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