J. EDSTqT~s . 

2" A°-6 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

~ T REGION IX 

~ 75 Hawthorne Street 

Q~ Pqo ~° San Francisco, CA 94105 - 

OCT 2 7 2006 

October 23, 2006 

Dr. Kevin J. Williams 

Program Coordinator 

Sacramento Metropolitan Air Quality Management District 

777 12thStreet, 3`dFloor 

Sacramento, CA 95814-1908 

Re: Analysis of Reasonably Available Control Technology for the 8-Hour Ozone State 

Implementation Plan, dated September 26, 2006 

Dear Dr. Williams: 

We greatly appreciate SMAQMD's efforts to develop a RACT SIP submittal to meet the 

requirements in Clean Air Act Section 182. The draft analysis is among the most comprehensive 

submittals we have reviewed to date. We have suuunarized some suggestions below for further 

improvement on the analysis. Because RACT SIPs are a new requirement with limited national 

policy or precedent, we are not yet certain which of these comments reflect approvability issues. 

General Comments 

1. The CTG, "Control of VOC Leaks from Petroleum Refinery Equipment" EPA-450/2-78- 

036 appears to have been inadvertently left out of the District's analysis. 

2. The analysis report indicates various District rules meet or exceed RACT. Particularly 

where the last RACT determination for specific source categories occun•ed many years 

ago, the report should reflect some analysis that RACT has not subsequently changed. 

For example, Rule 446 applies to tanks greater than 40,000 gallons and defines gas tight 

as 10,000 ppm at 1 cm. Bay Area AQMD Rule 8-5, Storage of Organic Liquids, has a 

lower applicability threshold and defines gas tight as 100 — 500 ppm at 1 cm depending on 

the component. We also note that a study prepared for the Lake Michigan Air Directors 

Consortium (LADCO) includes lowering the tank size applicability to 10,000 gallons as 

one of many recommendations to tighten RACT. See page 19 of: 

http;//www.ladco.orQ/reports/rno/MWRPOoroiects/Strateaies/Final°/u20Control%20Measures.odf. In this 

light, analysis of Rule 446, Storage of Petroleum Products could be expanded to discuss 

how the rule is considered to meet current RACT. 

Enclosure 1 lists various rules from the staff report which have been amended by the 

District. Those rules which have not yet been submitted for SIP approval should be 

submitted as soon as possible. Where there have been subsequent amendments to a rule, 
we understand that the District_will inform EPA which rule amendment to act on. 

4. Page 101 of the staff report includes specific conditions to be added and amended to the 

Kiefer Landfill Flare permit. These conditions should be included in the final package 

submitted to EPA for inclusion into the SIP. 

Future CTGs 

To assist the District with their planning efforts, we note that on October 5, 2006, EPA 

finalized four new CTGs covering flexible packaging printing materials, lithographic printing 

materials; letterpress printing materials, industrial cleaning solvents and flat wood paneling 

coatings. The new CTGs can be downloaded from this site: 

http://www.epa.gov/ttn/nMs/ozone/ctg act/index.htm While the current RACT SIP analysis 

does not need to address these new CTGs, the Notice points out that States (and local air 

districts) should submit their SIP revisions within one year of the date that the CTGs are 

finalized. Additional CTGs are expected to be issued in 2007 and 2008 (71 FR 28320 May 16, 

2006 http://www.epaov/fedrgstr/EPA-AIR/2006/Mav/Day-16/a7405.pdf ). Further guidance 

will be prbvided once we receive it. 

Please keep in mind that RACT SIP rules were required to be submitted to EPA by 

September 15, 2006, so any required submittals should be submitted as expeditiously as possible 

as EPA cannot consider the RACT SIP analysis complete without the required rules. Final 

irnplementation dates should be no later than the first ozone season that occurs 30 months later. 

For Sacramento Metropolitan AQMD, we believe that is January 1, 2009. 

If you have any questions regarding these comments, please feel free to contact me or 

Stanley Tong at (415) 947-4122. 

Sincerely, 

A, ~ 6V'V 

Andrew Steckel, 

Chief, Rulemaking Office 

Enclosure 

cc: Ravi Ramalingam (CARB) 
Table 1- Rules to be submitted if needed for RACT 

Rule Amended SIP version 

Rule 413 Stationary Gas Turbines 3/24/05 5/1/97 

Rule 442 Architectural Coatings 5/24/01 9/5/96 

Rule 450 Graphic Arts Operations 3/23/00 12/5/96 

11 /29/83 

Rule 451 Surface Coating of Miscellaneous Metal 10/2/97 9/5/96 submitted Parts and Products 

submit 10/2/97 amendment 

Rule 454 Degreasing Operations . 5/23/02 4/3/97 

Rule 456 Aerospace Coating Operations 7/23/98 9/5/96 

Rule 463 Wood Products Coatings 7/23/98 12/5/96 submitted 

Submit 7/23/98 amendment 

Rule 465 Polyester Resin Operations 6/4/98 2/6/97 submitted 

Submit 6/4/98 amendment 

Rule 466 Solvent Cleaning 5/23/02 

Rule 485 Municipal Landfill Gas 7/23/98 

Enclosure (1) 
SACRAMENTO METROPOLITAN 

AIR QUALITY 

MANAGEMENT DISTRICT 

Larry Greene 

AIR POLLUTION CONTROL OFFICER 

October 26, 2006 

Mr. Andrew Steckel 

Rulemaking Office 

Environmental Protection Agency, A-5-3 

75 Hawthorne Street 

San Francisco, CA 94105 

Dear Mr. Steckel: 

Thank you for the comments that you provided in your October 23, 2006 letter on our 

proposed RACT SIP analysis. After consideration of your comments, we have prepared 

the following responses. 

The CTG document "Control of Volatile Organic Compound Leaks from 

Petroleum Refinery Equipment," EPA-450/2-78-036, was inadvertently left out of 

our SIP Revision document. We have added a reference to this CTG to the 

Negative Declaration table for refineries (page 2 of the SIP Revision document). 

This addition does not change ourfindings that we have no refineries within our 

district, and that we do not anticipate such sources in the future. 

2. We recognize that for source categories for which the CTG documents were 

issued many years ago, changes in the development or availability of technology 

could change the current determination of RACT. In addition to the RACT 

requirement, our district has been required to achieve emission reductions 

beyond RACT in federal and state air quality plans designed to meet ozone air 

quality standards. In our ongoing search for emission reduction strategies, we 

have not identified additional emission reductions with cost effectiveness values 

that could be considered RACT. However, where significant, cost effective 

reductions could be achieved, we have adopted standards that exceed RACT. 

In the specific case of Rule 446, Storage of Organic Liquids, the CTGs (EPA450/2-77-036 and EPA-450/2-78-047) define the source category as tanks with 

capacities greater than 40,000 gallons storing liquids with vapor pressures 

greater than 1.5 psia. We consider the lowering of the applicability threshold to 

10,000 gallons` to be an expansion of the applicability of the CTGs. Section 

182(b)(2) of the Clean Air Act only requires RACT for CTG sources and other 

major sources. Only one major source within our district, Procter and Gamble, 

has tanks less than 40,000 gallons in capacity, and as noted in our RACT 

analysis staff report, these tanks are subject to more stringent controls under 

* Proposed measure for the Midwest Regional Planning Organization in Identification and 

Evaluation of Candidate Control Measures, prepared for the Lake Michigan Air Directors 

Consortium, April 14, 2005. 

777 12th Street, 3rd Floor 1 Sacramento, CA 95814-1908 

916/874-4800 1 916/874-4899fax 

www.airquality.org 
Mr. Andrew Steckel 

October 26, 2006 

Page 2 

Rule 464, Organic Chemical Manufacturing Operations, and the Miscellaneous 

Organics NESHAP. We do not believe it is appropriate to include analysis of an 

expanded CTG category in the present RACT SIP. 

Nevertheless, as part of our plans to achieve aftainment with the federal and 

state ozone air quality standards, our district has analyzed potential emission 

reductions from organic liquid storage tanks. In particular, we examined a 

potential control strategy that would expand the applicability of Rule 446 to 

include tanks with capacities between 10,000 and 40,000 gallons and storing 

liquids with lower vapor pressures (0.5 psia to 1.5 psia). Because of the small 

number of additional tanks that would be required to install controls, such a 

measure was estimated to result in insignificant emission reductions of 0.005 

tons per day of VOC. 

SMAQMD Rule 446 requires pressure-vacuum valves and covers for gauging 

and sampling connections to be maintained in a gas-tight condition. Gas tight is 

defined as an organic compound concentration not exceeding 10,000 ppm 

(expressed as methane) measured 1 cm from the device. The requirement and 

definition are consistent with San Joaquin Valley APCD Rule 4623 and Ventura 

County APCD Rule 70. 

South Coast AQMD Rule 463 defines gas tight as a concentration not exceeding 

1,000 ppm. Bay Area Rule 8-5 defines gas tight as a concentration less than 500 

ppm for pressure-vacuum valves and pressure relief devices and less than 100 

ppm for all other devices. 

The primary emissions from floating roof tanks are working losses that occur 

when liquid is withdrawn, leaks from the primary and secondary seals, and leaks 

from roof fittings and other penetrations. The tool that we use to estimate tank 

emissions, the EPA TANKS program, does not provide us with a method to 

estimate the emission reduction we could achieve by decreasing the gas-tight 

threshold. The CTGs don't address this potential source of emissions from 

leaking pressure-vacuum valves and other gas-tight connections. 

We believe that the emission reductions are likely to be near zero., but we will 

continue to examine the potential emission reductions that could be achieved by 

lowering the gas-tight threshold in Rule 446 as we develop our attainment plans 

for state and federal ozone standards. We do not consider this to be RACT at 

this time. 

3. You have noted in Table 1 of your lefter that several of our district rules have 

been amended after EPA approval as SIP revisions, have not yet received EPA 

approval, or have not yet been submifted to EPA. Our RACT analysis is based 

on the most recent amendments to the district rules. None of the SIP-approved 
Mr. Andrew Steckel 

October 26, 2006 

Page 3 

rules has been relaxed subsequent to approval by EPA. We will submit the most 

recent amendments of all rules that implement RACT. 

4. You have noted that the proposed SIP revision includes specific conditions to be 

added to the permit for the flare at the Kiefer Landfill. As you have requested, we 

will amend the permit to add these conditions prior to submitting the SIP revision 

for EPA approval. 

Thank you for the information that you provided on the future CTGs. We intend to 

submit SIP revisions to address these new CTGs as they are required. 

A public hearing to adopt the proposed SIP revision is scheduled for October 26, 2006. 

If you have any further comments or questions, please contact me at (916) 874-4833. 

Sincerely, 

at, 

Aleta Kennard 

Program Supervisor