 36.3 = 2 Reductions Emissions year 1 days 365

x lbs 2,000 ton 1 day hrs 24 0.22 MMBtu lb

* .0247) 0

- (0.136 MMBtu 1.2 year per units 282

× × ×      

× ×

Total Emissions for this Size Category = 36.3 tpy

The emissions reductions from 0.075 -0.4 and the 0. 4 – 2.0 size category need to be added together for the total expected emissions reductions from this rule.

Total Emissions Reduction for Both Size Categories = 51.6 tpy

C. EMISSIONS REDUCTIONS FOR ATTRITION RULE

District staff then took the total emissions reduct ions on a yearly basis and converted it to tons per day per unit. This annual amount of reductions should happen in a linear fashion over the 20 year period, because of older unit replacement with lower polluting units.

51.6 tpy x 1 year/365 day = 0.141 tpd each year ove r a 20 year period

Total Emissions Reduction for Both Size Categories = 0.141 tpd each year for 20 yearsSAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis for Rule 43 08 December 17, 2009

B-9
Final Staff Report with Appendices

For A mendments to Rule 4308 The emission reductions will be over a 20 year peri od, so the expected total emissions reductions of 2.77 tpd, calculated in Sec tion III A, should be achieved by 2031. Table B-3 shows how this rule will still meet the District’s plan

commitments for NOx emissions reductions.

IV. OTHER

The District expects there to be a desire to replac e old units with newer units because many of the new, lower-emitting units are a lso fuel and energy efficient. Many of these units actually give the location an e nergy savings from older units. As more advanced technology become more readily ava ilable, more emissions reductions may occur from this rule.

B-3: Emissions Reductions Plan Commitment

Year for Reductions Plan Commitment (annual avg) Rule Emission

Reductions 2011 0.12 tpd 0.14 tpd 2012 0.27 tpd 0.28 tpd 2013 0.39 tpd 0.42 tpd 2014 0.55 tpd 0.56 tpdSAN JOAQUIN UNIFIED VALLEY AIR POLLUTION CONTROL DI STRICT

Appendix B: Emission Reduction Analysis for Rule 43 08 December 17, 2009

B-10
Final Staff Report with Appendices

For A mendments to Rule 4308 (This page is intentionally blank)