Technical Support Document

for

EPA\'s Notice of Proposed Rulemaking

on revisions to the

California State Implementation Plan

as submitted by the State of California, Air Resources Board

for the South Coast Air Quality Management District

EPA\'s Analysis of

South Coast Air Quality Management District's

Rule 1105.1, Reduction of PM10 and Ammonia Emissions From Fluid
Catalytic Cracking Units

United States Environmental Protection Agency, Region IX

Air Division

Februrary 2005

Jerald S. Wamsley

**South Coast Air Quality Management District (SCAQMD),**

**Rule 1105.1 - Reduction of PM10 and Ammonia Emissions From Fluid
Catalytic Cracking Units**

**[Chronology of SCAQMD Adoption, Air Resources Board Submittal, and EPA
Actions]{.underline}**

\- The SCAQMD Governing Board adopted Rule 1105.1 on November 7, 2003.

\- The State of California submitted Rule 1105.1 to EPA on June 3, 2004
as a revision to the California State Implementation Plan (SIP).

\- On June 30, 2004, EPA found complete California Air Resource Board's
(CARB) submittal of Rule 1105.1.

There is no version of Rule 1105.1 in the SIP.

**[Rule Summary]{.underline}**

South Coast Air Quality Management District Rule 1105.1 - Reduction of
PM10 and Ammonia Emissions From Fluid Catalytic Cracking Units (FCCU),
is a rule designed to limit the particulate matter less than 10 microns
(PM10) and ammonia emissions from fluid catalytic cracking units at oil
refineries. The rule sets emission limits for filterable PM10 and
ammonia slip. PM10 and ammonia emissions result from the combination of
FCCU emissions and ammonia injection used with electrostatic
preciptators (ESP) to control FCCU emissions. Once in the atomsphere,
ammonia emissions react with other compounds to produce secondary
aerosol PM. Oil refineries are expected to implement any number of
several control technologies to meet the emissions limits including but
not limited to dry and wet ESPs, sulfur oxide reducing agents, selective
catalytic reduction, selective non-catalytic reduction, and wet gas
scrubbers.

**[Rule Evaluation]{.underline}**

**1. Statutory Requirements & EPA Guidance**

In section 189 of the Clean Air Act Amendments of 1990 (CAA), Congress
required that serious PM nonattainment areas, such as SCAQMD, implement
in a stepwise manner all reasonably available control measures (RACM)
and best available control measures (BACM) rules for all major sources
and significant PM-10 source categories. The SCAQMD's plan for attaining
the PM-10 NAAQS is the regulatory vehicle for determining RACM and
BACM..

In the case of Rule 1105.1, the SCAQMD PM-10 plan defines the source
category as "de minimis" or producing emission less than or equal to 5%
of the PM standard[^1]. Consequently, Rule 1105.1 is not designated as a
RACM or BACM measure in the SCAQMD PM-10 plan.

Because there is no previous version of Rule 1105.1 in the SCAQMD SIP,
EPA need not determine that this version of Rule 1105.1, adopted
November 7, 2003, weakens an existing version within the SIP. However,
EPA must determine that the rule does not interfere with any statutory
requirements concerning reasonable further progress (RFP) towards or
attainment of the National Ambient Air Quality Standards (NAAQS), or any
other applicable requirement of the CAA.

**2. Evaluation of Rule**

We believe that Rule 1105.1 is consistent with the relevant policy and
guidance regarding enforceability and SIP relaxations. The rule is
enforceable and contains the recordkeeping and monitoring requirements
needed to determine compliance. We are not reviewing Rule 1105.1 as a
RACM or BACM measure because SCAQMD did not define the rule as such
within the EPA approved serious area PM-10 plan. This plan listed Rule
1105.1 as an additional and "de minimis" measure in addition to those
BACM and RACM measures within the plan.

**3. Emission Reductions**

Rule 1105.1 is expected to reduce filterable PM10 emissions by 0.5 tons
per day and condensable PM10 by 1.99 tons per day[^2].

**4. Recommendations for Future Revisions**

We have no minor issues suggesting future amendment to the rule.

**5. Rule Deficiencies**.

There are no deficiencies in submitted Rule 1105.1 providing cause for
EPA to propose a disapproval of the rule.

**[Recommendation]{.underline}**

Section 110(k) of the CAA contains provisions governing EPA\'s review of
plans and regulations submitted by State of California, air districts,
and localities for inclusion in the California State Implementation
Plan. EPA can propose one of four actions on Rule 1105.1: full approval,
conditional approval, limited approval/disapproval, or a full
disapproval.

Rule 1105.1 contains no deficiencies. Also, the February 2002 rule
revision does not jeopardize reasonable further progress and attainment
of the NAAQS.

In conclusion, EPA proposes a full approval of the November 7, 2003
adopted version of SCAQMD Rule 1105.1 - Reduction of PM10 and Ammonia
Emissions From Fluid Catalytic Cracking Units.

**[Attachments]{.underline}**

1\. SCAQMD, Rule 1105.1 - Reduction of PM10 and Ammonia Emissions From
Fluid Catalytic Cracking Units, adopted November 7, 2003.

2\. \"Issues Relating to VOC (Volatile Organic Compound) Regulation
Cutpoints, Deficiencies, and Deviations,\" USEPA, May 28, 1988, cover
piece only.

3.  Staff Report for Proposed Rule 1105.1 - Reduction of PM10 and
    Ammonia Emissions From Fluid Catalytic Cracking Units, SCAQMD,
    October 9, 2003. This attachment does not include Chapter 7,
    Comments & Responses and the several appendices attached to and
    submitted with the Staff Report.

[^1]: See Tables 3.2 & 3.3, Estimated Source Contributions to South
    Coast Air Basin PM10 Annual Average and 24 Hour Average
    Concentrations in "Appendix I-D, Best Available Control Measures,
    PM10 SIP for the South Coast Air Basin," September 1994.

[^2]: See the October 9, 2003, SCAQMD Staff Report, at page 11.