State of California
AIR RESOURCES BOARD
Piccadilly Inn
2305 West Shaw Avenue
Regency Room
Fresno, CA
March 23, 1979
10:00 a.m.
AGENDA
Page
79-7-1 Public Hearing to Consider the Adoption of a. . . . . . . . . 001
Regulation Controlling Emissions of Sulfur Compounds from
Steam Generators Used in Oil Field Operations in the kern
County Air Pollution Control District
Continuation of Public Hearing to Consider the Adoption
of the Nonattainment Plans for Each County in the San Joaquin
Air Basin and for Mariposa County as Revisions to the State of
California Implementation Plan for the Attainment
and Maintenance of National Ambient Air Quality
Standards:
79-6-4 * Kern County (Sulfur Dioxide)
79-7-2 Other Business
a. Executive Session - Personnel & Litigation
b. Research Proposals
c. Delegations to the Executive Officer
ITEM NO.: 79-7-1
Public Hearing to Consider Adoption of a Regulation Controlling
Emissions of Sulfur Compounds from Steam Generators Used in
Oilfield Operations in the Kern County Air Pollution Control
District.
RECOMMENDATION
Adopt Resolution 79-10, thereby adopting into the regulations of
the Kern County Air Pollution Control district Rule 424 which
would control emissions of sulfur compounds from steam generators
used in oilfield operations in the district.
SUMMARY
In 1978, sulfur oxides emissions from oilfield steam generators
in Kern County caused the California 24-hour air quality standard
for sulfur dioxide to be exceeded on 45 days and the California
sulfate standard on 28 days. The maximum 24-hour sulfur dioxide
and sulfate concentrations were 0.142 ppm and 80.5 ug/m3
respectively which are about three times the California
standards. In addition, the national 24-hour sulfur dioxide
standard of 0.14 ppm was exceeded. The annual average of 87
ug/m3 exceeded the national standard of 80 ug/m3. Sulfur oxides
emissions also contributed to the large violations of the
California and National standards for total suspended
particulate. Sulfates are also highly effective in reducing
visibility. The California standard for visibility is exceeded
about 36 percent of applicable days at Bakersfield.
The Board discussed the problem in Kern County on January 26,
1978, when the permit problem in kern County was reviewed and on
April 26, 1978, when the Board approved, in principle, a model
rule to control nitrogen oxides and sulfur oxides emissions from
steam generators in Kern County.
The staff has made numerous verbal and written requests to Kern
County Air Pollution Control District to adopt rules to control
sulfur oxides emissions. However, these requests have been
ignored and the last sulfur oxides nonattainment plan of Kern
County maintains that no further controls on sulfur oxides
emissions are required. It is the staff's conclusion that the
Kern County Air Pollution Control District will not take
satisfactory action, and therefore, the Board must take such
action.
A review of Kern County Air Pollution Control District permit
files on December 14, 1978, showed that there were 817 permits to
operate issued for oilfield steam generators and there were
permits pending on an additional 468 steam generators. Emissions
from the 817 steam generators are estimated to be 252 tons per
day (TPD) and the permit-pending steam generators would add additional
54 TPD, for a total of 306 TPD.
The amounts of emissions reduction would be required in programs
to achieve the various air quality standards are:
Standard Reduction Needed
California 24-hour SO2 65%
California 24-hour sulfate 69%
National 24-hour TSP* 50%
National AGM** TSP 64%
California 24-hour TSP 85%
California AGM TSP 76%
* Total suspended particulate
** Annual geometric mean
The proposed model rule is designed to reduce emissions from
oilfield steam generators to 64 percent of estimated 1978 levels,
if all steam generators for which permits have been made were put
into operation. Emissions from existing generators without
scrubbers would be limited to 0.12 pounds of sulfur per million
Btu of heat input effective January 2, 1982. Emissions from new
steam generators would be limited to 0.058 pounds of sulfur per
million Btu of heat input, effective immediately. Steam
generators designated to be replaced by a cogeneration facility
would be exempted if timely applications were made for the
cogeneration facility.
Capital cost of the proposed rule is estimated to be 75 million
dollars. Cost-effectiveness is estimated to be $0.28 per pounds
of sulfur dioxide reduced. Cost per barrel of oil produces
(assuming 4 net barrels produced per barrel burned) would be
$0.42.
Environmental impacts other than an improvement in air quality
would be increased use of water and production of solid waste.
Staff analysis shows that associated water from oil production
will probably more than offset scrubber needs. Sufficient waste
disposal site capacity exists to receive solid waste for the next
7 or 8 years, and new sites are possible.
Lower tier low gravity oil is price-controlled at about $4.40 per
barrel and upper tier oil at about $8.30. Therefore, cost of
controls could be about 5 to 10 percent of the selling price of
the oil. However, the U.S. Department of Energy (DOE) has the
authority to increase the controlled price to compensate
producers for any increased cost. DOE should be urged to take
appropriate action if the Board adopts the regulation.
State of California
AIR RESOURCES BOARD
Staff Report 79-7-1
Table of Contents
Page
I. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . .1
II. Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6
III. Emissions from Steam Generators and Associated Combustion
Devices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
IV. Ambient air Quality . . . . . . . . . . . . . . . . . . . . . . . . 31
A. Meteorology. . . . . . . . . . . . . . . . . . . . . . . . . . 31
B. Air Monitoring sites . . . . . . . . . . . . . . . . . . . . . 35
C. Ambient Air Quality. . . . . . . . . . . . . . . . . . . . . . 39
V. Amount of Reduction in Emissions Required to Achieve Air
Quality Standards . . . . . . . . . . . . . . . . . . . . . . . . . 58
VI. The Proposed Rule . . . . . . . . . . . . . . . . . . . . . . . . . 63
A. Emission Limitations . . . . . . . . . . . . . . . . . . . . . 63
B. Compliance Schedule. . . . . . . . . . . . . . . . . . . . . . 64
C. Definition of Steam Generator or Boiler. . . . . . . . . . . . 65
D. Averaging of Emissions . . . . . . . . . . . . . . . . . . . . 65
E. Exemption of Cogeneration Units. . . . . . . . . . . . . . . . 66
VII. Methods of Controlling Emissions. . . . . . . . . . . . . . . . . . 73
VIII.Impacts of the Proposed Rule. . . . . . . . . . . . . . . . . . . . 80
A. Environmental Impacts. . . . . . . . . . . . . . . . . . . . . 80
B. Economic Impact. . . . . . . . . . . . . . . . . . . . . . . . 82
IX. Recommendation. . . . . . . . . . . . . . . . . . . . . . . . . . . 87
Appendix A - Correspondence. . . . . . . . . . . . . . . . . . . . . . .A-1
Appendix B- Bibliography . . . . . . . . . . . . . . . . . . . . . . . .B-1
Appendix C - Hearing Notice. . . . . . . . . . . . . . . . . . . . . . .C-1
Appendix D - Estimate of the Cost of Flue Gas Desulfurization. . . . . .D-1
Appendix E - Sulfate Data. . . . . . . . . . . . . . . . . . . . . . . .E-1