State of California AIR RESOURCES BOARD Bakersfield Inn Palm Room 1101 Union Avenue Bakersfield, CA November 28, 1979 10:00 a.m. AGENDA PAGE 79-27-1 Public Hearing to Consider Amendments to the Rules and . . . .001 Regulations of the Kern County Air Pollution Control District. a. Hydrocarbon Control Rules b. Status of NOx Control for Steam Generators and. . . . . .121 Availability Of NOx Trade-offs in Kern County c. Rule 202 and Rule 210.1 79-27-2 Other Business 1. Delegations to the Executive Officer 2. Executive Session Personnel Litigation ITEM NO.: 79-27-1a Public Hearing to Consider Amendments to the Rules and Regulations of Kern County Air Pollution Control District At the public hearings held in Bakersfield on September 7 and September 12, 1979, the Air Resources Board considered proposed amendments to the rules and regulations of the Kern County Air Pollution Control District. The ARB staff concerns about a number of District rules and regulations are discussed in ARB staff report 79-20-2, which is Attachment A to this report. On September 12, 1979, the ARB adopted Resolution 79-68 (Attachment B), which, among other actions, requested the Kern County Air Pollution Control Officer to propose to the District changes in these rules. The changes are in response to concerns raised in the ARB staff report 79-20-2. The ARB Executive Officer was to review the changes adopted by the district board, and if he found that substantial deficiencies remain in the rules, he was directed to issue a notice for a hearing before the Board. The November 28, 1979, hearing on this issue was notice in light of the uncertainty surrounding the expected date and scope of action to be taken by the Kern County Air Pollution Control District in response to Resolution 79-68. The ARB staff has been informed by the District staff that a hearing has been scheduled for November 27, 1979, to consider changes to the rules to satisfy the Air Resources Board's concerns. Depending on the action taken by the Kern County Air Pollution Control District, the ARB staff may retain the recommendations to the Board contained in staff report 79-20-2 or may recommend cancellation of the hearing on all or some of the rules. ITEM NO.: 79-27-1b Status of NOx Control for Steam Generators and Availability of NOx Trade-offs in Kern County SUMMARY At its September 12, 1979 public hearing, the Board requested that the staff prepare a status report describing: 1. The NOx emission inventory of current, approved, and pending (as of September 12, 1979) Thermally Enhanced Oil Recovery (TEOR) projects in Kern County; 2. The control technology which is available now (Best Available Control Technology) and that which is expected to be available in the future to mitigate NOx emissions increases; and 3. The potential for growth in TEOR operations as related to the need to prevent significant NOx emissions increases pursuant to Kern County Air Pollution Control District New Source Review Rules 210.1 and 210.2. In response to the Board's request, the staff investigated each of the above issues. The principal staff conclusions resulting from this investigation are: 1. Unless proper mitigation is required, significant increases in NOx emissions are expected to result from approval by the Kern County Air Pollution Control district of pending (as of September 12, 1979) applications for authority to construct (A/C) TEOR equipment, as well as from recent approvals for such equipment; 2. NOx emission control technologies, including combustion process modifications and selective noncatalytic reduction, have been demonstrated and are currently available at costs of under $.40 per net barrel of crude oil produced. Such emission controls have been required for some TEOR steam generators by the Kern County Air Pollution Control District and the Fresno County Air Pollution Control District and have been agreed to by major producers; and 3. With the application of Best Available Control Technology (BACT), sufficient direct NOx emission offsets are available in Kern County to allow TEOR operations to more than double in the near term compared to 1979 production levels. Consideration of other control options, such as interprecursor trade- offs, permit revisions, and gas-firing credits, is expected to allow an increase in TEOR operations, in the near term, to a level of about three and one-half times the 1979 level. This is equivalent to an increase in crude oil production of about 620,000 BBL/day. The staff recommends that the Board reaffirm its September 12, 1979, action, to amend Kern County Air Pollution Control District's (KCAPCD) New Source Review (NSR) Rule and to clarify the stationary source definition as shown in Attachment VIII-A to the staff's report. Furthermore, the staff recommends that Kern County District Rule 202(f) be amended to delete the exemption for gas-fired equipment as shown in Attachment VIII-E. TABLE OF CONTENTS Page Acknowledgment I. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . .3 II. Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5 III. Thermally Enhanced Oil Recovery NOx Emission Inventory. . . . . . . 13 A. Status of Permits. . . . . . . . . . . . . . . . . . . . . . . 13 B. Summary of NOx Emissions . . . . . . . . . . . . . . . . . . . 21 IV. NOx Control Technology Assessment . . . . . . . . . . . . . . . . . 26 A. Combustion Process Modification. . . . . . . . . . . . . . . . 28 B. Flue Gas Treatment . . . . . . . . . . . . . . . . . . . . . . 43 C. Technology Assessment Summary. . . . . . . . . . . . . . . . . 57 V. New Source Review . . . . . . . . . . . . . . . . . . . . . . . . . 63 A. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . 63 B. Availability of Offsets Under Current NSR Rule . . . . . . . . 65 C. Options for Board Consideration. . . . . . . . . . . . . . . . 80 D. Stationary Source Definition . . . . . . . . . . . . . . . . .82a VI. Conclusions and Recommendations . . . . . . . . . . . . . . . . . . 83 VII. References. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85 VIII. Attachments. . . . . . . . . . . . . . . . . . . . . . . . . . . . 88