PRELIMINARY DECISION OF ISSUANCE NO. 094Preliminary Decision of Issuance No. 094 Page 2 of 9...

PRELIMINARY

DECISION OF ISSUANCE NO. 094

Page 1 of 9

I. GENERAL INFORMATION

a. ERC Owner/Percent Ownership: Betteravia Farms

b. Primary Contact Name: Mr. Brent Reiswig

c. Primary Contact Company: Betteravia Farms

d. ERC Application Date: August 22, 2014

e. ERC Application Completeness Date: September 18, 2014

f. ERC Stationary Source Name: Betteravia Farms

ERC Stationary Source Number: 10654

g. ERC Facility Name: Betteravia Farms

ERC Facility Number: 10846

h. ERC Source: [ ] ATC Permit Required.

[x] Registration Canceled. Reg Number: See Attachment A

[x] PTO Required. Yes

[ ] Exemption

i. ERC Zone: North County

j. ERC Source Type: Agricultural

II. BACKGROUND

This Emission Reduction Credit (ERC) application is for the creation of NOx,,ERCs due to the

replacement of twenty-nine diesel powered engines with electric motors or Tier 4 engines. The

stationary engines are located at Betteravia Farms facilities on multiple parcels in the Santa Maria

Valley and Los Alamos areas. (See Attachment B). Each engine is registered with the District and

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Decision of Issuance No. 094

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therefore is not subject to permit. The engines provide power for stationary water booster pumps

and deep well pumps throughout the facilities for crop irrigation purposes. Several engines

qualify as “remote” under the State’s Agricultural Diesel ATCM and are identified in Table 1.0.

All engines have been at each site for the entire baseline period.

III. EMISSION REDUCTION CREDIT QUALIFICATION

a. Total DOI ERCs Approved:

NOx = 5.604 tpq / 22.417 tpy

b. Number of Emission Elements: 1

c. Emission Element Data

c.1 Emission Element Name: Twenty-nine Stationary Diesel IC Engines (Booster Pumps and

Deep Water Well Pumps)

- EE/DOI Number: 01/094

- Emission Element Description: A total of twenty booster pumps and nine deep well

pumps are powered by stationary diesel reciprocating internal combustion engines. These

engines will be replaced by electric motors or Tier 4 engines. Specific engine data is

provided in Attachment A.

.

- ERC Baseline: The three year emissions baseline (September 2011- September 2014) is

based on source test data, three years of hourly operational records and fuel use data from

source testing and fuel meter testing for each engine. The most conservative data was

used in the ERC calculations. Adjustments to source tested emission factors were made,

as necessary, to account for emission standards required by the stationary Air Toxics

Control Measure (ATCM) and emissions testing results which exceeded established

emission standards.

- Technical Uncertainty Factor Used? [x] Yes [ ] No

Source testing was conducted on each engine specifically for the purpose of calculating

the ERCs. NOx mass emission limits for each engine were established based upon EPA

Nonroad CI Emission Standards Title 13, Section 2423. For engines that source tested

above these limits, the EPA emission standard based limit was used in the ERC

calculations. The District determined that these emission rates are unnecessarily elevated

but is uncertain of the emission rates that could reasonably be expected from these

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engines given time in service. Therefore, the ERC totals for these engines only have been

discounted by a 20% uncertainty factor.

- ERC Due To: [x] Electrification of existing process (29 water pump engines)

- For Shutdowns/Reduction in Throughput: n/a (existing process remains, no shutdown)

[ ] BACT Discounted

[ ] 20 Percent Minimum Discount

- RACT/SIP/ATCM Discounted [ ] Yes [x] No

- RACT/SIP/ATCM Rules: The subject engines are Tier 0, Tier 1, Tier 2 and Tier 3

engines and are not subject to District permit or Rule 333 (Control of Emissions from

Reciprocating Internal Combustion Engines) emission standards. Each of the engines are

In-Use engines, and with the exception of six units, all meet the ATCM definition as

remotely located engines, therefore the ATCM emission standards do not apply to these.

The ATCM does apply to the six remaining engines.

These engines are also subject to the NEHSAP for stationary reciprocating IC engines.

They are all diesel fired engines rated less than 300 bhp. For this category of engine, the

NESHAP requires regular maintenance, but does not set numerical emission limits.

Therefore, these engines are not subject to further emission reductions by the NESHAP.

- ERC Adjustment to Tier 4 control: The approved ERCs do not reflect control from the

baseline emission levels down to the zero emissions level (i.e., 100% control). Credit was

granted only to Tier 4 emission levels to allow flexibility for future owners and operators

to use diesel powered engines to drive water pumps. The Tier 4 level applies since the

stationary ATCM requires any future engine installations to comply with the Tier 4

standards. The approved ERCs reflect the Tier 4 adjustment.

- Special ERC Restrictions? [x] Yes [ ] No

The ERCs are not approved for use on new NSR major source projects or major

modifications to existing major sources (i.e. not valid as federal ERCs).

- ERC Termination Date: none

- Are There Emission Element-Specific Conditions? [x] Yes [ ] No

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(1) Water Pumping Operations. All water pumping operations at the designated pump

locations listed in Table 1.0 shall be powered by electric motors or shall be powered by a

USEPA certified Tier 4 diesel engine. This requirement applies to any water well pump,

including any coupled stationary booster pump. This requirement applies to the land

owner(s) of the parcels (APN) listed in Attachment B, the owner of the engine and the

operator of the engine as listed on the associated District Permit to Operate issued for the

ERCs. The only exception to the Tier 4 requirements is during an electrical failure of an

electric powered well pump. In this case, a Tier 4 PERP’d engine for the horsepower

rating of the engine may be used for a temporary period not to exceed two months.

(2) New Water Wells. All new water wells that are commissioned or operated on any Santa

Barbara County land parcel comprising the Betteravia Farms stationary source shall be

equipped with electrically powered water pumps or by a USEPA certified Tier 4 diesel

engine. This provision applies to deep well water pumps and stationary booster pumps.

(3) Booster Pump Engines. Booster pump engines powered by any fuel shall not be used for

the direct pumping of water from underground reservoirs for any of the water wells

identified in Table 1.0 above unless powered by a USEPA certified Tier 4 diesel engine.

This provision includes booster pump operations directly associated with the water wells

and on stationary booster pumps.

(4) District Inspection. A District inspection shall be conducted to verify that all the

equipment for which ERCs have been granted has been removed from service and

disposed of in accordance with the conditions of this DOI. A minimum of three calendar

days advance notice shall be given to the District when scheduling this inspection.

(5) Engine Disposition. Betteravia Farms shall provide the following information to the

District regarding the disposition of the water pump engines identified in Table 1.0:

(a) Proof of installation of the new replacement electric motors or Tier 4 engines.

(b) Written certification or signed declaration from Betteravia Farms along with proof

that the original diesel-fueled engines are destroyed, sold, or otherwise transferred or

relocated to a new owner who operates the engine outside of the State of California

with the location and identity of the new owner, if applicable, along with a copy of a

written notification informing the new owner that the original engine must not be

operated, sold, or otherwise transferred or delivered in the State of California.

(6) Permit to Operate. To enforce the conditions of this DOI, a District Permit to Operate

(PTO) is required to be maintained jointly by the owner of the farm equipment, each

owner of the farm parcels listed in Attachment B, and the operator of the equipment. This

permit is required to be in place for the life of the farming operation in accordance with

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the findings made by the District Board of Directors per California Health and Safety

Code 42301.16 (Resolution 09-11on 08/20/09) providing the District the authority to

require permits for any agricultural source generating ERCs. The PTO shall remain in

place and is enforceable for the life of the ERCs even if the agricultural source reduces its

pollution levels below the permit thresholds in SB 700 or if all emission units are

removed from the source. A permit transfer shall be executed in accordance with District

Rule 203 within 30 days whenever there is a change in owner of the equipment, owner of

the farm land, or operator of the equipment.

(7) Life of DOI. This Decision of Issuance #094 remains active for the life of the ERCs.

This is defined as (a) the ERCs are being used by a project as approved by the District, or

(b) the ERCs remain unused in an active ERC Certificate.

(8) Use of the DOI. This DOI is valid for one year from the date stamped below if unused or

one year from the date of initial use. “Use” for the purposes of this DOI, means any

individual well that has been electrified.

(9) Replacement Engines. Any replacement engine shall be a Tier 4 engine. Prior to

replacing an electric motor on a well Betteravia Farms shall notify the District and obtain

a District permit or a registration as required by State and District rules.

(10) Records and Reporting. For each agricultural well pumping unit Betteravia Farms shall

maintain records of the items listed below. These records shall be submitted to the

District within 14 days upon written request from the District.

(a) The location of the agricultural pump (parcel number, ranch ID, well ID, and

geographic coordinates).

(b) Well ID, electric motor make, model, model year, and serial number.

(c) When an agricultural pump motor is replaced due to loss or malfunction,

identification of each replaced and replacement agricultural pump including make,

model, model year, and serial number, as well as, the reason for the replacement.

(d) The date, time, Tier, make, model, year of any diesel engine replacing an electric

motor.

(e) The hours of operation of each well pumping unit, and calendar year hours to date

for any well pump motor that is replaced.

(f) Date and well ID of each new well installed, and hours of operation of the associated

well pumping unit.

(11) Reimbursement of Costs. All reasonable expenses, as defined in District Rule 210,

incurred by the District, District contractors, and legal counsel for all activities related to

the Decision of Issuance 094, but not limited to the District Permit to Operate and

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compliance verification shall be reimbursed by Betteravia Farms pursuant to the

procedures of District Rule 210.

- Attachments [x] Yes [ ] No

Attachment 1 (ERC Calculations)

Attachment 2 (Pump APN Location / Owners)

d. Evaluation Criteria Summary: This application was submitted pursuant to the criteria

listed in Rule 806. The ERCs meet the basic qualification criteria of being surplus,

quantifiable, permanent and enforceable.

Surplus. In order for the ERCs to be valid, they must be surplus to the District’s Clean

Air Plan. The District’s 2007 Clean Air Plan uses 2002 as the baseline year. The Plan

estimates over 446 tons per year of NOx emissions from approximately 200 agricultural

diesel engines. The Plan also includes emissions for natural gas agricultural engines. The

District has registered/permitted approximately 240 agricultural diesel engines in the past

few years. The Plan was overly conservative in assuming the majority of these engines

were Tier 0 with the remaining being Tier 1 Moyer Program engines. Given that the

actual inventory of agricultural diesel engines are cleaner than assumed, the Plan’s

baseline annual emission tonnage therefore easily accounts for the 40+ additional engines

found in the field. Thus, the emission reductions from diesel and natural gas engines can

be considered surplus to the Plan.

The engines included in this DOI are not subject to District permit or District Rule 333.

With the exception of six engines, all qualify as remote and therefore are exempt from the

ATCM. Five of the remaining six engines are Tier 3 engines which satisfy the

requirements of the ATCM. One remote engine (ID #5061) is a Tier 2 engine and is

required to be replaced with a Tier 3 engine, therefore the ERCs for this unit are based on

the emission limits between a Tier 3 engine and a Tier 4 engine. None of the engines are

subject to emission limits from the NESHAP, therefore no RACT discount of the ERCs is

applicable.

Quantifiable. Documentation was provided verifying that each of the twenty-nine engines

was located at the site specified in Table 1.0 for the entire baseline period. Attachment A

provides the District approved ERC calculations. Each diesel engine was tested for, and

established, NOx emission factors in terms of “lb/MMbtu”. The testing was performed by

a third-party source test contractor and was reviewed and approved by the District. The

source test results were compared to emission rates based on EPA Tier standards and the

lesser of these were used in the in the ERCs calculations. With the exception of three

engines, all tested below the EPA standard. For those that did not, the EPA standard was

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used and a 20% uncertainty factor was applied.

Baseline fuel data was obtained from a short-term engine metering program conducted in

November 2014 in accordance with a District approved IC Engine Fuel Monitoring Plan.

Fuel rate data (average gallons per hour) for the engines was obtained by a portable fuel

meter for approximately a 24 hour period of routine field operations. Fuel use rates were

also determined during engine source testing. The lesser of the two rates was used in the

ERC calculations.

Engine operating hours were provided for the three year baseline (September 2011 -

September 2014) based on hour meter (totalizer) records for each engine. Average annual

operating hours were multiplied by the established fuel use rate to determine total annual

gallons used. The appropriate emission factor was then applied to determine actual

emissions. Actual emissions were then adjusted to allow for the installation of a Tier 4

engine. See Table 2.0 for details of these calculations.

The proposed ERCs are considered quantifiable. The District’s administrative file for this

project contains the records of hourly use, fuel monitoring records associated with the fuel

metering program, source test reports, and the source test fuel rates.

Permanency. In order to assure the permanence of the ERCs, Betteravia Farms is required

to install and use electrically powered pumps or Tier 4 engines at all 29 pump locations

for all future operations. In addition, to avoid any shift-in-load, a condition has been

included that requires all new wells at these sites to install electric pumps or pumps driven

by a Tier 4 engine. These requirements are conditions of approval under this DOI and

will be added to the stationary source’s engine operating permit.

Enforceability. A mechanism is necessary to ensure that Betteravia Farms and future

owners/operators of the ranches will continue to use electric motors or Tier 4 engines to

power stationary water well pumps subject to this DOI. Although Betteravia Farms’s

Cuyama operations are currently subject to permit under SB700, permits are not required

for an agricultural stationary source under SB700 if emissions fall below specified

thresholds. Thus, there is no assurance that Betteravia Farms or a future farm operator

will be required to retain permits under SB700. To address this uncertainty and to ensure

the permanency of ERCs, the District will require a permit to ensure enforcement of the

ERCs. To implement this requirement, the District Board of Directors has made required findings per SB700 /H&SC 42301.16 (per Resolution 09-11on 08/20/09) that provides the

District the authority to require permits for agricultural sources generating ERCs. These

permits shall remain in place and will be enforceable for the life of the ERCs even if the

agricultural source reduces its pollution levels below the permit thresholds in SB 700 or if

all emission units are removed from the source. In addition, such permits will have a

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transfer condition in accordance with District Rule 203, requiring application for a permit

transfer within 30 days whenever there is a change in owner of the equipment, owner of

the farm land, or operator of the equipment. The permits will be issued jointly to the

owner of the farm equipment, each owner of the farm land, and the operator of the

equipment. With these permitting requirements, the proposed ERCs are considered

enforceable.

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e. Recommendation: Based on the ERC application, the analyses contained herein and attachments contained within the DOI, approval of the ERCs is recommended.

J. Menno January 2015 January 2015

Evaluator Date Reviewer Date

AIR POLLUTION CONTROL OFFICER

DATE

Attachment:

Emission Reduction Credit Calculations

\\sbcapcd.org\Shares\Groups\ENGR\WP\ERCs\DOI-078\draftdoi3-4-12.doc

ATTACHMENT A

ERC CALCULATIONS

Decision of Issuance 094Table 1.0. Engine SpecificationsBetteravia Farms

Registration

Number

Device

No

Engine

ID Make Model

Model

YearSerial # HP

EPA

TierLat (DD) Lon (DD)

Remote

Engine? Pump Type

12563 111316 5031 Cummins QSM-11-C 2002 35068538 275 1 34.76128 -120.42875 Yes Water Well

12564 111317 5032 Deutz BF4L913T 1998 8521269 101 1 34.92533 -120.53549 Yes Booster

12566 111321 5041 Deutz BF6L914C 2004 8689890 155 2 34.93885 -120.55804 Yes Water Well

12567 111322 5042 Deutz BF6L914C 2004 8689884 155 2 34.95282 -120.55850 Yes Water Well

12429 110930 5061 John Deere 6081HF070 2005 RG6081H275329 250 2 34.75632 -120.41143 No Water Well

12428 110928 5071 John Deere 6090HF485 2006 RG6090L010713 250 3 34.96529 -120.52122 No Water Well


12426 110926 5073 John Deere 6068HF485 2007 PE6068L005072 200 3 34.94905 -120.53237 No Water Well

12427 110927 5074 John Deere 6068HF485 2007 PE6068L010620 185 3 34.93763 -120.52534 No Water Well


12569 111324 5951 Deutz BF6L912 Pre-1996 837729 113 0 34.96409 -120.52761 Yes Booster

12571 111326 5962 Deutz BF6L912 Pre-1996 6435634 113 0 34.96409 -120.52761 Yes Booster

12573 111332 5971 Deutz BF6L913 1997 8502549 113 1 34.96409 -120.52761 Yes Booster




n/a n/a 5976 Deutz F4M1008 1998 8140334 33.5 n/a 34.96409 -120.52761 Yes Booster













Decision of Issuance 094Table 2.0. Source Test Data / Baseline Data Betteravia Farms

Source Tested Fuel Calorific Value Hour

lb/hr lb/MMBtu Fuel Use (gal/hr)1

Btu/gal Data2

5031 1.32 1.1276 8.4200 138822 37765032 0.19 0.9717 1.4200 136135 17595041 1.06 1.9271 3.9600 138822 26125042 0.92 1.6533 4.0200 138822 23995061 1.20 1.1302 7.6200 138822 41375071 1.91 1.6918 7.3700 138822 56385072 0.40 0.4430 6.4200 138822 26115073 0.43 0.4971 5.8300 138822 24655074 0.49 0.5912 6.0000 137100 32565075 2.12 1.7087 8.9200 138822 26725951 0.72 1.2803 4.1200 136135 32555962 2.81 5.2741 3.8800 137802 8485971 2.31 5.8916 2.8600 137100 9345972 1.28 2.8894 3.2600 135821 25355973 0.40 1.5633 1.7900 137802 10925975 0.61 2.0131 2.2200 136135 19185976 0.10 0.6047 1.1600 137100 7555977 0.62 2.3121 1.9800 136135 9155978 0.72 1.8187 2.8300 137802 30975979 0.69 2.4661 2.4000 137802 8795981 0.53 2.4680 1.5600 137100 10535982 1.00 3.3082 2.2000 136135 9905983 1.21 3.1936 2.6800 137802 16275984 0.55 2.2807 1.7600 137802 11345986 1.05 2.2850 3.3200 137802 16545987 0.69 2.6205 1.9200 136135 13135991 0.41 2.7288 1.0800 137802 21945992 0.26 2.1329 0.0100 136135 12405993 0.34 1.7196 0.0230 137802 1306

1. The va lues represent the lesser of the fuel rate determined during source testing and the fuel rate establ ished during the 24-hr fuel metering program.

2. Hour data i s the average annual hours of operation per year during the basel ine period.

NOxEngine ID

Decision of Issuance 094Table 3.0. ERC Calculations Betteravia Farms

Engine ID Engine HP Annual

Gallons1 NOx Limit

(g/hp-hr)2NOx Limit

(lb/hr)3

Tier

Emissions

(TPY)4

Actual

Emissions

(TPY)5

Tier 4

Emissions

(TPY)6

NOx ERCs

(TPY)7

5031 275 31794 6.9 4.183 7.90 2.488 0.343 2.145

5032 101 2498 6.9 1.536 1.35 0.165 0.059 0.106

5041 155 10344 4.5 1.538 2.01 1.384 0.134 1.250

5042 155 9644 4.5 1.538 1.84 1.107 0.123 0.984

5061 250 31524 2.8 1.543 3.19 2.473 0.342 2.131

5071* 250 41552 2.8 1.543 4.35 4.879 0.466 3.014

5072 250 16763 2.8 1.543 2.01 0.515 0.216 0.300

5073 200 14371 2.8 1.235 1.52 0.496 0.163 0.333

5074 185 19536 2.8 1.142 1.86 0.792 0.199 0.593

5075* 250 23834 2.8 1.543 2.06 2.827 0.221 1.428

5951† 113 13411 14.074 3.506 5.71 1.169 0.122 1.047

5962† 113 3290 14.074 3.506 1.49 1.196 0.032 1.164

5971* 113 2671 6.9 1.719 0.80 1.079 0.035 0.607

5972 113 8264 6.9 1.719 2.18 1.622 0.095 1.527

5973 113 1955 6.9 1.719 0.94 0.211 0.041 0.170

5975 113 4258 6.9 1.719 1.65 0.583 0.072 0.512

5976†† 33.5 876 n/a n/a n/a 0.036 0.008 0.032

5977 113 1812 6.9 1.719 0.79 0.285 0.034 0.251

5978 113 8765 6.9 1.719 2.66 1.098 0.116 0.983

5979 113 2110 6.9 1.719 0.76 0.358 0.033 0.326

5981 113 1643 6.9 1.719 0.91 0.278 0.039 0.239

5982 113 2178 6.9 1.719 0.85 0.490 0.037 0.453

5983 113 4360 6.9 1.719 1.40 0.959 0.061 0.899

5984 113 1996 6.9 1.719 0.97 0.314 0.042 0.271

5986 113 5491 6.9 1.719 1.42 0.865 0.062 0.803

5987 113 2521 6.9 1.719 1.13 0.450 0.049 0.401

5991 55 2370 6.9 0.837 0.92 0.446 0.040 0.446

5992 55 1743 6.9 0.837 0.52 0.253

ATTACHMENT B

APN /Owners

Engine ID APN Parcel Land Owner

5031 099-010-049 Betteravia Farms

5032 113-140-010 US Trust - South


5042 113-080-028 Ferrini Ranches Inc


5071 113-050-050 US Trust - North


5073 113-110-002 US Trust - North

5074 113-140-003 Waller

5075 113-110-002 US Trust - North

5951 113-050-050 US Trust - North

5962 113-050-050 US Trust - North

5971 113-050-050 US Trust - North

5972 113-140-010 US Trust - South

5973 113-140-010 US Trust - South

5975 113-050-050 US Trust - North

5976 113-050-050 US Trust - North


5978 113-140-010 US Trust - South

5979 113-050-050 US Trust - North

5981 113-050-050 US Trust - North

5982 113-050-050 US Trust - North

5983 128-064-005 Layne

5984 113-140-010 US Trust - South

5986 113-050-050 US Trust - North

5987 113-050-050 US Trust - North

5991 113-080-030 Grubstake LLC

5992 113-080-030 Grubstake LLC

5993 113-140-010 US Trust - South

Additional Parcels Served by Engines

Parcel Land Owner

Betteravia Farms

Betteravia Farms

US Trust - North

Ferrini Ranches Inc

Betteravia Farms

Grubstake LLC

Betteravia Farms

Betteravia Farms

US Trust - North

Betteravia Farms

US Trust - North113-200-011

APN

099-010-029

101-080-050

113-050-049

113-080-027

113-100-014

113-080-032

113-120-019

113-130-007

113-140-001

113-140-004

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