3+flED S74r 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

October 23, 2006 

Dr. Kevin J. Williams 

Program Coordinator 

Sacramento Metropolitan Air Quality Management District 

777 12~~ Street, 3'd Floor 

Sacramento, CA 958 14-1 908 

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 summarized 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 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 10,000 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: 

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 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.~ov/ttn/naaqs/ozone/ct~ 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..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 as expeditiously as possible 

as EPA 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 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 (4 1 5) 947-4 1 22. 

Sincerely, 

Andrew Steckel, 

Chief, Rulemaking Office 

Enclosure 

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

Rule 

Rule 41 3 Stationary Gas Turbines 

1 Rule 451 Surface Coating of Misceilaneous Metal 

Parts and Products I submit 10/2/97 amendment 

Rule 442 Architectural Coatings - 

Rule 450 Graphic Arts Operations 

Amended 

3/24/05 

Rule 463 Wood Products Coatings I 

SIP version 

5/1/97 

5/24/0 1 

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