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~ s . 2" A°-6 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

~ T REGION IX

~ 75 Hawthorne Street
Pq o Q~ ~ ° San Francisco, CA 94105 - 

### OCT 2 7 2006

October 23, 2006

Dr. Kevin J. Williams Program Coordinator Sacramento Metropolitan Air Quality Management District 777 12 th Street, 3` d Floor 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.epa ov/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,

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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