BOARD MEETING DATE: December 3, 2004
AGENDA NO. 39

Staff Recommendations Regarding Controlling Emissions from Restaurant Operations

SYNOPSIS:

Control Measure PRC-03 – Emission Reductions from Restaurant Operations in the 2003 AQMP estimated reductions of 1 ton per day of PM₁₀ by 2010. Cost-effective controls for the majority of under-fired charbroilers have not been developed. This action is to recommend that the Board make findings of infeasibility, and substitute emission reductions from other adopted rules, as required by the 2003 AQMP. Staff is also recommending funding for demonstration projects.

COMMITTEE:

Stationary Source, September 24, 2004

RECOMMENDATION:

1. Make findings of infeasibility;
    
2. Approve substitution of emission reductions; and
    
3. Approve in concept up to eight new or retrofit demonstration projects for a total amount not to exceed $200,000 from the Rule 1309.1 – Priority Reserve Fund.

Barry R. Wallerstein, D.Env.
Executive Officer

Introduction

This report is presented to the Board as an update on the status of rule development efforts for reducing PM₁₀ emissions from restaurants operating under-fired charbroilers. At the March 2001 Board meeting, staff reported that cost-effective solutions for reducing emissions from under-fired charbroilers were limited. Currently, this remains the situation.

The continuing effort to identify cost-effective controls for this source category has been ongoing since 1991. Based on the approach described in this Board letter, staff is recommending that the Board make findings of infeasibility. The 2003 AQMP notes that if a stationary source control measure is deemed infeasible, the District is allowed to substitute with other measures, provided the overall equivalent emission reductions (by adoption and implementation dates) are maintained. Staff is also no longer recommending a rule (i.e., PR 1138.1) that would require PM₁₀ reductions from existing restaurants operating under-fired charbroilers. As described below, other rules adopted by the Board have achieved more reductions than the AQMP commitment and can be substituted for this control measure.

Background

Restaurants operations emit PM₁₀ and VOCs. Both of these pollutants can cause adverse health impacts, as well as being a potential nuisance to the local community. Restaurant operations include charbroilers, griddles, deep fat fryers, ovens, and other equipment. The total inventory is approximately 11.6 tons/day PM₁₀ and 1.6 tons/day VOC.

The 1997 AQMP contained Control Measure PRC-03 - Emission Reductions from Restaurant Operations. Rule 1138, adopted in November 1997, implemented Phase I of this control measure, reducing 0.5 ton/day of PM₁₀ emissions from chain-driven charbroilers. Under-fired charbroilers are the largest contributor to the PM₁₀ inventory contributing approximately eighty-three percent. Griddles account for approximately five percent of the total PM restaurant emissions inventory and four percent of the total VOC emissions. Oven emissions appear to be negligible. Based on the contribution of emissions from under-fired charbroilers, they were chosen as the next logical piece of basic equipment for which to seek cost-effective controls. As a result, The 1999 Amendment to the 1997 Ozone State Implementation Plan for the South Coast Air Basin listed PRC-03 – Emission Reductions from Restaurant Operations – Phase II, with reductions of 0.9 tons/day VOC and 7.0 tons/day of PM₁₀.

The Board received a report on emerging control technologies for under-fired charbroilers in May 1999. This report pointed out that a continuing effort to find cost-effective and technologically feasible controls for the restaurant industry has been ongoing since 1991. The earlier phases of this effort included the investment of significant resources in improving test methods and developing emission factors.

In August 2000, staff reported that cost-effective controls were limited and recommended substituting the remaining 0.9 tons/day of VOC emissions assigned to this source category when another control measure achieving excess VOC emission reductions was adopted in 2000 or early 2001. The 0.9 tons/day of VOC emissions from PRC-03 were to have been achieved by the year 2010. The Board accepted this proposal of substitution. The 2003 AQMP credits a substitution of emissions from Rule 461 – Gasoline Transfer and Dispensing, amended April 2000. On this basis, PM₁₀ is the only pollutant subject to further reductions from this source (restaurant operations) to meet AQMP commitments.

Controlling PM Emissions from Under-fired Charbroilers

Over the last thirteen years, the AQMD and various stakeholders have been seeking to identify cost-effective technologies controlling PM emissions from under-fired charbroilers. The number of cost-effective solutions for reducing emissions from under-fired charbroilers is still limited at this time. To date, two technologies have emerged as potentially cost-effective solutions. The first technology is a replacement of under-fired charbroilers with a Smokless™ broiler. This broiler is commercially available and is in use by approximately seventy restaurants in the United States. The Smokless™ broiler is not a control device but rather basic equipment similar to an under-fired charbroiler. It is not a direct-flame cooker and it may result in a meat product that differs in appearance and/or taste. Cooking methods, taste, and appearance are very critical to a restaurant’s operation. Although this equipment might be an option, staff would not recommend a rule that required a switch to a different type of cooking equipment. The Smokless^TM broiler capital cost is approximately $5,550, compared to a similarly sized under-fired charbroiler which costs about $3,100.

The second technology is an add-on scrubber manufactured by CAST Inc. For the majority of restaurants, the multi-component scrubber design (scrubber, filter and catalyst) would have a cost-effective range of greater than $20,000/ton (varies based on actual profile of meat cooked). This is compared to cost-effectiveness for chain-driven charbroilers (Rule 1138) of $1,680/ton of PM and VOC reduced (The cost-effectiveness for under-fired charbroilers is for PM reductions only). For this design, the added capital cost would range from $9,000 to $33,000, depending on the inclusion of avoided costs for other equipment (e.g., hood). Based on an example restaurant cooking 2,800 lbs/week (a very high volume of meat), the manufacturer has estimated the capital cost for a new scrubber to be $26,000. Taking into account cost savings for make-up air and reduced air conditioning expenses, the cost-effectiveness for a high-volume restaurant is estimated to be $1,100/ton of PM reduced. For a similarly sized, very high-volume restaurant, the retrofit cost-effectiveness would range from $4,000 to $7,300/ton. The range in cost-effectiveness is dependent on such factors as the amount and type of meat cooked, the type of exhaust hood and volume of make-up air.

While there are some very large operations and a number of franchises and chains, there are large numbers of family-owned restaurants. Many are small businesses, which are also ethnic and minority owned. The restaurant industry is highly competitive, with a fairly high turnover rate and relatively small profit margin. Collectively, under-fired charbroilers are a large PM¹⁰ emission source, but each restaurant emits less than one to less than ten pounds per day. This makes it very challenging to have a cost-effective control solution that is affordable for this type of operation. Additionally, it is desirable to have control equipment that requires operation and maintenance that can be done by personnel that may not be familiar with sophisticated, high-tech equipment. The scrubber system would be cost-effective for newly constructed restaurants cooking over 400 or more pounds per day (2,800 lbs/week). For under-fired charbroilers, retrofit costs can be several times the cost of a similar installation on a new restaurant. A survey of restaurants done for AQMD by a contractor in 1999 showed that greater than ninety-nine percent of restaurants using under-fired charbroilers cooked less than or equal to 1,200 pounds of meat per week.

Staff Recommendations

Infeasibility Findings
There are currently limited solutions available for reducing PM₁₀ from under-fired charbroilers, from the vast majority of restaurants. The majority of businesses in this source category are small businesses, and it is not cost-effective at this time to adopt a rule requiring retrofit add-on controls. Staff recommends that the Board make a finding of infeasibility, at this time, due to the circumstances described above.

Substitution of Emission Reductions
The emission reduction commitment for under-fired charbroilers from the 2003 AQMP under PRC-03, projected at 0.2 tons/day of PM₁₀ by 2006 and 1.0 ton/day of PM₁₀ by 2010, must be accounted for from other adopted rules. These reductions will be accounted for by emissions achieved that were greater than the 1999 AQMP commitment through the implementation of Rules 1186 - PM₁₀ Emissions from Paved and Unpaved Roads, and Livestock Operations and 403 – Fugitive Dust. The reductions in excess of the AQMP commitment are estimated to be 0.7 tons/day starting in 2005 for Rule 403 and 0.28 tons/day for Rule 1186 starting in 2006, for a total of 0.98 tons/day of PM₁₀. With growth factors applied, the reduction is estimated to be 1.04 tons/day PM₁₀ in 2010. Emission reductions from these two rules are not accounted for in the 2003 AQMP and thus 1.0 ton/day of PM₁₀ reductions can be substituted for the SIP commitment from AQMP Control Measure PRC-03.

Since controls for new very large restaurant operations may be cost-effective, staff will seek the Board’s approval in the future to remove the exemption for under-fired charbroilers from Rule 219 – Equipment Not Requiring a Written Permit Pursuant to Regulation II, and revise it to require permits for under-fired charbroilers cooking 2,800 or more lbs/week of meat. This amount of meat cooked represents a very large volume restaurant. Rule 222 – Filing Requirements for Specific Emission Sources not Requiring a Written Permit Pursuant to Regulation II, would be amended concurrently to exclude under-fired charbroilers processing 2,800 or more lbs of meat/week, from the registration program, thus requiring them to obtain a Permit to Operate.

Staff also recommends that BACT be updated to reflect the newest technology available for under-fired charbroilers. The Smokless™ broiler and the multi-component scrubber would be evaluated as BACT for under-fired charbroilers. However, staff would rely on the BACT process to identify the appropriate control for this source. These two actions would result in permitting and the installation of BACT for new large restaurants operating under-fired charbroilers.

Demonstration Projects
Staff further recommends that the Board approve in concept up to $200,000 from Rule 1309.1 – Priority Reserve, to fund six to eight new or retrofit demonstration sites on large restaurants. Staff will return to the Board at a later date with more information on how this program will be administered. Criteria for funding will include that the control equipment is available commercially and has been used on a restaurant or very similar application (i.e. greasy effluent stream), and is expected to achieve at least eighty percent reduction in PM¹⁰. Staff will work with the California Restaurant Association and others to identify potential demonstration sites.

Future rule adoption may be an option, depending on the effect of market parameters on the development and cost of control technologies. This approach would reduce emissions from some of the very large new restaurants and may help advance technology that could, in the future, be cost-effective for retrofit application.

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