State of California
AIR RESOURCES BOARD

State Office Building
455 Golden Gate Avenue - Room 1194
San Francisco, CA

October 25, 1978
10:00 a.m.
AGENDA
Page

78-19-1 Approval of Minutes of September 27, 1978 001

78-19-2 Public Hearing for Consideration of Adopting Sulfur 005
Dioxide Emission Regulations for the Bay Area Air Pollution
Control District

78-19-3 Continuation of a Public Hearing for Reconsideration of 173
Air Resources Board Regulation Limiting the Sulfur Content
of Unleaded Gasoline Sold in California

78-19-4 Other Business -
a. Executive Session - Personnel & Litigation
b. Research Proposals 353
c. Delegation of Authority to the Executive Officer
to Review And Comment on Nonattainment Plans

ITEM NO.: 78-19-2

Public Hearing for Consideration of Adopting Sulfur Dioxide
Emissions Regulations for the Bay Area Air Pollution Control
District.

RECOMMENDATION

The staff recommends that the Board adopt Resolution 78-51
revising Sections 3121 through 3123.9 of the Bay Area Air
Pollution Control District's Regulation 2.

SUMMARY

The California Health and Safety Code requires air pollution
control districts, including the Bay Area Air Pollution Control
District (BAAPCD), to adopt rules and regulations which assure
that reasonable provision is made to achieve and maintain all
applicable ambient air quality standards. Such standards for
sulfur dioxide (SO2), sulfate, total suspended particulate matter
(TSP), and visibility reducing particles have been established.

Under the provisions of Regulation 2 of the BAAPCD, sources of
SO2 emissions are required to emit no more than 300 ppm unless
they establish a ground level monitoring network to assure that
certain ambient concentrations of SO2 are not exceeded. If these
sources establish such networks, they are allowed to emit up to
6,000 ppm of SO2. The SO2 emissions from the ten sources that
emit more than 300 ppm account for 107 tons per day or
approximately 49 percent of the total inventory of SO2 emissions
in the BAAPCD.

Sulfur dioxide emissions from sulfur recovery units and sulfuric
acid plants are estimated to be 65.7 tons per day or about 61
percent of the emissions from sources that operate under the
ground level monitoring provisions of Regulation 2 of the BAAPCD.

These emissions contribute to violations of the SO2 and TSP
ambient air quality standards in the San Francisco Bay Area Air
Basin and to violations of the TSP standard in the San Joaquin
Valley Air Basin.

The staff has proposed changes to Regulation 2 of the BAAPCD that
would significantly reduce the SO2 emissions emanating from
sulfur recovery units and sulfuric acid plants. Specifically,
SO2 limits of 150 ppm or 4 pounds per short ton of sulfur
produced (whichever is more restrictive) and 300 ppm or 5 pounds
per short ton of sulfuric acid produced (whichever is more
restrictive) have been proposed for sulfur recovery units and
sulfuric acid plants, respectively.

The technology to reduce SO2 emissions from these two source
types is currently available. Flue gas desulfurization systems
on sulfur recovery units can attain the proposed SO2 limits. One
such system (the Beavon-Stretford) is currently installed on
Union Oil's sulfur recovery unit in Rodeo. Control of SO2
emissions from sulfuric acid plants can be achieved through
further reaction of sulfur to sulfuric acid through the use of a
double absorption process. Allied Chemical's plant in Richmond
currently uses this process and attains a 300 ppm limit. Some
modifications are necessary, however, if a 5 pounds per short ton
of sulfuric acid produces is to be met.

Implementation of the proposed modifications to Sections 3121
through 3123.9 of Regulation 2 of the BAAPCD will result in an
emissions reduction of 58.6 tons of SO2 per day or approximately
42 percent of the estimated needed emissions reductions to attain
and maintain applicable ambient air quality standards. The
proposed revisions will also limit SO2 emissions from fluid
catalytic crackers, fluid cokers, and coke calcining kilns to
approximately their current levels, thus ensuring that the
emissions from these sources are not allowed to increase.
Control of SO2 emissions from these sources is currently being
investigated; source specific strategies, if feasible, will be
proposed at a later time.

Further information is needed before specific requirements for
the installation of monitors on refinery flares can be
established.

Table of Contents

Page

I. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

II. Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3

III. Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . .5

IV. Discussion of Proposed Rules. . . . . . . . . . . . . . . . . . . . 18
A. Air Resources Board Staff Proposal . . . . . . . . . . . . . . 18
B. Estimated Emission Reductions. . . . . . . . . . . . . . . . . 26
C. Bay Area Staff Proposal. . . . . . . . . . . . . . . . . . . . 29

V. Emissions and Ambient Air Quality . . . . . . . . . . . . . . . . . 31
A. Current Emissions. . . . . . . . . . . . . . . . . . . . . . . 31
B. Current Air Quality. . . . . . . . . . . . . . . . . . . . . . 31
1. San Francisco Bay Area Air Basin. . . . . . . . . . . . . 31
2. San Joaquin Valley Air Basin. . . . . . . . . . . . . . . 36
C. Projected Emissions. . . . . . . . . . . . . . . . . . . . . . 38
D. Future Air Quality . . . . . . . . . . . . . . . . . . . . . . 44
1. San Francisco Bay Area Air Basin. . . . . . . . . . . . . 44
2. San Joaquin Valley Air Basin. . . . . . . . . . . . . . . 44

VI. Sulfur Dioxide Controls in the Bay Area . . . . . . . . . . . . . . 45
A. Current Sulfur Dioxide Regulation. . . . . . . . . . . . . . . 45
B. Background . . . . . . . . . . . . . . . . . . . . . . . . . . 45

VII. Attaining and Maintaining Ambient Air Quality Standards . . . . . . 51
A. Reductions Needed. . . . . . . . . . . . . . . . . . . . . . . 51
B. Legal Authority to Adopt Rules . . . . . . . . . . . . . . . . 54

VIII. Control Strategy for Sulfur Dioxide Emissions. . . . . . . . . 57
A. Sulfur Recovery Plants . . . . . . . . . . . . . . . . . . . . 58
1. Process Description . . . . . . . . . . . . . . . . . . . 58
2. Available Control Technology. . . . . . . . . . . . . . . 61
a. Beavon-Stretford Process . . . . . . . . . . . . . . 61
b. SCOT Process . . . . . . . . . . . . . . . . . . . . 62
c. Wellman-Lord Process . . . . . . . . . . . . . . . . 62
d. IFP Process. . . . . . . . . . . . . . . . . . . . . 63
B. Sulfuric Acid Plants . . . . . . . . . . . . . . . . . . . . . 63
1. Process Description . . . . . . . . . . . . . . . . . . . 63
2. Available Control Technology. . . . . . . . . . . . . . . 64

IX. Environmental Impacts . . . . . . . . . . . . . . . . . . . . . . . 66
A. Water. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66
B. Solid Waste. . . . . . . . . . . . . . . . . . . . . . . . . . 67
C. Natural Resources. . . . . . . . . . . . . . . . . . . . . . . 68
D. Other Impacts. . . . . . . . . . . . . . . . . . . . . . . . . 68

X. Economics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68
A. General. . . . . . . . . . . . . . . . . . . . . . . . . . . . 68
B. Comparison of Necessary Air Pollution Expenditures to Total. . 71
Company Expenditures

XI. Bibliography. . . . . . . . . . . . . . . . . . . . . . . . . . . . 73

Appendices

Page

Appendix A - Petition and Subsequent Correspondence from Sierra. . . .A-1
Club, Citizens for a Better Environment, and Friends
of the Earth.

Appendix B - Current Sulfur Dioxide Rules in the Bay Area Air. . . . .B-1
Pollution Control District.

Appendix C - Correspondence between Air Resource Board staff . . . . .C-1
and Bay Area Air Pollution Control district concerning
sulfur dioxide rules.

Appendix D - Proposed Sulfur Dioxide Rules in the Bay Area Air . . . .D-1
Pollution Control District.

List of Tables and Figure

Table IV-1: Anticipated Effect of Proposed Regulation on. . . . . . . 28
Sulfur Recovery Units and Sulfuric Acid Plants

Table V-1: Sulfur Dioxide Emissions in the San Francisco Bay
Area Air Basin in 1975. . . . . . . . . . . . . . . . . . 32

Table V-2: Summary of Sulfur Dioxide Emissions and Current . . . . . 33
Controls on Sulfur Recovery Units and Sulfuric Acid
Plants in the San Francisco Bay Area Air Basin

Figure V-1: Sulfur Dioxide Emissions, San Francisco Bay Area
Air Basin . . . . . . . . . . . . . . . . . . . . . . . . 39

Table V-3: Projected Sulfur Dioxide Emissions in the San . . . . . . 40
Francisco Bay Area Air Basin for 1980, 1985, 1990,
and 1995

Table V-4: Comparison of BAAPCD and ARB Sulfur Dioxide . . . . . . . 43
Emissions Projections for Selected Categories for 1980,
1985, 1990, and 1995

Table VI-1: Summary of Regulation 2 . . . . . . . . . . . . . . . . . 46

Table VII-1: Average Daily Sulfur dioxide Emissions of Sources . . . . 52
Conducting Ground Level Monitoring in the BAAPCD

Table X-1: Estimated costs to Meet Proposed Sulfur Dioxide
Regulation. . . . . . . . . . . . . . . . . . . . . . . . 69

Table X-2: Average Capital Expenditures for Affected
Companies . . . . . . . . . . . . . . . . . . . . . . . . 72

ITEM NO'S.: 78-19-3 and 78-16-3

Public Hearing for Reconsideration of Air Resources Board
Regulation Limiting the Sulfur Content of Unleaded Gasoline Sold
in California.

RECOMMENDATION

Adopt Resolution 78-45, thereby amending Section 2252 of Title 13
of the California Administrative Code. The amended Section 2252
would continue the existing schedule for reduction of the sulfur
content of unleaded gasolines (currently 400 parts per million,
and 300 ppm after January 1, 1980) sold at retail in the South
Coast Air Basin, in the Counties of Ventura, Santa Barbara, San
Luis Obispo, Kern, San Diego and Imperial, and in those portions
of the Counties of San Bernardino, Los Angeles and Riverside not
within the boundaries of the South Coast Air Basin. Section 2252
as amended would truncate the existing schedule at the current
sulfur content limit for unleaded gasoline (400 parts per
million) in all other areas of the state.

SUMMARY

On June 30, 1975, the air Resources Board adopted Resoluiton 75-
33 effecting the following schedule of limitaions on the sulfur
content of unleaded gasoline sold at retail in California.

Maximum Sulfur Content
(Parts per Million by Weight) Effective Date of Limitation
500 January 1, 1976
400 January 1, 1978
300 January 1, 1980

On November 30, 1977, the Western Oil and Gas Association
petitioned the Board to reconsider and to repeal Resolution 75-
33. The petition contends that the Board adopted the resolution
on insufficient grounds and in response to predictions by the
environmental Protection Agency of dangerous levels of sulfuric
acid emissions from automobiles equipped with catalytic
converters. The sulfate levels predicted by EPA have not been
experienced.

During 1977, the California ambient air quality standard for
sulfates was violated in the South Coast Air Basin on an
estimated 91 days, and there were 20 sulfate episodes (i.e.,
oxidant level of .20 ppm or more concurrent with a sulfates
standard violation) during that year. The California ambient air
quality standard for sulfur dioxide was violated in the South
Coast air Basin on 13 days in 1977.

Analyses show that, in order for six key air monitoring stations
in the South coast Air Basin (SCAB) to record compliance with the
24-hour state sulfate standard at all times, sulfur oxides
emissions which were experienced in 1973 would have to be reduced
by 75 percent. Analyses also show that, by 1990, sulfur dioxide
emissions from automobiles in the SCAB will be reduced to about
25.8 tons per day if the sulfur in gasoline regulation remains in
effect, whereas such emissions could reach about 86 tons per day
in the absence of the regulation. Additionally, direct emissions
of sulfuric acid or sulfates from catalysts would add
substantially to the ambient sulfate concentration.

From these analyses, it is concluded that no relaxation of the
scheduled sulfur content limit of 300 ppm for unleaded gasolines
should be allowed in the South Coast Air Shed or in neighboring
counties where gasoline destined for consumption in that air shed
could be purchased.

Retention of the present regulation is needed in the San Diego
Air Basin to maintain the California air quality standard for
sulfate, since concentrations close to the standard have occurred
recently. Violation of the sulfate standard by a wide margin in
Kern County requires that SOx emissions be kept to a low level
there.

Sulfur oxide emissions-related air quality is considerably better
in the northern portion of the state than in the South Coast Air
Basin and the relative contribution of gasoline to total sulfur
oxides emissions is smaller. If high emissions of sulfate from
exhaust catalysts do not occur, acceptable air quality can be
achieved in most of the northern portion of California without
limiting the sulfur content of unleaded gasoline 300 ppm. In
view of the potential impact of direct emissions of sulfuric acid
or other sulfates from exhaust catalysts, however, the sulfur
content of unleaded gasoline should not be allowed to rise above
400 ppm. In addition, truncation of the present regulation at
400 ppm in the San Francisco Bay Area air Basin is advised only
if new controls are implemented there to reduce emissions of
sulfur oxides from industrial sources.

Limited data on the costs of retaining the regulation for
u