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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 1990E. GettysburgAvenue Fresno, California 93726 

# #5&4:/ Dear Mr.

EPA appreciatesthe 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/m324-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 appreciatesyour willingnessto facilitatethat. 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 commentsbelow. 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 developmentthat continue to provide additional reductionsbetween 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/m3standard by 2019 in most of the SJV. Given the importance of an accurate understanding of these baseline measures for attainment planningpurposes, we recommend that the plan identify the specific measures that are providing the identifiedbaseline 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 describesprojected population growth, it does not describe the other parametersused 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~rrtedon Rec\cled Paper

" - 

## --Recluirementsfor 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 economicallyand technologically feasiblemeasures that are necessary to provide for attainment as expeditiouslyas practicable or to demonstrate reasonable Mer progress. See 40 CFR 

## 5 5 1.10 10; see also 70 FR 7 1612 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 feasibilitymust be adopted as RACM if, considered individuallyor 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 anypotential RACM that are not adopted and to quantifypotential emissionreductions 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 similarto 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 inventorywith 2008 PM2.5 Plan controls" and the "emissions target." This analysis is also an importantpart 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 12,2012 comments to ARB on the draft modeling protocol, we emphasized the importance of exploring the benefits of controllingprecursors other than NOxand SO,, such as VOC or ammonia. While we agree that the control ofNOxis effective, we believe the severity of the PM2.5 problem in the SJV necessitates evaluatingwhether control of other precursors will expedite attainment. In addition to calculating the amount of additional emissionsneeded to advance attainmentby a year under a mainlyNO,-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 SourceReview (NSR)program, the Plan should document the methods used to derive equivalencyratios. This documentation should include rationales explainingwhy the methods are reasonable for the specificrequirement. The methods should be based
on the photochemical modeling used in the attainment demonstration and should account for the variability ofpollutant and precursorrelationships across the air basin. Since trading may involve emissionreduction credits created some time ago under different atmospheric conditions than currently

### exist, the rationale should account for this situation. Note that under the PM2.5NSR 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 ofthe PM2.5 attainment plan for the area.
Comments on SpecificRules

In 2009, the District completed an analysis of all RACT required for Ozone precursors (VOC and NOx), which EPA largely approved in 20 11. Appendix D to the draft PM2.5 Plan provides a somewhat analogous analysis for PM2.5 sources. Despite significant overlapbetween these two documents, we recommend additional informationin the PM2.5 analysis below, particularly includingwhere: (1) the analysis asserts additional control is too costly without providing supportinginformation 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 ofthe 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 addingPM2.5 limits to the rule in addition to existing SO, limits for non-PUC qualitynatural 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 citationto 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 Generatorsand 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 citationto analysis)of Mer controls, including those required by Bay Area Air Quality Management District's (BAAQMD) Rule 9-6 (20 instead of 55 ppm NOxfor certain water heaters) and previouslyrecommended 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 addingPM2.5 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 additionto SO, limits and analyze whether it is reasonable to require agriculturalIC enginesto complywith 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 comparabilityto federal rules and regulations (page D-27), we recommend also

1 40 CFR Part 51Appendix S, paragraph 1V.A and 40 CFR 51.165(a)(11); see also preamble to "Implementation of the New Source Review (NSR) Programfor Particulate Matter Less Than 2.5 Micrometers (PM2.5)",73 FR 28321at28339, May 16, 2008.referencing40 CFR 60 Subpart 

### KKKK, Standards of Performance for StationaryCombustion 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 SO2limits at least as stringent as the Subpart 

### KKKK requirements. Page D-27 explains that new and major modificationsmust implement BACT for NO, and PM2.5 and BACT limits are more stringent than Rule 4703. Page D-28 includes a NOxBACT 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..



### .fueltreatment sulfurremoval systemsto reduce SO, emissions and foster additionalPM2.5 reductions." It appears that at least one facilityin 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 analyzePM2.5 BACT costeffectiveness. We recommend additional discussion of this facility to help evaluatewhether 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 electrostaticprecipitators (ESPs). While the District states that these technologies have not been achieved in practice for stationarygas 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 11,Flares -Beginning July 1,2010,Rule 43 1 1 required all operators ofpetroleum refinery flares and any flareswith flaring capacity greater than or equal to 5.0 MMBtu per hour to submit flare minimization plans (FMPs). Beginning July 1,2011, operators of flares subject to FMPs were required to begin recordkeeping on all flaring events. By July 1,2012, 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 flaringevents. This new information regarding flares in SJV may provide information on how to Mer reduce flaringemissions. Also, page D-32 acknowledges EPA's previous recommendations to further strengthen the rule but does not discussthem in detail. These recommendations are requirementsfrom other California district flare rules, and demonstrate areas where BAAQMD or South Coast Air QualityManagement District (SCAQMD)rules seem more stringentthan Rule 43 11. The specificrecommendations, such asrequiring 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 flarereports to update the emissions inventoryand analyze EPA's additional recommendations (fiom the TSD associated with the proposed approval of Rule 43 11,at 76 FR 52623)to help reduce emissions. We also ask that the District consider the previous recommendation to develop separate refinery and non-refineryflare 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 containerplants in Table 3 of Rule 4354, which limits emissionsto 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 feasiblebut may be cost prohibitive. We recommend providing more detailed costeffectiveness analysis (or citationto analysis) of additionalcontrols, including those required by BAAQMD Rule 9-1, to support the RACM analysis.

D.3.1 Rule 4103, Open Burning -

### Given the significance ofthis 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 Sadredinto 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 reductionburning. As reference, the Placer CountyAir 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 ofthe ConservationTillage 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 

### 138PAR

### 1138PDSR.pdC page 9) notes that smoke in the cooking area can result if control equipment is not cleaned at the proper frequencyand 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 certified control device similar to SCAQMD Rule 1138 (d)(l)(B) (http 

### to help ensure rule effectiveness.

Given the significant emissions from underfired charbroilers, we also support the District's work with BAAQMD and SCAQMDto 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 ofthe wood burning season, we agree with the draft plan that further strengthening of the District's existing successfulwood burning deviceprogram should be considered to supportthe 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 appropriateto 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 indicatesdevelopment 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, particularlybecause of the relatively large emissionsassociated with this source, to support the RACM analysis.

D.7.5 SC 005, AsphaltlConcrete Operations 

## - We recommend evaluating whether warm mix asphalt is technicallyand economicallyfeasible and appropriate for RACM. Warm mix asphalt operates at lower temperaturesthan hot mix asphalt, saving fuel and, based on some reports, possibly reducing PM emissionsby 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 contactme at (4 15) 947-4 157,Frances Wicher at (4 15)972-3957, or Andrew Steckel at (4 15) 947-4 115 if you have any questions or need clarificationofthese comments. Sincerely, ,--



### K~w Associate 

# vA

Director, Air Division

cc: Karen Magliano, CaliforniaAir Resources Board Sylvia Zulawnick, California Air ResourcesBoard