State of California
AIR RESOURCES BOARD
Jack Tar Hotel
Van Ness and Geary Streets
El Dorado Room*
San Francisco, CA
December 20, 1977
77-27-1 Public Hearing to Consider Amendments to Regulation 2, 1
Division 13, of the Bay Area Air Pollution Control District
(New Source Review).
77-27-2 Status Report Regarding Investigation of Sulfur Dioxide 109
Emissions from the Exxon Company, USA, Benicia Refinery.
77-27-3 Status Report Regarding the San Francisco Air Quality 162
77-27-4 Other Business -
a. Executive Session - Personnel & Litigation
b. Research Proposals
*Note: Room changed subsequent to notices being sent out.
ITEM NO.: 77-27-1
Public Hearing to Review and Consider Amendment or Adoption of
New Source Review Rules for the Bay Area Air Pollution Control
Approve Resolution 77-53, thereby amending the aspects of the
District's Rules and Regulations that pertain to new source
review as shown in the attachment to the resolution or as may be
amended by the Board.
Both state and national ambient air quality standards are
frequently violated in the San Francisco Bay Area Air Basin.
Emission projections show that during the next 10 to 15 years,
stationary sources will be responsible for increasing fractions
of the total emissions of most pollutants. Regulation of
increases in emissions as a result of the construction of new
stationary sources is essential for attaining and maintaining the
standards in the District. However, the Bay Area air Pollution
Control District's existing new source review rules have a number
of serious defects.
The proposed amendments: change the definition of stationary
source to include all emissions associated with a facility or
operation, establish definitive criteria to identify sources
subject to new source review, add a requirement that best
available control technology be employed for new and modified
sources, establish provisions by which authority may be granted
for the construction of new sources if resulting increases in
emissions are offset by decreases in emissions from existing
sources, provide for additional exemptions, and improve various
In December 1976 the EPA promulgated an Interpretative Ruling for
implementation of the requirements of 40 CFR 51.18 (new source
review). In 1977, the State Legislature adopted Assembly
Concurrent Resolution 19 and Senate Concurrent Resolution 17
directing the Board to review all districts' New Source Review
rules for consistency and effectiveness and to seek amendments
where necessary, particularly with regard to emission offset
policies. A review of the Bay Area Air Pollution Control
District's existing new source review rules shows that they are
inconsistent with both State and federal new source review
The proposed amendments are based on Rule 213 et seq. as adopted
in October 1976 by the ARB for the South Coast Air Quality
The ARB staff has held a number of meetings with the District
staff to discuss changes to the district's current new source
review rules. The ARB staff has also attended several meetings
of a subcommittee of the District Advisory Council to comment on
district proposals to amend the current new source review rules
and to recodify all of the District's Rules and Regulations
including the new source review rules. A September 8, 1977
letter from the Executive Officer to the District detailed
suggested changes to a District staff proposal. However, neither
the Advisory Council nor the District Board has taken any action
to amend the existing rules.
Implementation of the proposed amendments to the rules will have
a beneficial impact on the air quality of the region and should
have little, if any, adverse impact on other aspects of the
environment such as water quality or solid waste disposal. It is
expected that only minor economic impacts will result from the
adoption of these amendments. Similar rules have been in
existence in the South Coast Air Basin for over a year, and no
significant adverse economic impacts have been found to occur as
a result of those rules.
ITEM NO.: 77-27-2
Investigation of Sulfur Dioxide Emissions from the Exxon Company,
USA, Benicia Refinery.
a) That the Board schedule a public hearing to consider
assuming the powers of the Bay Area Air Pollution Control
District (BAAPCD) to enforce Section 3123 on a source
operation basis, as provided for by Section 3214.1.
b) That the Board schedule a public hearing to determine
whether grounds exist to revise Section 3123 to provide for
lower, Best Available Control Technology sulfur dioxide
emission limits, and to specify a shorter averaging time for
c) That the BAAPCD should install continuous sulfur dioxide
monitors at its San Francisco and Burlingame air monitoring
stations since these are the areas of maximum ambient
concentrations of sulfur dioxide in the air basin.
The Exxon Benicia Refinery is the largest stationary source of
sulfur dioxide in the San Francisco Bay Area, contributing nearly
one-fifth of all sulfur dioxide emitted in the Basin. The
exhaust gases from two sulfur recovery units, a catalytic cracker
and a fluid coker are manifolded into the main stack and
discharged into the atmosphere.
Recently, the Air Resources Board (ARB) staff conducted five
source tests on the main stack complex.
The tests were conducted to determine the compliance status of
the SO2 sources at the refinery and to use the results as an aid
in evaluating the BAAPCD's rules and enforcement practices.
The tests showed that while emissions from the main stack were in
compliance with the applicable regulations of the BAAPCD;
emissions from the sulfur recovery units (SRUs), were found to be
far in excess of the District's sulfur dioxide limitation.
Unlike most sulfur recovery operations in the State, the units at
Exxon lack tail gas desulfurization devices.
Previous source tests conducted by the BAAPCD staff have found
main stack SO2 emission levels up to 61.7 tons per day, almost
twice as much as found by the ARB staff.
The State SO2 standard was exceeded in December 1976 at the
downtown San Francisco monitoring station and was associated with
airflow from the northeast, across the District's major
industrial areas including Benicia. Continuous SO2 monitoring is
needed in San Francisco and Burlingame to determine if additional
high SO2 levels or excesses of the State Standard are occurring
in these areas.
Furthermore, recent ARB sponsored research indicates the
emissions generated in the Bay Area may intrude into the San
Joaquin Valley. Exxon's SO2 emissions alone are twice the
current SO2 emission inventory of the northern San Joaquin
Valley. Given the time which elapses between the release of SO2
from Exxon's refinery and the arrival of these pollutants into
the San Joaquin Valley, it is likely that a portion of the SO2 is
converted to sulfate which contributes to violations of the
ambient air quality standards for total suspended particulate
Section 3122 of BAAPCD's Regulation 2, permits a source to emit
concentrations of SO2 up to 300 ppm. However, a source may
choose as an option to Section 3122 to comply with Section 3123
which permits maximum SO2 emissions of 6000 ppm averaged over a
24-hour period if ambient air quality measurements, made outside
the source property boundaries, do no exceed ground level
concentrations specified in Section 3121. Exxon has chosen the
option of complying with Section 3123. However, this rule is so
lenient that Exxon could emit over 200 tons per day of SO2 from
the main stack and still meet the limit of 6000 ppm.
Section 3214.1 of Regulation 2 requires that if air contaminants
from two or more source operations are combined prior to
emission, and if there are adequate and reliable means for
establishing a separation of the components of the combined
emissions so as to indicate the nature and quantity of emissions
arising from each individual source operation, the provisions of
Regulation 2 should apply to each such source operation
separately. Based on recent source tests, we believe that Exxon
is in violation of Section 3123 when Section 3214.1 is applied.
The BAAPCD interprets the rule differently and disagrees with us.
The ARB staff has reached the following conclusions:
1) The SRUs at Exxon's Benicia refinery are in violation of the
provisions of Section 3123 as amplified by Section 3214.1.
2) The BAAPCD is misinterpreting Sections 3214.1 and 3123.
3) Exxon could bring the SRUs into compliance and easily reduce
the SRU SO2 emissions to 150 ppm or less with the available
tail gas desulfurization devices commonly used today.
4) Revision of Section 3123 to specify a lower limit for
existing SRUs seems feasible. The ARB staff believes that
an SO2 limit of 150 ppm and 60 pounds per hour, averaged
over 15 consecutive minutes, is achievable. Based on our
source test of the SRU at Union Oil in Rodeo, sulfur dioxide
emissions could be controlled to less than three ppm and
0.18 pounds per hour.
ITEM NO.: 77-27-3
Bay Area Air Quality Maintenance Planning Progress Report.
This is a three part report. It is presented to the Board as a
status report on the progress of the Bay Area Air Quality
Maintenance Plan (AQMP). Part I is a statewide overview of the
AQMP which begun in 1974. The AQMP structure in California, with
minor modifications, complies with the basic Clean Air Act
Amendment requirements for nonattainment planning. In each of
the designated AQMAs, ARB and a local agency have been jointly
designated and are currently developing a plan. After approval
by ARB, each AQMP will be submitted to EPA as a SIP revision.
Part II briefly describes the Bay Area AQMP and its development.
The Environmental Management Task Force, a subcommittee of ABAG
that is composed of locally elected officials, representatives of
industry, and other interest groups, is responsible for policy
direction of the AQMP. ABAG, Bay Area Air Pollution Control
District, and Metropolitan Transportation Commission provide the
working staff for the Joint Technical Staff for the development
of the AQMP. In February 1977, the ARB designated itself and
ABAG as co-responsible for the development of the AQMP. The
draft AQMP is scheduled to be published this month. The regional
adoption will take place between February and April 1978. It is
anticipated that the AQMP will be submitted to ARB in May 1978
and to EPA by October 31, 1978.
Part II of this report includes the strategies currently being
proposed, and the issues raised by those strategies. The draft
plan contains a variety of stationary source control measures,
mobile source control measures, transportation control measures,
and development and land use management measures as strategy
options for the AQMP. The ARB staff has supported the inclusion
of all feasible land use management and transportation control
measures in the development of AQMPs.
Part III of this report includes some of the technical support
detail for the issues raised in Part II. 1975 is used as a base
year for air quality, emissions, and all projections. The
analysis of existing air quality in the Bay Area shows that
photochemical oxidant, carbon monoxide, and total suspended
particulates violate the federal standards in some or all of the
region. The technical foundation of the plan and the basis for
strategy selection and analysis is determined in part by the
techniques used to project future air quality. The forecasting
system consists of three primary components: the ABAG Series 3
populations; housing; employment and land use modeling system;
the MTC travel model system; and the BAAPCD's LIRAQ and Larsen
air quality models.