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uizi UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

3 5 ,o* REGION IX 4t PROT~G' 75 Hawthorne Street 

San Francisco, CA 94105-3901 

Mr. Samir Sheikh 

Director of Strategy and Incentives 

San Joaquin Valley Air Pollution Control District 

1990 E. Gettysburg Avenue 

Fresno, California 93726 

Dear Mr. #5&4:/ 

EPA appreciates the opportunity to review the most recent draft of the San Joaquin Valley Air Pollution 

Control District's (District's) 2012 PM2.5 Plan. Thank you for continuing to work with EPA, the 

California Air Resources Board (ARB), the Metropolitan Planning Organizations (MPOs) and all 

stakeholders to ensure that the Plan provides for expeditious attainment of the 35 pg/m3 24-hour PM2.5 

standard in the San Joaquin Valley (SJV) and to address community and industry concerns. EPA 

Regional Administrator, Jared Blumenfeld, has committed that EPA will be involved with you early in 

the process and appreciates your willingness to facilitate that. This draft reflects extensive effort from 

you and your staff, and we understand that much additional work at the District and ARB is underway. 

We provide preliminary comments below. 

Documentation of the Baseline Emissions Inventory 

Baseline emissions inventories are the projected future inventories that incorporate reductions from 

baseline control measures; that is, measures adopted prior to a plan's development that continue to 

provide additional reductions between the base year and the attainment year. 

Preliminary results of the air quality modeling as presented by ARB at the June 2012 workshop show 

that baseline measures are expected to provide for attainment of the 35 pg/m3 standard by 2019 in most 

of the SJV. Given the importance of an accurate understanding of these baseline measures for attainment 

planning purposes, we recommend that the plan identify the specific measures that are providing the 

identified baseline reductions and the emissions reductions associated with each measure. The Plan 

should also highlight those baseline measures with compliance dates during the period that the Plan 

covers. We note that the Plan already describes many of the measures that have been adopted to regulate 

sources in the SJV; however, it does not currently identify the measures for which emission reductions 

are included in the baseline inventories. 

Another important element of the baseline inventory is the growth factors used to project future 

emissions levels. While the draft Plan currently describes projected population growth, it does not 

describe the other parameters used to project growth. We recommend that the plan include a discussion 

of these growth factors including information on their values, the sources from which they are derived 

and the source categories they are used to project. 

I'r~rrted on Rec\cled Paper 

" - - - 
Recluirements for Reasonable Available Control Measures Demonstration 

The 20 12 PM2.5 Plan should provide for implementation of all reasonably available control measures 

(RACM) for existing sources as required by CAA 5 172(c)(l). RACM are those economically and 

technologically feasible measures that are necessary to provide for attainment as expeditiously as 

practicable or to demonstrate reasonable Mer progress. See 40 CFR 5 5 1.10 10; see also 70 FR 7 16 12 

at 7 166 1 (November 29,2005). 

As part of the RACM demonstration, the Plan should include a list of the potential measures considered 

by the State, District, and the SJV MPOs and analysis sufficient to show that all RACM, including 

reasonably available control technologies (RACT), have been adopted and are being implemented 

expeditiously. See 40 CFR 55 1.10 1 O(a). Potential measures that are reasonably available considering 

economic and technological feasibility must be adopted as RACM if, considered individually or 

collectively, they would advance attainment in the area by one year or more. See 40 CFR 5 5 1.1010(b). 

Please work with ARB and the SJV MPOs to identify any potential RACM that are not adopted and to 

quantify potential emission reductions fkom these measures. As part of this analysis, the plan should 

estimate the additional emission reductions needed to advance attainment by one year and should 

include a table similar to Table 9-1 ("San Joaquin Valley PM2.5 Attainment Outlook") fkom SJV's 2008 

PM2.5 Plan with information on the added reductions needed for attainment in each year beyond those 

already anticipated fiom the adopted control strategy. On Table 9- 1, this would be the difference 

between "Emissions inventory with 2008 PM2.5 Plan controls" and the "emissions target." This analysis 

is also an important part of any request under CAA section 172(b) for an extension of the attainment 

date beyond five years. 

Evaluation of PMu Plan Precursors 

In our March 12,20 12 comments to ARB on the draft modeling protocol, we emphasized the 

importance of exploring the benefits of controlling precursors other than NOx and SO,, such as VOC or 

ammonia. While we agree that the control of NOx is effective, we believe the severity of the PM2.5 

problem in the SJV necessitates evaluating whether control of other precursors will expedite attainment. 

In addition to calculating the amount of additional emissions needed to advance attainment by a year 

under a mainly NO,-focused control regime, the Plan's air quality modeling should also evaluate the 

additional emission reductions that would be necessary if additional reductions in VOC and ammonia 

emissions were considered as well. 

Documentation of Interpollutant Trading Ratios 

If the Plan will include provisions that rely on trading between PM2.5 and its precursors to meet Clean 

Air Act requirements (e.g., a trading mechanism for transportation conformity) or if the District intends 

to allow interpollutant trading for offsets in its New Source Review (NSR) program, the Plan should 

document the methods used to derive equivalency ratios. This documentation should include rationales 

explaining why the methods are reasonable for the specific requirement. The methods should be based 

on the photochemical modeling used in the attainment demonstration and should account for the 

variability of pollutant and precursor relationships across the air basin. Since trading may involve 

emission reduction credits created some time ago under different atmospheric conditions than currently 
exist, the rationale should account for this situation. Note that under the PM2.5 NSR implementation 

rule,' interpollutant trading for PM2.5 and its precursors is allowed only upon EPA approval of a specific 

trading hierarchy and ratio(s) as part of the PM2.5 attainment plan for the area. 

Comments on Specific Rules 

In 2009, the District completed an analysis of all RACT required for Ozone precursors (VOC and NOx), 

which EPA largely approved in 20 1 1. Appendix D to the draft PM2.5 Plan provides a somewhat 

analogous analysis for PM2.5 sources. Despite significant overlap between these two documents, we 

recommend additional information in the PM2.5 analysis below, particularly including where: (1) the 

analysis asserts additional control is too costly without providing supporting information or citation; or 

(2) sources emit SO, or direct PM2.5 that were not discussed in the Ozone RACT analysis. Unless 

otherwise indicated, section and page numbers below refer to Appendix D of the June 27,2012 draft 

PM2.5 Plan. 

D. 1.2 Rule 4307, Boilers, Steam Generators and Process Heaters - 2.0 MMBtuihr to 5.0 MMBtuihr - 

We recommend the District consider adding PM2.5 limits to the rule in addition to existing SO, 

limits for non-PUC quality natural gas boilers (e.g., liquid fuel fired boilers). Also, page D-12 

suggests that additional controls are technically feasible but cost prohibitive. We recommend 

providing more detailed cost-effectiveness analysis (or citation to analysis) of Mer controls 

to support the RACM analysis. Such analysis should include more detailed information to 

clarify the relative size of emission inventories, and thus the relative importance in the RACM 

demonstration, associated with Rules 4307,4308 and 4320. 

D. 1.3 Rule 4308, Boilers, Steam Generators and Process Heaters - 0.075 MMBtuihr to less than 2.0 

MMBtuihr - Pages D-14 and 15 suggest that additional controls are technically feasible but 

may be cost prohibitive. We recommend providing more detailed cost-effectiveness analysis 

(or citation to analysis) of Mer controls, including those required by Bay Area Air Quality 

Management District's (BAAQMD) Rule 9-6 (20 instead of 55 ppm NOx for certain water 

heaters) and previously recommended by EPA (removing the RV exemption), to support the 

RACM analysis. 

D. 1.5 Rule 4320, Advanced Emission Reduction Options for Boilers, Steam Generators, and Process 

Heaters Greater than 5.0 MMBtuihr - We recommend the District consider adding PM2.5 limits 

to the rule in addition to SO, limits for liquid fuel fired boilers. 

D. 1.7 Rule 4702, Internal Combustion Engines - We recommend the District consider adding PM2.5 

limits to the rule in addition to SO, limits and analyze whether it is reasonable to require 

agricultural IC engines to comply with the same limits required of non-agricultural IC engines 

if they are constructed and operated similarly. 

D. 1.8 Rule 4703, Stationary Gas Turbines - For completeness regarding the regulatory evaluation 

and comparability to federal rules and regulations (page D-27), we recommend also 

1 40 CFR Part 51 Appendix S, paragraph 1V.A and 40 CFR 51.165(a)(11); see also preamble to "Implementation of the New 

Source Review (NSR) Program for Particulate Matter Less Than 2.5 Micrometers (PM2.5)", 73 FR 28321 at28339, May 16, 

2008. 
referencing 40 CFR 60 Subpart KKKK, Standards of Performance for Stationary Combustion 

Turbines, which includes requirements for NO, and SO2 (the most recent amendment became 

effective on July 6,2006.) Additionally, we recommend the District consider adding SO2 limits 

at least as stringent as the Subpart KKKK requirements. 

Page D-27 explains that new and major modifications must implement BACT for NO, and 

PM2.5 and BACT limits are more stringent than Rule 4703. Page D-28 includes a NOx BACT 

cost-effectiveness estimate of $24,50O/ton, but we recommend the District add the PM2.5 

BACT cost-effectiveness analysis to provide context for the PM2.5 RACM analysis. 

Page D-28 references "the potential control of.. . fuel treatment sulfur removal systems to 

reduce SO, emissions and foster additional PM2.5 reductions." It appears that at least one 

facility in the District is equipped with this system. However, it is unclear whether this facility 

is subject to District Rule 220 1 and therefore was required to analyze PM2.5 BACT costeffectiveness. We recommend additional discussion of this facility to help evaluate whether 

this control is appropriate for PM2.5 RACM. 

Lastly, we recommend the District provide more narrative regarding the status of its research 

regarding baghouses, scrubbers and electrostatic precipitators (ESPs). While the District states 

that these technologies have not been achieved in practice for stationary gas turbines, it is 

unclear what information was considered and whether additional research is underway or 

appropriate. For example, it is unclear whether this information relies partly on technologies 

evaluated through the District's NSR process. 

Rule 43 1 1, Flares - Beginning July 1,2010, Rule 43 1 1 required all operators of petroleum 

refinery flares and any flares with flaring capacity greater than or equal to 5.0 MMBtu per hour 

to submit flare minimization plans (FMPs). Beginning July 1,201 1, operators of flares subject 

to FMPs were required to begin recordkeeping on all flaring events. By July 1,20 12, flare 

operators should have submitted annual reports which include investigations determining the 

cause of flare events, prevention measures considered, volumetric flow of vent gas, vent gas 

composition, and duration of flaring events. This new information regarding flares in SJV may 

provide information on how to Mer reduce flaring emissions. Also, page D-32 

acknowledges EPA's previous recommendations to further strengthen the rule but does not 

discuss them in detail. These recommendations are requirements from other California district 

flare rules, and demonstrate areas where BAAQMD or South Coast Air Quality Management 

District (SCAQMD) rules seem more stringent than Rule 43 1 1. The specific recommendations, 

such as requiring more fiequent causal analysis, describing why a flaring event is consistent 

with the FMP, providing a public process for FMPs, and providing causal analysis for flare 

events between 5,000 and 500,000 scf, may all reduce emissions. We recommend the district 

review the newly submitted annual flare reports to update the emissions inventory and analyze 

EPA's additional recommendations (fiom the TSD associated with the proposed approval of 

Rule 43 1 1, at 76 FR 52623) to help reduce emissions. We also ask that the District consider 

the previous recommendation to develop separate refinery and non-refinery flare rules. 

D.2.4 Rule 4354, Glass Melting Furnaces - Page D-37 states that there are no feasible opportunities 

for additional emission reductions. However, we recommend the District consider lowering the 
existing SO, limits for container plants in Table 3 of Rule 4354, which limits emissions to 0.9 

and 1.1 lbs of SO,/ton of glass depending on cullet content. BACT for this category was 

designated by the District in 2006 at 0.8 lbslton (see 

http://www.valleyair.orghusind/pto/bact/bactLoader.htm). 

D.2.6 Rule 4802, Sulfiuic Acid Mist - Page D-40 suggests that additional controls are technically 

feasible but may be cost prohibitive. We recommend providing more detailed costeffectiveness analysis (or citation to analysis) of additional controls, including those required 

by BAAQMD Rule 9-1, to support the RACM analysis. 

D.3.1 Rule 4103, Open Burning - Given the significance of this source category and the availability 

of economically feasible chipping services, please ensure that the case-by-case analysis of 

citrus orchard removals described in the June 27,20 1 1 letter from Seyed Sadredin to Deborah 

Jordan is being implemented. We also note that reducing emissions from this source could 

affect the annual standard as well as wintertime direct PM2.5. 

D.3.2 Rule 4 106, Prescribed Burning and Hazard Reduction Burning - Page D-48 suggests chipping 

and burn boxes through grant programs may be an alternative to burning for communities 

subject to fire hazard reduction burning. As reference, the Placer County Air Pollution Control 

District conducted such a pilot program and estimated significant emission reductions. 

(http://www.plaeer.ea.gov/Departments/CommunityDevelopment/Plannin~~iomass/-/media~c 

drlPlannin~iomass/mans/07 aped grant Fn %20Rvt 120308.ashx.) 

D.4.1 Rule 4204, Cotton Gins - Page D-53 suggests that additional controls are technically feasible 

but may be cost prohibitive. We recommend providing more detailed cost-effectiveness 

analysis (or citation to analysis) of additional controls to support the RACM analysis. 

D.4.2 Rule 4550, Conservation Management Practices - Page D-5.5 suggests that additional controls 

are technically feasible but may not be cost effective. Please provide a more detailed analysis 

to determine whether requiring additional controls is cost effective. In addition, given research 

showing the efficacy of conservation tillage in reducing PM emissions, please analyze whether 

it is appropriate to allow selection of the Conservation Tillage CMP to have greater weight and 

to fulfill the requirement for CMP selection for multiple cropland categories, thereby 

incentivizing this CMP which helps address multiple air and water quality concerns. 

D.5.1 Rule 4692, Commercial Charbroiling - SCAQMD Rule 1138's staff report 

(http:llwww.aqmd.govlrules/proposed/ 1 13 8PAR 1 13 8PDSR.pdC page 9) notes that smoke in 

the cooking area can result if control equipment is not cleaned at the proper frequency and may 

indicate that control equipment is not hctioning properly. We recommend the District 

consider adopting a requirement to record the date and time of cleaning and maintenance for 

the catalyst or other 

(http 

certified control device similar to SCAQMD Rule 1 138 (d)(l)(B) 

to help ensure rule effectiveness. 

Given the significant emissions from underfired charbroilers, we also support the District's 

work with BAAQMD and SCAQMD to establish cost-effective controls, and we recommend 
that District's PM2.5 Plan include when the joint evaluation with SCAQMD on underfired 

charbroilers controls is expected to be completed. 

D.5.2 Rule 490 1, Wood Burning Fireplaces and Wood Burning Heaters - Given the magnitude and 

timing of the wood burning season, we agree with the draft plan that further strengthening of 

the District's existing successful wood burning device program should be considered to 

support the RACM analysis. 

D.5.3 Rule 4902, Residential Water Heaters - We recommend evaluating rule exemptions (e.g., for 

LPG or liquid fuels), and whether they are still appropriate to help clarify whether controlling 

emissions from non-natural gas fired water heaters are technically and economically feasible 

and should therefore meet PM2.5 RACM. 

In addition, Southern California Gas Company indicates development of low NO, burners may 

achieve < 6ppm NO, for residential water heating. The District may want to investigate this 

research effok for future rule improvements and include the research in Chapter 6, ~echnolo~~ 

Advancement, of the PM2.5 Plan as appropriate. (see slide 19, 

D.6.6 Rule 8061, Paved and Unpaved Roads - Page D-8 1 suggests that additional controls are 

technically feasible but may be cost prohibitive. We recommend providing more detailed costeffectiveness analysis (or citation to analysis) of a lower trip threshold, particularly because of 

the relatively large emissions associated with this source, to support the RACM analysis. 

D.7.5 SC 005, AsphaltlConcrete Operations - We recommend evaluating whether warm mix asphalt 

is technically and economically feasible and appropriate for RACM. Warm mix asphalt 

operates at lower temperatures than hot mix asphalt, saving fuel and, based on some reports, 

possibly reducing PM emissions by 5 1 - 90%. The review should include the potential of using 

warm mix asphalt on public and private roadsllands. See 

http://www.meadwestvaco.comlmwlg;roupslcontentjdocuments/documentjmwO 17395 .pdf. 

Thank you in advance for the opportunity to work with you and your staff as you develop the PM2.5 Plan 

further. Please contact me at (4 15) 947-4 157, Frances Wicher at (4 15) 972-3957, or Andrew Steckel at 

(4 15) 947-4 1 15 if you have any questions or need clarification of these comments. 

Sincerely, ,-- 

K~w Associate vA Director, Air Division 

cc: Karen Magliano, California Air Resources Board 

Sylvia Zulawnick, California Air Resources Board