3+flED S74r UNITED STATES ENVIRONMENTAL PROTECTIONAGENCY REGION IX 75 Hawthorne Street San Francisco, CA 94105 

### October 23, 2006

Dr. Kevin J. Williams Program Coordinator SacramentoMetropolitan Air Quality Management District 777 12~~ Street, 3'd Floor Sacramento, CA 958 14-1 908 Re: Analysis ofReasonably 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 amongthe most comprehensive submittalswe have reviewed to date. We have summarized some suggestions below for further improvement on the analysis. Because RACT SIPSare 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 ofthe District's analysis. 2. The analysis report indicatesvarious District rules meet or exceed RACT. Particularly where the last RACT determination for specific source categories occurred 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 10,000ppm at 1 cm. Bay Area AQMD Rule 8-5, Storage of Organic Liquids, has a lower applicability threshold and defines gas tight as 100 -

### 500ppm 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 10,000gallons as one ofmany recommendations to tighten RACT. Seepage 19of: htt~://www.ladco.or~/reportslrpo~WRPOproiectsiStr~df. 

### 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. 3. Enclosure 1lists 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 aspossible. 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 flexiblepackaging 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.~ov/ttn/naaqs/ozone/ct~ act/index.htm While the current RACT SIP analysis does not need to addressthese 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..gov/fedr~str/EPA-AIR/2006/May/Day- 161a7405.pdf). Further guidance will be provided 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 asexpeditiously aspossible asEPA cannot consider the RACT SIP analysis complete without the required rules. Final implementation dates should be no later than the first ozone season that occurs 30 months later. For SacramentoMetropolitan 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 (41 5) 947-4

### 122. Sincerely,

Andrew Steckel, Chief, Rulemaking Office Enclosure cc: Ravi Ramalingam (CARB)Table 

### 1

# - Rules 

### to be submitted if needed 

### for RACT Rule Rule413 Stationary Gas Turbines 

# 1 Rule 451 Surface Coating of Misceilaneous Metal Parts and Products 

### I submit 10/2/97amendment Rule 442 Architectural Coatings
- Rule 450 Graphic Arts Operations Amended 3/24/05

Rule 463 Wood Products Coatings I SIP version 5/1/97 5/24/01 3/23/00

Rule 454 Degreasing Operations Rule 456 Aeros~ace Coatincl O~erations 

### 1 12/5/96 submitted 

# 1 7123/98 Submit 7/23/98 amendment 9/5/96 12/5/96

5/23/02 7/23/98



# 1 Rule 466 Solvent Cleaning 

## 1 5/23/02 

## / 4/3/97 9/5/96

Rule 465 Polyester Resin Operations 

## 1 Rule 485 Municipal Landfill Gas 

## 1 7/23/98 

## 1 I 2/6/97 submitted

Enclosure (1) 

### L 

# ! 6'4/98

, Submit 6/4/98 amendment