UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX AIR DIVISION

Technical Support Document for The EPA ’ s Notice of Proposed Rulemaking for the California State Implementation Plan

The EPA ’ s Evaluation of

South Coast Air Quality Management District, 2016 AQMP Reasonably Available Control Technology (RACT) Demonstration

– Adopted June 6, 2014

Prepared by: Ja mes Shears and Stanley Tong Reviewed by: Andrew Steckel

June 2016- 2

- RULE IDENTIFICATION

-

Agency : South Coast Air Quality Management District (S C AQMD)

SIP Approved Version : There is no previous SIP approved SCAQMD RACT SIP for the 2008 8

- hour ozone standard, but we previously approved the following document for the 1997 8

- hour ozone standard: SCAQMD Reasonably Available Control Technology Analysis (2006 RACT SIP) Adopted

- July 14, 2006 Submitted

- January 31, 2007 Approved

- December 18, 2008 (73 FR 76947)

Subject of this TSD: S C AQMD 2016 AQMP Reasonably Available Control Tech nology (RACT) Demonstration Adopted

– June 6, 2014 Submitted

– Ju ly 1 8 , 20 14

BACKGROUND

-
Volatile organic compounds (VOC) and nitrogen oxides (NOx) in the presence of sunlight can lead to the formation of ground

- level ozone or “ smog ” which can result in significant impacts to human health and the environment

. Section 182 of the Clean Air Act (CAA) requires areas that are classified as moderate or above for ozone nonattainment to implement reasonably available control technology (RACT ) for specific types of sources. The South Coast Air Quality Management District (S C AQMD or the District ) falls under this requirement as the South Coast Air Basin (Basin) is classified as a n extreme ozone nonattainment area and the Coachella Valley locate d in Riverside County is classified as a severe

- 15 nonattainment area under the 2008 8

- hour national ambient air quality standard (NAAQS) for ozone (40 CFR 81.305 )

. Under CAA § 182(b)(2) and (f), S C AQMD must, at a minimum, adopt RACT level controls for

s ources covered by a Control Techniques Guidelines (CTG) document and for any major stationary source of VOC or NOx

. The EPA defines RACT as the “ lowest emissions limitation that a particular source is capable of meeting by the application of control techno logy that is reasonably available considering technological and economic feasibility. ” 44 FR 53761 (September 17, 1979)

. A RACT analysis should, therefore, take into account the technological and economic feasibility of controls, and may differ from sourc e to source and location to location.

SUBMITTAL SUMMARY

–
The District adopted its RACT SIP certification for the 2008 ozone standard on June 6, 2014 and the California Air Resources Board (CARB) submitted it to EPA on July 18, 2014. SCAQMD performed it s RACT SIP analysis based on an ozone non

- attainment classification- 3

- of “extreme”. This classification defines a major stationary source as those facilities that emit or have the potential to emit at least 10 tons per year (tpy) of VOC or NOx.

SCAQMD’s sub mittal included the following documents:

a. “ S C AQMD 2016 AQMP Reasonably Available Control Technology (RACT) Demonstration ”, dated May 22, 2014 [hereinafter “ 20 1 6 AQMP RACT SIP ” ]

. b. Resolution No. 14

- 14: “A Resolution of the South Coast Air Quality Management D istrict (SCAQMD) Board certifying that the SCAQMD’s current air pollution rules and regulations fulfill the 8

- hour ozone Reasonably Available Control Technology (RACT) requirements and adopting the RACT SIP revision.”

SCAQMD’s analysis included the follow ing areas. Further discussion is provided below.

• Review of previous RACT demonstrations from its 2007 and 2012 Air Quality Management Plan s (AQMP)

• Further e valuation of selected SCAQMD Rules and Regulations

• New major sources identified since its 2006 RACT SIP certification

• Negative declarations

EPA EVALUATION

– The EPA evaluated t he following elements of SC AQMD ’ s 201 6 AQMP RACT Analysis :

• The bases for concluding l ocal rules implement RACT

• Efforts to identify new major source s within the District

• N egative declarations where there are no facilities subject to a CTG

T he following documents were also used to support our review:

• “ Final Rule to Implement the 8

- Hour Ozone National Ambient Air Quality Standard

– Phase 2 ” (70 FR 71612; November 29, 2005).

• “ State Implementation Plans, General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 ” (57 FR 13498; April 16, 1992) ; 57 FR 18070 (April 28, 1992)

.

• Enforceability

- Section 110(a) of the CAA requires enforceable emission limitati ons and other control measures. Several EPA guidance documents are used to evaluate rule enforceability, including “ Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviations

, ” EPA, M ay 25, 1988 (The Blue Book), and “ Guidance Document for Co rrecting Common VOC & Other Rule Deficiencies, ” EPA Region 9, August 21, 2001 (the Little Bluebook).

• “ State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 ” (57 FR 55620, November 25, 1992) ( “ the NOx Supplement ” ).

• Memorandum from William T. Harnett to Regional Air Division Directors, (May 18, 2006),

“ RACT Qs & As

– Reasonably Available Control Technology (RACT) Questions and Answers ”

.

• RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) describing Region IX ’ s understanding of what constitutes a minimally acceptable RACT SIP.- 4

- • Letter dated April 4, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) listi ng the EPA ’ s current CTGs, ACTs, and other documents which may help to establish RACT.

• “ Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requirements’’ (80 FR 12264; March 6, 2015).

• EPA ’ s CTGs and ACTs : https://www.epa.gov/ozone

- pollution/control

- techniques

guidelines

- and

- alternative

- control

- techniques

- documents

- reducing

• CARB ’ s emissions inventory database http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php

• S C AQMD , CARB

, and EPA Region IX databases of S C AQMD rules S C AQMD : http://www.aqmd.gov/home/regulations/rules/scaqmd

- rule

- book CARB: http://www.arb.ca.gov/rldb/rldb.htm EPA: http://www.epa.gov/approved

- sips/approved

- sips

- region

- 9

The following summarizes S C AQMD actions to address RACT requirements and the EPA ’ s evaluation of those actions.

1. The b ases for concluding local rules implement R ACT

RACT is required for source categories covered by an EPA Control Techniques Guidelines document ( “ CTG sources ” ) and all sources that are not covered by a CTG document but are

“ major sources ” (i.e., for S C AQMD, “ non

- CTG sources ” that emit or have th e potential to emit at least 1 0 tons per year of VOCs or NOx .)

SCAQMD action (2006 RACT SIP and 2007 AQMP) :

SCAQMD’ s 2016 AQMP RACT SIP (submitted July 18, 2014) summarizes its past RACT certifications and states that its previous RACT analyses are incor porated as components of its 2007 and 2012 Air Quality Management Plan (AQMP) Reasonably Available Control Measures (RACM)/RACT Demonstrations. 1 The District’s 2007 and 2012 AQMP RACM/RACT analysis supplements and updates its “2006 RACT SIP” certification

.

SCAQMD’s 2006 RACT SIP certified that all sources subject to a CTG and all major non

CTG VOC and NOx s ources implemented RACT for the 1997 8

- hour ozone standard

. Appendices 2

– 4 contain the District’s analysis that its rules implement RACT and

1 2016 AQMP RACT SIP

, Attachment B, Regulatory History, page 1 : http://www.aqmd.gov/docs/default

source/Agendas/Governing

- Board/2014/2014

- jun6

- 031.pdf?sfvrsn=2 ;
2007 AQMP Appendix VI: Reasonably Available Control Measures (RACM) (June 2007) http://www.aqmd.gov/docs/default

- source/clean

- air

- plans/air

- quality

- management

- plans/2007

- air

- q uality

management

- plan/2007

- aqmp

- appendix

- vi.pdf?sfvrsn=2 ;
2012 AQMP Appendix VI: Reasonably Available Control Measures (RACM) Demonstration (February 2013) http://www.aqmd.gov/docs/default

- source/clean

- air

- plans/air

- quality

- management

- plans/2012

- air

- quality

management

- plan/final

- 2012

- aqmp

- (february

- 2013)/appendix

- vi

- final

- 2012.pdf- 5

- Appendix 5, Table 5

- 1 lists the District’s major sources with Title V permits. EPA approved SCAQMD’s 2006 RACT SIP certification in D ecember 2008. 2

The District’s 2007 AQMP is an integrated plan to address both the 1997 PM 2.5 and the 1997 8

- hour ozone NAAQS

. Table 3 of the SCAQMD 2007 AQMP contains a brief analysis of 82 source

- specific rules and a summary of requirements from other air districts if SCAQMD concluded that th e requirements in other jurisdictions were more stringent

. The AQMP review s four new CTGs issued by EPA in September 2006 and conclude s that its rules implement the recommendatio ns in the new CTGs with the exception of the fountain solution VOC concentration limits for sheet

- fed presses and heat

- set web presses in Rule 1130

– Graphics Arts. SCAQMD amended Rule 1130 on May 2, 2014 to implement the recommendations in the CTG

. The 20 07 AQMP states that in general, SCAQMD’s current rules and regulations are equivalent or more stringent than rules in other air districts. 3

EPA Evaluation The District’s 2007 AQMP was submitted on November 28, 2007 and approved into the SIP 77 FR 12674 (March 1, 2012). EPA approved the May 2, 2014 amendments to Rule 1130 in 80 FR 40915 ( July 14, 201 5 ) as implementing RACT

. We are not aware of any information that would alter our prior determination that the SCAQMD 2006 RACT SIP updated and supplemented by the District’s 2007 AQMP demonstrates the District’s rules implement RACT.

SCAQMD action (2012 AQMP) :

The District’s 2012 AQMP focuse s primarily on PM 2.5 an d its precursors including NOx, VOC and S O x and i s designed to address the federal 2006 24

- hour PM 2.5 standard.

Table VI

- 4 of the 2012 AQMP contains a brief analysis of nine District rules that are subject to CTGs that EPA promulgated between 2006

– 2008

. The 2012 AQMP concludes that the following rules are either equivalent to, or are more stringent than the corresponding CTGs, and that no further action is needed: Rule 1104, Wood Flat Stock Coating Operations; Rule 1171, Solvent Cleaning Operations; Ru le 1107, Coating of Metal Parts and Products; Rule 1128, Paper, Fabric, and Film Coatings; Rule 1145, Plastic, Rubber, Glass Coatings; Rule 1162, Polyester Resin Operations. Also listed in Table VI

- 4 is Rule 1130, Graphic Arts

, which states a rule update w ill be pursued. As mentioned above, EPA approved the May 2, 2014 amendments to Rule 1130 to implement the recommendations in the CTG.

The AQMP states Rule 1115, Motor Vehicle Assembly Line Coating Operations

, has less stringent limits than the CTG for va rious primers, and it exempts certain coatings that are not exempted by the CTG. It also s tates that Rule 1115 has a small inventory (~ 0.01 tpd ) and concludes that no action is needed. The AQMP also indicates that a rule update may be pursued for Rule 116 8, Adhesives and Sealants, since it has less stringent limits than the CTG for certain adhesives.

2 A pproval of SCAQMD 2006 RACT SIP: 73 FR 76947 (December 18, 2008).

3 2007 AQMP page VI

- 5

, http://www.aqmd.gov/docs/default

- source/clean

- air

- plans/air

- quality

- management

plans/2007

- air

- quality

- management

- plan/2007

- aqmp

- appendix

- vi.pdf?sfvrsn=2

.- 6

- EPA Evaluation The District’s 2012 AQMP was submitted on February 13, 2013 and approved into the SIP in 79 FR 52526 ( September 3, 2014 ). We agree with the District that Rules 1104, 1171, 1107, 1128, 1145, and 1162 implement RACT.

For Rule 1115, we determined there are potentially four coating operations for new heavy

duty vehic le s and that these facilities are subject to the 2008 CTG for Miscellaneous Metal and Plastic Parts Coatings and not the 2008 CTG for Auto mobile and Light

- Duty Truck Assembly Coatings. We also conclude that Rule 1107

, Coating of Metal Parts and Products

, i mplements the 2008 CTG for Miscellaneous Metal and Plastic Parts Coating.

For Rule 1168, we disagree with the District’s conclusion that it has less stringent limits than the CTG for certain adhesives and conclude the rule implements EPA’s 2008 CTG for Mi scellaneous Industrial Adhesives. We discuss these rules and our evaluation in greater detail later in this TSD. We are not aware of any information that would alter our prior determination that the SCAQMD 2006 RACT SIP updated and supplemented by the Dist rict’s 2007 and 20 12 AQMP s demonstrates the District’s rules implement RACT.

2. Efforts to identify new major sources within the District

SCAQMD action:

SCAQMD ’s 2016 AQMP RACT SIP does not contain a listing of major sources similar to that contained in Appendix 5 of its 2006 RACT SIP. Subsequent to the 201 6 AQMP RACT SIP submittal, the EPA requested and received SCAQMD’s list of new major VOC / NOx sources that have received Title V permits since the 2006 RACT SIP. 4 SCAQMD indicated there are 26 new Title V facilities, one facility i s major for CO, one facility i s major for PM 10 and three are covered under the District’s Re gional C l ean Air Ince ntives Market program (RECLAIM ) . The remaining 21 major sources are listed below.

4 Email dated January 29, 2016, from Kal a m Cheung (SCAQMD ) to Stanley Tong ( USEPA ) , RE: “New Title V Facilities since 2006”

.- 7

- E PA evaluation:

The EPA reviewed SCAQMD’s list of equipment emitting greater than 5 tpy at the above facilitie s and agree the emission sources are subject to rules that implement RACT. In addition, SCAQMD indicates that all new major sources since 2006 are required to have Best Available Control Technology (BACT), which exceeds RACT, as a condition of permit. 5

T he District ’ s efforts to identify all new major source s appea r s to be thorough

.

3

. Submit negative declarations where there are no facilities subject to a CTG

.

S CAQMD action:

In lieu of adopting RACT rules, Districts can adopt negative declarations fo r CTG source categories if there are no sources in the District covered by the CTG

.

5 Id. SCAQMD New Major Sources Title V Permits Since 2006

Permit Permitted Facility

3513 3704 10966 11245 14871 51475 69081 104806 139808 139938 140373 148236 148568 151798 1 52707 153992 157152 173108 174406 800428 800436 Irvine Ranch Water District All American Asphalt, Unit No. 01 Weber Metals Inc. Hoag Hospital Sonoco Products Co. Southern California Edison Co. Baxter Healthcare Corp., Hyland Division MM Lopez Energy LLC In land Empire Regional Composting Authority Sunshine Gas Producers LLC Ameresco Chiquita Energy LLC Air Liquide Large Industries U.S., LP Southwest Mill and Lumber Tesoro Refining and Marketing Co., LLC Sentinel Energy Center LLC Canyon Power Plant Bowerman Power LFG, LLC Silver Creek Industries, Inc. Arlon Graphics LLC Lamps Plus Inc./Pacific Coast Lighting Tesoro Refining and Marketing Co., LLC- 8

- In its 201 6 AQMP RACT SIP, SCAQMD did not claim any negative declarations

. At that time, t he District indicated it ha d sources that are subject to all of the CTGs.

EP A evaluation:

Subsequent to its 201 6 AQMP RACT SIP submittal, EPA had several discussions with SCAQMD and concluded there may be two CTG categories where the District has no
sources applicable to the CTGs . F or the 2007 CTG for P aper, F ilm and Foil coating s, it appears from a review of the SIC codes applicable to the CTG, CARB’s emissions inventory, and discussion with SCAQMD permit engineer, that SCAQMD has no sources with coating lines exceeding the CTG threshold of 25 tons/year VOC per coating line (EPA 453/R

- 07

- 003)

.

For the Surface Coating Operations at Shipbuilding and Repair Facilities CTG ( 61 FR

44050, August 27 , 1996 and EPA

- 453/R

- 94

- 032 ) , SCAQMD indicates it only has one active Title V shipyard facility that is subject to Rule 1106

, Marine Coatin g Operations. The one coating category in Rule 1106 that exceeds the CTG’s VOC content limit is inorganic zinc and the District indicates inorganic zinc coating is not used at the facility. 6 Consequently, the EPA recommends that SCAQMD evaluate and adopt w here appropriate, negative declaration s for these two CTG categories. The EPA concurs that there is no need for other negative declarations.

4

. Review of specific rules and whether they implement RACT

S CAQMD action:

The 201 6 AQMP RACT SIP analysis eval uated more than 30 rules recently developed and/or amended by other ozone nonattainment air districts from September 2012 to March 2014 7 . The air districts in California included the Bay Area Air Quality Management District (BAAQMD), San Joaquin Valley Ai r Pollution Control District (SJVAPCD), Mojave Desert Air Quality Management District (MDAQMD), Antelope Valley Air Quality Management District (AVAQMD), Sacramento Metropolitan Air Quality Management District (SMAQMD), and Ventura County Air Pollution Con trol District (VCAPCD), and state agencies for ozone i mpacted areas in Texas, Maryland and Dela ware.

SCAQMD concluded that its rules exceeded or closely matched those of other agencies, with the following rules requir ing further evaluation

. 1) Rule 462 Orga nic Liquid Loading

SCAQMD Rule 462 limits organic vapor emissions from facilities that load 20,000 gallons or more in a day of organic liquids into any tank truck, trailer, or railroad tank car to 0.08 pounds/1000 gallons. BAAQMD Rule 8

- 33 limits bulk g asoline terminal

6 Email dated February 4, 2016, from Kal a m Cheung (SCAQMD) to Stanley Tong ( USEPA), RE: “ 2014 Ozone RACT SIP

- Rule 1106 and Rule 1128”

. 7 SCAQMD June 6, 2014 Board meeting, Agenda No. 31, page 2 and the 2016 AQMP RACT SIP

, Table 1. http://www.aqmd.gov/docs/default

- so urce/Agendas/Governing

- Board/2014/2014

- jun6

- 031.pdf?sfvrsn=2- 9

- emissions to a maximum of 0.04 pounds/1000 gallons of organic liquid loaded

. The 201 6 AQMP RACT SIP states “ Fugitive VOC emissions monitoring protocols between the BAAQMD and the SCAQMD gasoline bulk terminal and cargo tank operations need to be evaluated to determine whether the provisions of SCAQMD Rule 462 apply to BAAQMD ’s Section 8

- Rule 33.” 8

EPA Evaluation

S upplemental information provided by SCAQMD for Rule 462 indicates it has 23 major source bulk loading terminals. Sourc e te sts for 9 bulk terminals showed emissions from 0.0004 to 0.029 lbs/1000 gallons. 9 We note that BAAQMD adopted its 0.04 lb/1000 gallons VOC limit for gasoline bulk terminals in 2009 with an effective date of January 10, 2011. We were unable to identify any other air district with this lower limit in a SIP rule . Accordingly, we agree that Rule 462 currently implements RACT for this category

.

We recommend the District evaluate adopting a 0.04 pounds/1000 gallons limit for gasoline bulk terminals subject to t he outcome of its evaluation of differences in bulk terminal and cargo tank monitoring protocols between the BAAQMD and the SCAQMD.

2) Rule 1148.1 Oil and Gas Production Wells

, and Rule 1173 Control of Volatile Organic Compound Leaks and Releases from Compo nents at Petroleum Facilities and Chemical Plants

SCAQMD action:

VCAPCD Rule 71.5 regulates VOC emissions from glycol dehydrators which are used to remove water from natural gas

. In response to the EPA’s query whether the SCAQMD regulated emissions fro m glycol dehydrators, the District’s 201 6 AQMP RACT SIP states it needs to determine if existing SCAQMD Rule s 1148.1 and 1173 already cover these emissions.

SCAQMD provided a November 2014 S u pplemental A nalysis 10 stating VCAPCD Rule 71.5 requires VOC emiss ions from glycol dehydrators to be controlled by at least 95%. SCAQMD’s November 2014 S upplemental A nalysis also states emissions from glycol dehydrators are regulated under Rule 1148.1, which also requires a 95% control efficiency and is as stringent as t he VCAPCD rule. SCAQMD also states that Rule 1173 covers VOC leaks from petroleum and chemical plants and that both Rules 1148.1 and 1173 were SIP approved in 2011 and 2010 respectively by the EPA as fulfill ing RACT.

EPA Evaluation

8 SCAQMD June 6, 2014 Board meeting, Agenda No. 31, page 2. http://www.aqmd.gov/d ocs/default

- source/Agendas/Governing

- Board/2014/2014

- jun6

- 031.pdf?sfvrsn=2

9 Email dated November 25, 2014, from Joe Cassmassi (SCAQMD) to Stanley Tong (USEPA), RE: “SCAQMD RACT Analysis Draft 20141119(2) hereinafter “ November 2014 S upplemental A nalysis”.

10 Id.- 10

- The EPA has reviewed S CAQMD’s November 2014 S upplemental A nalysis and agrees that glycol dehydrators are covered by Rule 1148.1 and that Rules 1148.1 and 1173 implement RACT for this category

. 3) Rule 1118 Control of Emissions from Refinery Flares

SCAQMD action:

Rule 1118 appl ies to all flares used at petroleum refineries, sulfur recovery plants and hydrogen production plants and Rule 1150. 1 applies to landfill flares. However, neither rule cover s other flares such as those used in wastewater treatment plants or oil and gas pro duction facilities . SCAQMD’s 2016 AQMP RACT SIP states potential flare emissions from other District sources need to be evaluated to determine the local applicability of SJVAPCD Rule 431 1 since San Joaquin’s rule regulates flares emit ting greater than 10 t py of VOC or NO x regardless of source category. 11

EPA Evaluation

Discussions with SCAQMD revealed flares at t wo source categories (wastewater treatment facilities and oil and natural gas production facilities) are not covered under Rule 1118 and may nee d further investigation to determine if they are major non

- CTG sources requiring RACT.

SCAQMD’s November 2014 S upplemental A nalysis of flaring emissions at wastewater treatment plant s indicated the largest VOC emissions was from the Hyperion Treatment Pla nt at 10,269 lbs/year (5.1 tpy) in 2012 12 with the potential to emit 40 tpy total for the six flares at the facility. SCAQMD indicated that Hyperion’s digester gas goes through successive processes that reduce the volume of gas before it reaches a flare. Th e District indicated most of the digester gas first go es to Scattergood Generating Station to generate electricity. Next, a ny residual gas is combusted in a boiler, and finally any remaining gas from the boiler would go to the flares. Consequently, SCAQMD staff indicated any remaining VOC reaching the flare would be well below 10 tpy, and so the flares would not be considered a major source. We agree that VOC emissions are reduced when combusted to generate electricity

. CARB’s emissions inventory website shows Tidelands Oil Production Company (Facility ID 800325) in Long Beach has NOx emissions of 14.7 tpy in 2012; 12.1 tpy in 2013; and 4.3 tpy in 2014 and 2015

. The draft Title V permit 13 for this facility indicates it has two small boilers and a 58 MM B tu /h r ground flare. The flare is designated as an emergency flare and has permit conditions requiring a minimum flare temperature and

a non

- resettable totalizing fuel meter.

11 2016 AQMP RACT SIP page 3.

12 SCAQMD November 2014 Supplemental A nalysis, dated November 18, 2014, page 2

13 Facility Permit to Operate, Tidelands Oil Production Co, 949 Pier G Ave, Long Beach, CA, Facility ID 800325 Draft, April 14, 2015.- 11

- While Tidelands ’ NOx emissions show a decreasing trend such that it is no longer a

m ajor source of NOx , the District should evaluate regulating non

- refinery / non

- landfill flares similar to San Joaquin Rule 4311 which requires flares greater than or equal to 5.0 MM Btu/hr to submit a flare minimization plan for APCO approval

. If additional reductions are needed, the District may also want to evaluate whether increased flaring (e.g., routine use of emergency flares) at oil production or wastewater treatment facilities are occurring due to more stringent gas constituent limits imposed by pipe line gas companies or power plants

. 4) Rule 1130 Graphic Arts

SCAQMD action:

SCAQMD’s 201 6 AQMP RACT SIP states Rule 1130 is more stringent than AVAQMD Rule 1130 for flexographic specialty inks for facilities emitting more than 10 tons per year. It furth er states that for facilities that emit less than 10 tons per year and that use less than 2 gallons per day and less than 120 gallons per year, AVAQMD Rule 1130 has more restrictive VOC content limits for flexographic specialty inks used for flexible packa ge printing (383 g/l). In contrast, SCAQMD Rule 1130 allows 460 g/l for metallic ink and 535 g/l for matte finish ink for no more than 2 gallons per day and less than 125 gallons per year

. 14 The 2016 AQMP RACT SIP further states that the emission reduction potential for this category is de minimis based on the number of affected facilities (0.006 tpd), but will analyze the viability of creating a new sub

- category.

EPA Evaluation

The EPA ’s original concern with Rule 1130 was it did not meet the recommend ed fountain solution VOC limits in the 2006 CTG for offset lithographic printing and letterpress printing. SCAQMD amended Rule 1130 on May 2, 2014 to conform to the CTG and on July 14, 2015, the EPA approved it into the SIP as implementing RACT

.

To deter mine whether AVAQMD Rule 1130 ’s flexographic specialty ink VOC content limit is more stringent than the SCAQMD limit, we found that AVAQMD further limits flexographic specialty ink s to no greater than 300 g/l f or facilities with the potential to emit or wi th actual emissions of at least 10 tpy ( AVAQMD Rule 1130 (C)(2)(b)

- SIP approved on October 5, 2015 )

. However, d iscussion with AVAQMD indicates they have

no flexographic printers. 15 We therefore continue to believe SCAQMD Rule 1130 implements current RACT and we are not aware of any information that would alter our prior determination. No further action is required for RACT.

5) Rule 1112 Emissions of Oxides of Nitrogen from Cement Kilns and Rule 2002 Allocations for Oxides of Nitrogen (NOx) and Oxides of Sul fur (SOx)

14 2016 AQMP RACT SIP page 3.

15 Email dated April 30, 2015 , from Tracy Walters ( AVAQMD ) to Vanessa Graham (USEPA), RE: “ AVAQMD Rule 1130

– Graphic Arts”

.- 12

- Portland cement is manufactured by mixing together raw materials at high temperatures in a rotary kiln. The intermediate product that exit s the kiln is called “clinker”, which is then ground up to make cement. 16

SCAQMD action:

SCAQMD determin ed its NOx emissions rate limit for cement kilns is slightly higher (2.73 vs 2.3 lbs/ton of clinker) than the limit in BAAQMD Regulation 9, Rule 13. SCAQ MD further notes that the averaging time for its NOx limit i s one year using a continuous emissions mon itoring system, while the BAAQMD allows a 30 day averaging period. The 2016 AQMP RACT SIP states it will assess the feasibility of reducing NOx emissions from cement kilns through its RECLAIM program and will compare the impacts of alternate averaging peri ods. 17

EPA Evaluation

Subsequent to the 2016 AQMP RACT SIP submittal, SCAQMD determined that both cement plants in the District (Cal Portland Cement and Riverside Cement) are no longer producing clinker. 18 Specifically, SCAQMD stated the permits for the tw o cement kilns at Cal Portland Cement have been inactive and all permits at Riverside Cement have been inactivated and the facility is officially shut down. EPA Region 9 Air Enforcement staff also confirmed that the cement kilns are shutdown. Consequ ently, the EPA concludes there are currently no major NOx sources of Portland cement kilns in the District and this source category is no longer subject to RACT since there are no major source cement kilns operating in the District

.
Nonetheless, we note that th e District amended its RECLAIM rule on December 4, 2015 to lower the NOx emission factor for cement kilns to 0.5 lb per ton of clinker.

6) Rule 1128 Paper, Fabric, and Film Coating Operations

SCAQMD action:

Rule 1128 is not discussed in the SCAQMD’s 2016 AQMP RACT SIP

. The District’s 2007 AQ MP (Table 3) compares Rule 1128’s 15% VOC limit or 85% capture and control against the Midwest Regional Planning Organization ( RPO ) ’s proposed limit of 100% capture and 90

- 95% control efficiency for existing sources an d 97% control for

16 EPA 530

- R

- 08

- 007, Study on Increasing the Usage of Recovered Mineral Components in Federally Funded Projects Involving Procurement of Cement or Concrete ; Appendix A: Overview of Portland Cement and Concrete. https://www.epa.gov/sites/production/files/2016

- 03/documents/repo rt4

- 08.pdf

17 2016 AQMP RACT SIP page 3 and SCAQMD Board Meeting June 6, 2014, Agenda No. 31 page 3.

1 8 Email dated January 15, 2016 , from Sang

- Mi Lee ( SCAQMD ) to Stanley Tong (USEPA), RE: “ FW Cal Portland Cement and Riverside Cement Permit Status”

.- 13

- new/reconstructed sources

. 19 SCAQMD’s 2007 AQMP states the “incremental increase from 85% to 90

- 97% in control efficiency is not cost

- effective for the existing sources in the South Coast air basin.” The District’s January 2015 Supplement to the 24

- Hour PM 2.5 State Implementation Plan states the District’s rule is more stringent than the 2007 CTG and the incremental increase in control efficiency is not cost

- effective. 20

EPA Evaluation

Rule 1128, amended March 8, 1996, specifies a maximu m VOC content of 265 grams per liter for coatings or allows compl iance using an approved emissions control system meeting 90% capture and 95% control for any coating in any paper, fabric or film coating application process

. Cleaning materials are limited t o 15% or less VOC or 85% capture and control efficiency.

The CTG for Paper, Film and Foil Coatings (EPA 453/R

- 07

- 003) recommends an overall VOC control efficiency of 90 percent for each coating line. Alternatively, the CTG allows emission limits that are equivalent to 90 percent overall control. The CTG applies to individual surface coating lines with a potential to emit, prior to controls, of at least 25 tpy of VOC.

For cleaning materials, the 2007 CTG does not recommend add

- on controls . It states “Add

- on controls would be a costly alternative for reducing VOC emissions from cleaning materials because the area to be controlled is quite large and a large volume of air would be captured and directed to a control device.” The CTG also states it does not rec ommend the use of a VOC content or VOC composite vapor pressure limit for cleaning materials.

Subsequent discussion with SCAQMD indicated it does not have any paper coating facilities subject to the CTG’s applicability threshold of at least 25 tpy of VOC , prior to controls for individual coating lines

. 21 We therefore conclude SCAQMD does not have sources subject to the paper coating portion of the CTG for Paper, Film, and Foil coatings. Also see the earlier discussion on negative declarations.

7) Motor Veh icle Assembly Line Coatings Rule 1115

SCAQMD action:

19 Th e 2007 AQMP does not provide a citation to the RPO proposal. We found Identification and Evaluation of Candidate Control Measures, April 14, 2005 ( http://www.ladco.org/reports /control/bart/final_report_mactec.pdf p.21) which lists potential recommendations to tighten RACT, but it appears these recommendations have not been adopted. e .g., Illinois’ paper coating limits were effective 6/19/1998. See Section 215.204 http://www.ipcb.state.il.us/documents/dsweb/Get/Document

- 11924

20 Supplement to the 24

- Hour PM 2.5 State Implementation Plan for the South Coast Air Basin, Board Meeting Date February 6, 2015 , Agenda No. 22, page D

- 33. http://www.aqmd.gov/docs/default

source/Agendas/Governing

- Board/2015/2015

- feb6

- 022.pdf?sfvrsn=2

21 Email dated Febru ary 4, 2016, from Kalam Cheung (SCAQMD) to Stanley Tong (USEPA), RE: “2014 Ozone RACT SIP

- Rule 1106 and Rule 1128”.- 14

- SCAQMD ’s 2016 AQMP RACT SIP does not address coatings from automobile assembly line coating s, but its 2012 AQMP for the 24

- hour PM 2.5 standard states the Auto and Light

- Duty Truck Assembly Coatings “CTG has more stringent limits for electro

- deposition primer at 84 g/L (145 g/L in Rule 1115); sprayable primer, primer

surfacer, and topcoat at 144 g/L (180 g/L in Rule 1115); and trunk coatings, interior coatings, sealers, and deadeners at 650 g/L (Rule 1115 exempt s these categories). The District’s 2012 AQMP states that Rule 1115 has a small inventory of about 0.01 tpd, thus no action is needed. ” 22 The District ’s November 2014 S upplement al Analysis to the 2016 AQMP RACT SIP further states that Rule 1171, Solvent Cleaning Operations, has strict VOC emissions limits (25 grams/liter) on solvent cleaning procedures and therefore Rules 1115 and 1171 combined meets federal RACT requirements.

EPA Evaluation

CAA §182(b)(2 ) requires CTG sources and major non

- C TG sources to implement RACT. RACT under section 182(b) (2) differs from RACM/RACT under section 172(c) in that section 182(b)(2) is a technology control

- based requirement and is not obviated because the emissions inventory for a particular stationary sour ce category is very small and will not advance attainment

.

SCAQMD’s November 2014 S upplement al Analysis indicates the following facilities are subject to Rule 1115

– Motor Vehicle Assembly Line Coatings :

AMREP Inc, Ontario, CA

- 9906 lbs/yr; 4.9 tpy

man ufactures refuse trucks 23

The Paint Department

, Chino, CA

- 6919 lbs/yr; 3.5 tpy refinishes recreational and commercial vehicles 24 Not subject to RACT as vehicle refinishing is not a CTG and this is not a major source

El Dorado National

– Riverside, CA

– 5897 lbs/yr; 2.9 tpy manufactures buses

On further discussion with SCAQMD and EPA’s Office of Air Quality Planning and Standards, it was determined that the coating of heavier duty vehicles are covered by the CTG for Miscellaneous Metal and Plastic Parts Coatings and not the CTG for Auto

22 Final 2012 AQMP for 24

- hour PM 2.5 , February 2013, Appendix VI: Reasonably Available Control Measures (RACM) Demonstration, page VI

- 10. http://www.aqmd.gov/docs/default

- source/clean

- air

- plans/air

- qu ality

management

- plans/2012

- air

- quality

- management

- plan/final

- 2012

- aqmp

- %28february

- 2013%29/appendix

- vi

- final

2012.pdf

23 The company’s web site states its assembly line produces 500 reuse trucks per year. http://www.amrepinc.com/assemblyline.htm

24 The Paint Department refinishes recreation and commercial vehicles and is not subject to the CTG for Automobile and Light Duty Truck Assembly Coatings. ht tp://www.thepaintdepartment.com/- 15

- and Light

- Duty Truck Assembly Coatings

. Therefore, Rule 1107, Coating of Metal Parts and Products, and not Rule 1115, Motor Vehicle Assembly Line Coating Operations, is the appropriate rule to compare against EPA’s 2008 C TG for Miscellaneous Metal and Plastic Parts Coatings. We agree that Rule 1107 implements RACT for heavier duty vehicles

. No further SCAQMD action is required to demonstrate RACT for this category.

8) Marine Coating Operations Rule 1106

SCAQMD action:

Ru le 1106 is not discussed in the SCAQMD’s 2016 AQMP RACT SIP. The District’s 2012 AQMP for the 24

- hour PM 2.5 standard states its VOC content limits are generally similar to those in Ventura Rule 74.24 and Bay Area 8

- 43, except Bay Area has a lower limit for pretreatment wash primer at 420 g/L (780 g/L in Rule 1106) and recommends to further study the potential of lowering the emission standards

. 25

Subsequent to submitting its 2016 AQMP RACT SIP, SCAQMD ’s web site indicated the District plans to revise Rule 1 106 to subsume the requirements of Rule 1106.1

– Pleasure Craft Coatings Operations and to revis e the VOC content limits for pretreatment wash primers, antenna

, repair and maintenance thermoplastic, inorganic zinc, and specialty marking coatings in order t o align the limits with the EPA ’s CTG and other California air districts. 26

EPA Evaluation

The EPA’s CTG for shipbuilding and repair facilities states “the NESHAPS can be used

as a ‘ model rule ’ ”. 27 We reviewed the VOC content limits in 40 CFR Part 63 subp art II National Emission Standard for Shipbuilding and Ship Repair (Surface Coating) against Rule 1106 and agree with SCAQMD’s assessment that Rule 1106’s VOC content limit is consistent with the NESHAPs with the exception of inorganic zinc (650 g/L vs 34 0 g/L). ‘

The S hipbuilding and S hip R epair (Surface Coating) NESHAP applies to major source facilities . The provisions do not apply to coatings used in volumes < 52.8 gallons / year provided the total volume of coatings exempted does not exceed 264 gallons per year at any facility. 28 Subsequent to the 2016 AQMP RACT SIP submittal, SCAQMD

25 Final 2012 AQMP for 24

- hour PM 2.5 , February 2013, Appendix VI: Reasonably Available Control Measures (RACM) Demonstration, page VI

- 33. http://www.aqmd.gov/docs/default

- source/clean

- air

- plans/air

- quality

management

- plans/2012

- air

- quality

- management

- plan/final

- 2012

- aqmp

- %28febru ary

- 2013%29/appendix

- vi

- final

2012.pdf

.
26 Draft Staff Report, Proposed Amended Rule 1106

– Marine and Pleasure Craft Coating Operations, September 2015, p

. 1

- 1. http://www.aqmd.gov/docs/default

- source/rule

- book/Proposed

- Rules/1106/par

- 1106

- draft

- staff

report

- 09

- 01

- 15.pdf?sfvrsn=6

27 61 FR 44050, 44052 (August 27, 1996) https://www3.epa.gov/airquality/ctg_act/61_FR_1996

- 08

- 27_44050.pdf

28 40 CFR 63.781 http://www.ecfr .gov/cgi

- bin/text

idx?SID=ff727d5f02984f37f4e253eb13951517&mc=true&node=se40.11.63_1781&rgn=div8- 16

- determined that it only has one Ti tle V shipyard, Willard Marine

, and the shipyard does not use inorganic zinc coatings. 29 CARB’s 201 3 emissions inventory shows the total VO C emissions was 2 tpy for this facility and the facility does not appear in CARB’s 2014 or 2015 inventory

. The District may want to evaluate adopting a negative declaration for this category

s ince it doesn’t appear there are facilities that exceed the CT G ’s applicability threshold,

9) Adhesive and Sealant Applications Rule 1168

SCAQMD action

In its 2012 AQMP, Table VI

- 4, SCAQMD indicates Rule 1168 does not fully meet the 20 08 CTG, and it may pursue a rule update. SCAQMD states t he following catego ri es are not consistent with EPA’s 2008 CTG for Miscellaneous Industrial Adhesives : 1) reinforced plastic composite VOC limit: CTG 200 g/l, Rule 250 g/l, 2) single

- ply roof membrane adhesive primer: CTG 250 g/l, Rule 450 g/l, 3) other adhesive primers: C TG 250 g/l, Rule 420 g/l, 4) VOC control efficiency: CTG 85%, Rule 80%.

EPA evaluation

EPA considers the 2008 CTG reinforced plastic composite category (200 g/l) to be the

same as Rule 1168’s fiberglass category (80 g/l) and find that the SCA QMD rule is more stringent than the CTG. For the single

- ply roof membrane adhesive and adhesive primer category, t he 2008 CTG recommends a limit of 250 g/l. Rule 1168 matches the se limits. 30 Rule 1168 limits single ply roof membrane sealants to 450 g/l whil e the CTG does not regulate this category. SCAQMD should update its 80% control efficiency limit to meet the 85% CTG recommendation.

10) Cutback Asphalt Rule 1108 and Emulsified Asphalt Rule 1108.1

If additional emissions reductions are needed beyond RACT, t he District may want to investigate Warm M ix asphalt as an option to hot mix asphalt

– See San Joaquin 2015 DRAFT Warm Mix Asphalt Further Study Report http://www.valleyai r.org/notices/Docs/2015/12

- 01

- 15_%28WMA%29/WMA.pdf and EPA’s December 23, 2015 comments on the draft report.

11) Newer versions of rules not submitted for SIP approval

The following table list s SCAQMD amended rules that have not been submitted to the EPA fo r SIP approval . The May 1, 2009 amendment to Rule 1171 extends a n exemption f or cleaning of application equipment used to apply solvent

- borne fluoropolymer coatings

29 Email dated February 4, 2016, from Kalam Cheung (SCAQMD) to Stanley Tong (USEPA), RE: “2014 Ozone RACT SIP

- Rule 1106 and Rule 1128”.

30 Rule 1168 has a cat egory called architectural non porous sealant primers which we believe correlates to the 2008 CTG’s adhesive primer category.- 17

- which expired on December 31, 2008 in the SIP approved version of the rule (February 1, 200 8)

. T his creates a SIP gap where the local rule a llows this exemption , but the SIP rule does not and could leave a facility vulnerable as EPA would enforce the SIP rule requirements

.

12) NOx RECLAIM

The EPA first approved SCAQMD’s RECLAIM program into the California SIP in June 1998 based in part on a conclusion that the NOx emission caps in the program satisfied the RACT requirements of CAA section 182(b)(2) and (f) for covered NOx emission sources in the aggregate. 31 In 2005 and 2010, the District adopted revisions to its RECLAIM program, which the EPA approved on August 29, 2006 and August 12, 2011, respectively, based in part on conclusions that the revisions continued to satisfy RACT requirements at the time of the rule revisions. 32 However, based on new information contained in SCAQMD’s December 2015 Draft Final Staff Report (“2015 staff report”) revising Rule 2002 “ Allocations f or Oxides o f Nitrogen (NOx) a nd Oxides o f Sulfur (SOx) ”, additional NOx reductions are now required to achieve RACT, as evidenced by the lack of controls on some refinery boil er units and the District’s proposal to reduce the NOx RECLAIM emissions cap. 33

A more detailed discussion about RECLAIM and the requirement that the program ensures, in the aggregate, NOx emissions reductions equivalent to RACT

- level controls can be foun d in our partial approval/disapproval of the South Coast Moderate Area Plan for the 2006 PM 2.5 NAAQS. 34 We propose to partially approve and partially disapprove the 2016 AQMP RACT SIP certification because the District’s 2015 staff report states that

some r efinery boilers/heaters were expected to, but did not install controls such as selective catalytic reduction that the District considers available, achieved

- in

- practice and

31 See EPA’s partial approval / disapproval of SCAQMD Moderate Area Plan for the 2006 PM 2.5 NAAQS at 81 FR 22025 , 22027 (April 14, 2016) citing 61 FR 57834 (November 8, 1996) and 63 FR 32621 (June 15, 1998)

32 71 FR 51120 (August 29, 2006) and 76 FR 50128 (August 12, 2011).

33 Draft Final Staff Report, Proposed Amendments to Regulation XX Regional Clean Air Initiatives Market (RECLAIM) NOx RECLAIM, December 4, 2015 http://www.aqmd.gov/docs/default

- source/Agendas/Governing

Board/2015/2015

- dec4

- 030.pdf?sfvrsn=9

34 81 FR 22025 , 22027 and 22028 (April 14, 2016) discussing an absence of a demonstration that the 2010 RECLAIM program ensures, in the aggregate

, NOx emission reductions equivalent to RACT

- level controls. Rule Current SC Version Submitted Current SIP Approv ed version 1122 S olvent Degreasers 5/1/09 No 10/1/04 2/8/06 (71 FR 6350) 1171 Solvent Cleaning Operations 5/1/09 No 2/1/08 9/29/11 (76 FR 60376)- 18

- cost effective and that a new revised NOx RECLAIM cap is needed to ensure RACT is b eing achieved. 35

On December 4, 2015, SCAQMD adopted a new NOx emissions cap for RECLAIM which reflects a best available retrofit control technology level of 2 ppmv NOx for refinery boilers/heaters >40 MMBtu/hr indicating that controls “are either commerci ally available, achieved

- in

- practice and/or can be designed to achieve 2 ppmv NOx in a cost

- effective manner.” 36 The EPA will evaluate the December 4, 2015 RECLAIM Rule amendment for RACT when it is submitted for SIP approval

.

Public Comments

SCAQMD’s 201 6 AQMP RACT SIP was made available for public comment. The Board hearing package states one comment was received during the 30

- day public notice period “pertaining to reduction of methane and related gases emanating from oil and gas wells.” The District’s response stated “such emission reductions may be suited for a future control measure investigation, since a RACT analysis is restricted only to adopted rules and regulations.” No comments were receive during the Board hearing.

Summary With the exception o f Rule 2002, S C AQMD ’ s 2016 AQMP RACT SIP as supplemented by its 2007 , 2012 AQMPs and November 2014 S upplemental Analysis largely support s the District ’ s certification that its regulations meet or exceed RACT

. Rule 2002 (November 5, 2010) does not implemen t RACT as evidenced by the lack of controls on some refinery boiler units and the District’s proposal to reduce the NOx RECLAIM emissions cap.
We propose to approve SCAQMD’s certification that its rules satisfy RACT, with the exception of Rule 2002’s NOx emissions cap. We propose to disapprove SCAQMD’s determination that the November 5, 2010 SIP version of Rule 2002 continues to implement NOx RACT in the aggregate for certain NOx sources. Final disapproval will result in offset and highway sanctions unless EPA approves a SIP revision amending Rule 2002 as fulfilling NOx RACT for refinery boilers within 18 months of the effective date of the disapproval. See CAA section 179(b) and 40 CFR 52.31. We will not finalize this partial disapproval, however, if we fu lly approve a rule fulfilling NOx RACT for refinery boilers before finalizing action on the 2016 AQMP RACT SIP. EPA is committed to working with CARB and the District to resolve th is RACT deficienc y , and we encourage the State and District to submit a SIP revision correcting the identified deficienc y as expeditiously as practicable. A revised 2016 AQMP RACT SIP demonstration will not be necessary if the submitted rule amendments correct the identified deficienc y

.

35 Draft Final Staff Report, Proposed Amendments to Regulation XX Regional Clean Air Initiatives Market (RECLAIM) NOx RECLAIM, December 4, 2015 (p. 78, 92, 267

- 268)

36 Id. (p. 92)- 19

- In addition, CAA section 110(c)(1) provides that EPA must promulgate a Federal Implementation Plan (FIP) within two years after finding that a State has failed to make a required submission or disapproving a SIP submission in whole or in part, unless EPA approves a SIP revision correcting the defic iencies within that two

- year period.

Suggestions for Improvement

1) Negative Declarations

– evaluate adopting negative declarations for the paper coating portion of the Paper, Film, and Foil coating CTG and for the Shipbuilding and Ship Repair (Surface Coa ting) CTG or amending the associated rules

. 2) Rule 1118 Flares

– E valuate expanding the rule to i nclud e non

- refinery / non

- landfill flares (e.g., oil and gas production and wastewater f lares) similar to San Joaquin Rule 4311 which requires a flare minimizat ion plan for all flares >5 MM BTU/hr. If additional reductions are needed, e valuate whether increased flaring (e.g., routine use of emergency flares) at oil production facilities or wastewater treatment facilities are occurring due to more stringent gas con stituent limits imposed by pipeline gas companies or power plants

. 3) Rule 462 Organic Liquid Loading

– Evaluate adopting a VOC limit of 0 .04 pounds/1000 gallons of organic liquid transfer subject to the outcome of the District ’s evaluation of differences in bulk terminal and cargo tank monitoring protocols between BAAQMD and SCAQMD.

REFERENCES

-

1. S C AQMD 2016 AQMP Reasonably Available Control Technology (RACT) Demonstration , dated May 22, 2014, Adopted June 6, 2014; Submitted

– July 18, 2014. http://www.aqmd.gov/docs/default

- source/Agendas/Governing

- Board/2014/2014

- jun6

- 031.pdf?sfvrsn=2

2. RACT SIPs, Letter dated March 9, 2006 from EPA Region IX (And rew Steckel ) to CARB (Kurt Karperos) describing Region IX ’ s understanding of what constituted a minimally acceptable RACT SIP

.

3. RACT SIPs, Letter dated April 4, 2006 from EPA Region IX (Andrew Steckel) to CARB (Kurt Karperos) listing EPA ’ s current CTGs, AC Ts, and other documents which may help to establish RACT.

4. RACT Qs & As

– Reasonably Available Control Technology (RACT): Questions and Answers, May 18, 2006 Note from William T. Harnett, Director, Air Quality Policy Division, to Regional Air Division Dire ctors. https://www3.epa.gov/ttn/caaa/t1/memoranda/ractqanda.pdf

5. “ Final Rule to Implement the 8

- Hour Ozone National Ambient Air Quality Standard

– Phase 2 ” (70 FR 71612; November 29, 2005). https://www.gpo.gov/fdsys/pkg/FR

- 2005

- 11

- 29/pdf/05

- 22698.pdf- 20

- 6. “ Implementation of the 2008 National Ambient Air Quality Standards for Ozone: State Implementation Plan Requ irements’’ (80 FR 12264; March 6, 2015). https://www.gpo.gov/fdsys/pkg/FR

- 2015

- 03

- 06/pdf/2015

- 04012.pdf

7. “ Issues Relating to VOC Regulation Cutpoints, Deficiencies, and Deviati ons, ” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988 http://archive.epa.gov/ttn/ozone/web/pdf/voc_bluebook.pdf

8. “ Guidance Document for Correcting Common VOC & Other Rule Deficiencies, ” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001 http://www.arb.ca.gov/drdb/lbb2001.pdf

9. “ State Implementation Plans, General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 ” ( 57 FR 13498; April 16, 1992); (57 FR 18070; April 28, 1992)

.

10. “ State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 ” (57 FR 55620, Nove mber 25, 1992) ( “ the NOx Supplement ” ).

11. EPA ’ s CTGs and ACTs https://www.epa.gov/ozone

- pollution/control

- techniques

guid elines

- and

- alternative

- control

- techniques

- documents

- reducing

12. CARB ’ s emissions inventory database http://www.arb.ca.gov/app/emsinv/facinfo/facinfo.php

13. SC AQMD, CARB, and EPA Region IX databases of S C AQMD rules SC AQMD: http://www.aqmd.gov/home/regulations/rules/scaqmd

- rule

- book CARB: http://www.arb.ca.gov/rld b/rldb.htm EPA: http://www.epa.gov/approved

- sips/approved

- sips

- region

- 9

14. EPA Region 9 December 23, 2015 comments on San Joaquin Valley APCD’s 2015 DRAFT Warm M ix Asphalt Further St udy Report.

15. 2007 AQMP Appendix VI: Reasonably Available Control Measures (RACM) (June 2007) http://www.aqmd.gov/docs/default

- source/clean

- air

- plans/air

- quality

management

- plans/2007

- air

- quality

- management

- plan/2007

- aqmp

- appendix

vi.pdf?sfvrsn=2 ;

16. 2012 AQMP Appendix VI: Reasonably Available Control Measures (RACM) Demonstration (February 20 13) http://www.aqmd.gov/docs/default

- source/clean

- air

plans/air

- quality

- management

- plans/2012

- air

- quality

- management

- plan/final

- 2012

- aqmp

- (february

- 2013)/appendix

- vi

- final

- 2012.pdf- 21

- 17. San Joaquin Valley APCD, 2015 DRAFT Warm Mix Asphalt Further Study Report

, December 1, 2015 http://www.valleyair.org/notices/Docs/2015/12

- 01

- 15_%28WMA%29/WMA.pdf

18. Draft Final Staff Report, Proposed Amendments to Regulation XX Regional Clean Air Initiatives Market (RECLAIM) NOx RECLAIM, December 4, 2015 http://www.aqmd.gov/docs/default

- source/Agendas/Governing

- Board/2015/2015

- dec4

- 030.pdf?sfvrsn=9

19. Email dated November 25, 2014, from Joe Cassmas si (SCAQMD) to Stanley Tong (USEPA), RE: “SCAQMD RACT Analysis Draft 20141119(2) hereinafter “November 2014 Supplemental Analysis”.

20. Email dated April 30, 2015, from Tracy Walters (AVAQMD) to Vanessa Graham (USEPA), RE: “AVAQMD Rule 1130

– Graphic Arts”.

21. Email dated January 15, 2016, from Sang

- Mi Lee (SCAQMD) to Stanley Tong (USEPA), RE: “FW Cal Portland Cement and Riverside Cement Permit Status”.

22. Email dated January 29, 2016, from Kalam Cheung (SCAQMD) to Stanley Tong (USEPA), RE: “New Title V Faciliti es since 2006”.

23. Email dated February 4, 2016, from Kalam Cheung (SCAQMD) to Stanley Tong (USEPA), RE: “2014 Ozone RACT SIP

- Rule 1106 and Rule 1128”.